A Vietnamese supplier can manufacture furniture using wood harvested in another country. Vietnam’s low-risk classification does not automatically apply to that wood. The EUDR defines the country of production by where the relevant commodity was produced. The country list and the production-country definition must therefore be read together. EUDR, Article 2(24); Regulation 2025/1093, Annex.

Start with where the trees grew

Vietnam appears in the low-risk list in Implementing Regulation (EU) 2025/1093. For wood, the relevant origin is the country where it was grown and harvested. Processing that timber into furniture in Vietnam does not change its country of production for EUDR purposes. Country classification; Commission guidance, country of production and composite products.

For example, if a manufacturer combines Vietnamese wood with timber from another country, the importer needs to establish the origins of both. It cannot use the furniture factory’s address as the origin of all the wood. Article 9 requires the production country and the geolocation of the plots that supplied the relevant commodities. EUDR, Article 9(1)(c)–(d).

Imported timber is not automatically higher risk: its production country may itself be classified as low risk. Check the actual country against the current list. Countries that are neither low nor high risk remain standard risk. EUDR, Article 29(2); Regulation 2025/1093.

What simplified due diligence changes

Article 13 allows operators to omit the risk assessment and risk mitigation obligations in Articles 10 and 11 when its conditions are met. Before relying on that simplification, the operator must assess supply-chain complexity and the risk of circumvention or mixing with unknown-origin material or material from standard- or high-risk countries. It must establish that the relevant commodities and products were produced exclusively in low-risk countries or parts of countries. EUDR, Article 13(1); Commission guidance on simplified due diligence.

This is a narrower shortcut than “no checks needed”. If new information or substantiated concerns point to non-compliance or circumvention, the operator must fulfil Articles 10 and 11 and immediately communicate relevant information to the competent authority. EUDR, Article 13(2).

What you still need

For an EU importer placing covered products from outside the EU on the market for the first time, the information requirements remain. They include the product and wood species, quantities, production countries, plot geolocation and production dates or periods, supplier details, and adequately conclusive and verifiable evidence of deforestation-free and legal production. The collected information must be retained for five years and supplied to competent authorities on request. EUDR, Article 9.

The due diligence system and the due diligence statement are not waived by the country’s low-risk status. The importer must meet its operator obligations before placing the relevant products on the market. These obligations are distinct from the rules for downstream operators and traders. EUDR, Articles 4, 8 and 12, read with the 2025 amendment.

Three questions for your supplier file

Our practical starting point is to ask:

  • Which country and plots supplied each wood source in this order?
  • Can the evidence be connected to the products and shipment you will import?
  • Does any mixed or uncertain source prevent you from relying on simplified due diligence?

These questions help you organise a review; they do not replace the legal assessment. Use the eight-question importer self-check to identify gaps in your preparation, or read the application-date guide for small furniture importers.