Rubberwood can be used in furniture and furniture parts. For EUDR scope, start with the product and its customs classification. Covered wooden furniture belongs to the wood entries in Annex I, even when the wood comes from rubber trees. The rubber entries concern specified products in Chapter 40. EUDR, Article 1 and Annex I, as updated by Delegated Regulation 2026/2102.

One tree species does not mean two product categories

The EUDR links relevant products to the commodities listed beside them in Annex I. A wooden furniture part does not become a Chapter 40 rubber product because the tree also produced latex. Our reading of that product-based structure is that rubberwood alone does not create a duplicate wood-and-rubber due diligence obligation for the same wooden part. EUDR, Article 2(1)–(2) and Annex I; Commission guidance on composite products.

Check the actual classification and exclusions. The amended wood entries include specified wooden furniture under ex 9403 and wooden furniture parts under ex 9403 91. Wooden parts of seats have a separate entry, ex 9401 91 90. The current wording excludes used and second-hand products from those entries. A product name alone is not enough to establish scope. Regulation 2026/2102, Annex points (xx)–(yy).

A plantation label does not settle land history

The EUDR excludes agricultural plantations from its definition of forest. The Commission’s guidance explains that this can include rubber plantations, even though they contain trees. That describes the land use; it does not prove what occupied the land before the plantation. EUDR, Article 2(4)–(6); Commission guidance, agricultural plantations.

Wood products must meet the deforestation-free definition, including the 31 December 2020 cut-off and the wood-specific forest-degradation condition. A rubber plantation established through conversion of forest to agricultural use after that cut-off cannot be treated as compliant merely because it is now an agricultural plantation. The plot’s history and the relevant definitions therefore matter. EUDR, Article 2(3), (7) and (13), and Article 3.

What your EU customer needs from you

Article 9 sets the information requirements for the operator’s due diligence. For a Vietnamese manufacturer supplying an EU importer, that translates into a supplier evidence request covering the following areas. This is a practical summary of the information needed, not a separate statutory checklist imposed on every overseas manufacturer. EUDR, Articles 7 and 9.

  • Product and material: the product description, quantities and the common and scientific names of the wood species used.
  • Production origin: the country, the required geolocation of every supplying plot and the relevant production dates or periods.
  • Legality: verifiable evidence addressing the relevant legislation of the country where the wood was produced.
  • Land history: evidence addressing the EUDR requirements on deforestation and forest degradation.
  • Traceability: a clear connection between those sources, the timber received and the products supplied, including mixed wood sources.

Source for these evidence areas: EUDR, Article 9(1); Commission guidance on traceability, legality and composite products.

Separate evidence preparation from EU responsibility

In the usual arrangement where a Vietnamese manufacturer supplies an EU importer, the importer that first places the covered product on the EU market carries the operator’s due diligence responsibility. The manufacturer supplies the underlying information. Different commercial arrangements can change the role analysis, so confirm who is acting as the operator. EUDR, Articles 2, 4 and 7, read with Regulation 2025/2650.

Start with the manufacturer self-check, also available in Vietnamese. For the wider product and timing context, see the Vietnam wood and furniture guide.