EUDR and Coffee Wood Dog Chews: Who Files, When, and What Your Supplier Must Hand You
EUDR for coffee wood dog chews: who files the due diligence statement, which dates apply, and the plot data a Vietnamese supplier must provide.
By WINVN · · 7 min read
From 30 December 2026 (30 June 2027 for micro and small importers), a wooden dog chew cannot be placed on the EU market unless a due diligence statement has been filed for it under the EU Deforestation Regulation (EUDR). Most questions we receive get the direction of the obligation wrong: buyers ask the supplier to "become EUDR compliant", when the filing and the liability sit with the EU importer. What the supplier owes is data.
Short answer: the EU operator that first places the chews on the EU market, normally the importer, files the due diligence statement. Large and medium operators, and downstream operators and traders of any size, apply the rules from 30 December 2026; micro and small operators importing these goods should have until 30 June 2027. The supplier's job is to hand over plot geolocation, the production period and evidence that the land was not forest after 31 December 2020. WINVN supplies that for its Dak Lak sourcing, with coordinates under NDA.
Does the EUDR cover coffee wood dog chews?
Yes. Annex I of Regulation (EU) 2023/1115 defines the wood scope by customs heading, and it includes ex 4421, other articles of wood. Coffee wood chews are most often entered under heading 4421. The chew is not exempt because it is a pet product, and not exempt because the tree was an agricultural crop rather than forest timber. See the HS code for coffee wood dog chews for the classification reasoning.
Who files: the operator, not the exporter
Regulation (EU) 2025/2650 amended the EUDR in December 2025. Two points matter for this product:
- The operator that first places the goods on the EU market files the statement. For a container shipped from Ho Chi Minh City to Rotterdam, that is the EU importer. A Vietnamese exporter has no account in the EU information system and cannot file for you. There is no "supplier EUDR certificate" in the regulation; anyone offering one is describing something the law does not contain.
- Downstream operators and traders no longer file their own statement. If you buy from an EU operator that has already filed, you collect and keep the reference number of that first statement.
The dates
| Date | Applies to |
|---|---|
| 30 December 2026 | large and medium operators; downstream operators and traders of any size; micro and small enterprises for products that were listed in the annex of the old EU Timber Regulation (Regulation (EU) No 995/2010) |
| 30 June 2027 | micro and small enterprises and natural persons, for the remaining products |
| 31 December 2020 | not an application date: the deforestation cut-off. The land must not have been forest after this date |
The annex of the old EU Timber Regulation listed specific wood headings (4401 to 4418, pulp and paper, and certain furniture and prefabricated buildings). Heading 4421 was not among them, so a micro or small importer of coffee wood chews should fall under the 30 June 2027 date. Check your company-size category and product scope with your adviser, and note that your supplier's data has to be ready either way. A medium or large importer, or any downstream operator or trader, should plan for 30 December 2026.
Sources: European Commission, Access2Markets notice on the EUDR delay and simplification; Council of the EU press release of 18 December 2025.
What you need from the supply side
| Data point | Where it comes from |
|---|---|
| HS code | your customs entry (commonly heading 4421) |
| Description and quantity | commercial invoice and packing list |
| Country of production | certificate of origin (EUR.1) |
| Scientific name | phytosanitary certificate, which records the genus Coffea |
| Plot geolocation | supplier only: latitude and longitude to six decimal places; a plot of 4 hectares or less needs a single point |
| Production period | supplier only: for coffee wood, the harvest registration date |
| Evidence the land was not forest after 31 Dec 2020 | supplier only: planting year and land-use documents |
The top four rows you already hold. The bottom three are the reason to start the conversation with your supplier now rather than in December.
What WINVN holds
For the Dak Lak sourcing, each lot is backed by three Vietnamese documents held by the partner processing yard that buys the standing trees:
- A purchase contract for the standing coffee trees between the grower and the yard.
- A harvest registration filed with the commune People's Committee before cutting.
- A report endorsed with the commune People's Committee's seal confirming that registration.
On the documented example plot in Cu Kuin district, Dak Lak, the trees were planted in 1996, 24 years before the EUDR cut-off, and the plot is 1 hectare, so a single coordinate point describes it. The cut is a replanting cut: old, low-yielding trees come out and the land goes back into coffee.
What this dossier is not: it is not a satellite deforestation analysis, a third-party audit or a certification. The commune confirms a registered harvest, not forest cover. If your risk assessment needs remote-sensing verification, commission it against the coordinates we supply.
Why the coordinates are not published
The document set that proves the plot also carries the grower's national ID number, date of birth, home address and signature. Publishing it would be a personal-data breach under Vietnamese rules and, for a European audience, under the GDPR. So the commune, district, province, planting year and plot area are public; the coordinates, the grower's name and the signed contract go to buyers under an NDA.
The part that does not favour Vietnam
Vietnam signed a Voluntary Partnership Agreement with the EU in 2018, but its FLEGT licensing scheme is not yet operating. According to the European Commission, Indonesia is the only partner country with an operating licensing system. If your buying policy requires FLEGT-licensed timber as a hard condition, Vietnamese coffee wood cannot meet it, and we would rather you know that during qualification.
What WINVN does not claim
- WINVN is not an EUDR operator and does not file due diligence statements.
- WINVN issues no "deforestation-free certificate", because the regulation creates no such supplier document.
- The dossier described covers the Dak Lak sourcing. Ask per lot, and ask before you order.
- No environmental marketing claim is made: no biodegradability rate, no carbon figure.
A realistic sequence before December 2026
- Now: ask every wood supplier for a sample plot dossier and the geolocation format they can deliver.
- On the first order: take the plot data for the actual lot, not a specimen, and check the commune matches the origin on the EUR.1.
- Before December: decide whether your risk assessment needs remote-sensing verification on top of the documents.
- From 30 December 2026: file as the operator, keep the reference number and pass it downstream.
Questions buyers ask
Can a Vietnamese supplier file the EUDR statement for me?
No. The operator placing the goods on the EU market files it. The supplier provides the data that goes into it.
When does the EUDR apply to wooden dog chews?
From 30 December 2026 for large and medium operators and for downstream operators and traders of any size. Micro and small operators placing chews under heading 4421 on the market should have until 30 June 2027, because 4421 was not listed in the old EU Timber Regulation's annex. Confirm your category with your adviser.
What geolocation format is needed?
Latitude and longitude to six decimal places for each plot. A plot of 4 hectares or less can be described by one point rather than a polygon.
Request the EUDR document set with your destination country. We will send the redacted dossier, the commune and planting year, and the coordinates under NDA.
