The fact that the European Commission (EC) on July 13 approved the Delegated Act updating the product catalog and the Implementing Act on the Information System of the EU Deforestation Regulation (EUDR) demonstrates that the enforcement timing of this regulation is drawing near.

Exchanging with the VNA reporter in Brussels, Mr. Tran Ngoc Quan, Trade Counselor of Vietnam in Belgium and the European Union (EU), evaluated that the EU has finalized the consultation process regarding the scope and execution methods, and "the responsibility now belongs to enterprises in seriously executing these regulations when exporting." Following a long period of debate over derivative products, the Delegated Act basically determined the catalog of goods belonging to the scope of regulation, within which supplementing instant coffee, a number of palm oil derivatives, and frozen beef tongue.

Against Vietnam, according to Counselor Tran Ngoc Quan, the most notable alteration is bringing instant coffee into the catalog. He analyzed: "The coffee sector serves as the primary subject bearing impacts from the EUDR and the Vietnamese coffee sector has determined the demand to execute it. Now, instant coffee, a rapidly developing convenient segment, being brought into the application scope will generate challenges for the processing sector." He argued that the challenge lies precisely in the product's characteristics, as instant coffee is usually a blend of multiple coffee types and other raw materials, within which a number of products also contain soybeans or cocoa powder, which also belong to the regulatory scope of the EUDR. The Counselor noted: "Therefore, instant coffee processing enterprises must gather and manage information systems significantly more than the raw material field."

Meanwhile, against the rubber and wood sectors, Counselor Tran Ngoc Quan reassured that this adjustment round "possesses no newly arising issues." Products made of vulcanized rubber, conveyor and transmission belts, aircraft and motor vehicle seats were brought out of the application scope. According to the Counselor, this is viewed as a "welcoming signal for the rubber processing industry, especially recycled products from previous rubber raw materials," but advocacy efforts to remove kitchen tools and utensils from the catalog have not yet succeeded. To determine whether goods belong to the scope of regulation, he set out a simple set of questions for rubber enterprises: is the product made from natural or synthetic rubber; is it recycled goods; is it a vulcanized product. Mr. Quan noted that products made from natural rubber still belong to the regulatory scope.

A new point evaluated by the Vietnamese Trade Counselor to Belgium and the EU Tran Ngoc Quan as a "step forward" of the EUDR lies in the proxy declaration mechanism. Purchasing enterprises and cooperatives can declare on behalf of farmers and individual manufacturing households, and associations can declare on behalf of small enterprises.

The Counselor argued that this mechanism reflects the reality of agricultural trade in developing countries, where goods are purchased from multiple small-scale sources, against a backdrop where farmers still encounter restrictions regarding capacity to approach information and foreign languages. However, the Counselor warned that this is merely a proxy declaration mechanism, while products must still possess full traceability information.

He explained: "To put it simply, each product born must possess an accompanying 'birth certificate' to prove the production time, land plot number, and land-use right." Thus, each shipment needs to be established with a "birth certificate" right from the production stage and this dossier will accompany the product throughout its entire life cycle. Technically, core data encompasses land plot coordinates along with legal information regarding land-use rights and production dates, and cooperatives play the role of intermediate data aggregation hubs instead of thousands of households having to self-access the EU Information System. The Counselor emphasized: "Only in this way can enterprises purchasing goods from thousands of manufacturing households satisfy export conditions into the EU."

Counselor Tran Ngoc Quan also pointed out the gap between regulations in theory and deployment in reality. The Counselor evaluated that the declaration mechanism is described by the EU as "simple and easy to execute," but production and purchasing activities in developing countries primarily still bear a small-scale nature, therefore, even a simplified process can still be complicated against farmers and households.

The Counselor stated that the declaration page is projected to open from the end of July, but merely utilizes the English language. He evaluated that this is a non-trivial barrier against many farming households. Alongside that is the risk of technical incidents occurring when EU information pages and document links are continuously overloaded due to rapidly rising traffic during times nearing the deadline.

Against a backdrop where the legal framework is basically completed and the execution deadline is low in the possibility of continuing to be delayed, Counselor Tran Ngoc Quan emphasized that the EUDR serves as a mandatory regulation. This regulation does not relate to market opening or product quality, but places the focus on data and commodity data governance.

The Counselor emphasized that large enterprises still possess around 5 months before the December 30, 2026 deadline, while small and micro enterprises possess an additional 6-month period. According to him, this serves as the "golden time" for enterprises to switch to product data management systems, under the principle that merely shipments fully satisfying data requirements are eligible for export into the EU; enterprises cannot purchase shipments that are unclear regarding the EUDR to bring into this market.

Therefore, exporting enterprises need to instruct their purchasing systems to support farmers and farms to establish production data, and localities need to instruct producers to declare according to each individual shipment and encourage participating in cooperatives, signing contracts with purchasing companies to receive declaration support.

For its part, the Vietnam Trade Office in Belgium and the EU is and will continuously update the EU's application guidelines to disseminate to enterprises and associations, particularly monitoring specific guidelines from the end of this July. Concurrently, the Trade Office also coordinates with associations in both the EU and Vietnam to jointly dialogue with the EU side. This coordination mechanism has proved efficient when the Trade Office along with the European Confederation of Leather Tanners (COTANCE) successfully advocated bringing leather products out of the regulatory scope of the EUDR during this adjustment round.

Source: Bao Tin tuc va Dan toc -  TTXVN