Forests under 4 ha may use single GPS coordinate for timber exports to the EU

Under the EUDR, all timber products placed on the EU market must demonstrate that they did not cause deforestation or forest degradation after December 31, 2020. One of the mandatory pieces of information is the geographical coordinates of the harvesting plot, defined by longitude and latitude under the WGS84 reference system, with a minimum of six decimal digits.

Accordingly, the guidance issued by the Department of Forestry and Forest Protection clearly differentiates requirements based on the size of the harvesting plot. For plots of 4 ha or larger, forest owners are required to collect the coordinates of the corner points forming polygons that fully represent the plot boundaries. However, plots smaller than 4 ha only need to provide the coordinates of a single point located within the plot, preferably near its center.

The Department further recommends that, where conditions permit, polygon coordinates should be collected even for small plots to enhance the level of detail of the dossier. However, this is not a mandatory requirement.

Geographical coordinates are a component of the documentation package demonstrating compliance with the EUDR, alongside documents on legal land-use rights, harvesting records, forest product inventories, and compliance commitments by entities throughout the supply chain. Providing coordinates alone does not replace other legal obligations of forest owners.

The document also clearly states that the absence of valid coordinate information means the dossier lacks sufficient grounds for EU importers to conclude a "negligible risk" level. In such cases, the consignment will not be permitted to enter the EU market.

The coordinate requirements apply uniformly to planted forest timber, rubberwood harvested for timber, and other types of timber falling within the scope of the EUDR. Specifically for rubberwood, the dossier must additionally include information on the year of planting, the year of harvesting, and plantation liquidation records, together with the coordinates of the harvesting plot.

In addition to the requirements on geographical coordinates that are considered mandatory technical conditions within the traceability system under this regulation, the Department of Forestry and Forest Protection also clearly defines the responsibilities of entities in the timber supply chain and their corresponding actions.

Accordingly, forest owners take upstream responsibility. They must establish boundaries and geographical coordinates for each harvesting plot, demonstrate legal land-use rights, and provide harvesting documentation in accordance with regulations.

Organizations and individuals engaged in timber harvesting are responsible for developing harvesting plans linked to geographical coordinates, conducting harvesting strictly in line with approved plans, and fully measuring and declaring harvested timber volumes. After harvesting, all documentation must be handed over to the buyer, including the harvesting plan, forest product inventory, and relevant legal documents, ensuring traceability for each plot.

Sawmills and pre-processing facilities may only receive timber lots with valid origin documentation. These facilities must manage input and output materials by lot, maintain internal traceability systems, and ensure that high-risk materials are not mixed with timber lots that meet EUDR requirements. Upon transfer of products, all origin documentation must be fully passed on to the next buyer.

Enterprises and traders involved in procurement act as intermediaries and are responsible for screening suppliers, purchasing only timber with complete, lawful documentation linked to harvesting plot coordinates. The aggregation process must ensure the integrity of documentation accompanying each lot and ensure full handover to processing facilities or exporting enterprises, together with a commitment to comply with the EUDR.

Timber processing enterprises are required to establish internal traceability systems to ensure that all materials used in production can be traced back to the harvesting plot. Enterprises may only use materials that meet EUDR requirements and must assess and exclude high-risk material lots. For imported timber, enterprises must additionally collect coordinate information of harvesting plots from the country of origin and manage each lot separately.

Exporting enterprises are responsible for summarizing and transferring the complete set of origin documentation to EU importers. Although exporting enterprises do not directly submit the Due Diligence Statement (DDS), they are responsible for conducting internal risk assessments to ensure that the documentation provided meets the "negligible risk" threshold. All related documentation must be retained for a minimum of five years to facilitate verification upon request by EU partners or competent authorities.

According to the risk list issued by the European Commission (EC) in May 2025, Viet Nam has been classified by the EU as a low-risk country under the EUDR framework, based on assessments of deforestation trends, legal frameworks, and enforcement in the country of origin. For countries classified as low risk, EU authorities will conduct post-clearance inspections on only about 1% of consignments or exporting enterprises.

The Department of Forestry and Forest Protection also notes that the obligation to submit the Due Diligence Statement (DDS) lies with the EU importer, not with Vietnamese organizations or individuals.