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EUDR Due Diligence by Shipment Lot
How to run due diligence as a lot-level workflow for Vietnam-sourced coffee and rubber — without treating certificates as a substitute for plot data.
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EUDR Due Diligence by Shipment Lot
An EUDR due diligence system is not a single policy document. For importers sourcing from Vietnam, it is a repeatable workflow that ties evidence to each shipment lot before you file a due diligence statement.
In this article, a production plot is the land where coffee or rubber is grown; a shipment lot is one export shipment (often one container) those plots feed into.
Step 1: Collect information by shipment lot
Collect what you will later use to justify the statement:
- product details and one consistent product code set,
- production plots that contribute to the shipment lot,
- plot location data (point or polygon, as required by plot size),
- how evidence moves from source actors to the shipment,
- legality evidence under Vietnamese law where needed.
Step 2: Assess data risk — not only country risk
Vietnam is listed as low risk. That simplifies risk assessment and mitigation. It does not remove plot location or legality requirements.
Check whether:
- plot data actually links to this shipment lot,
- the same plot appears to be claimed across overlapping buyer files,
- certificates (if any) have been verified again — not trusted one-way.
Sector certificates are useful context. They are not a substitute for shipment-lot-specific plot and chain evidence in the EU declaration workflow.
Step 3: Close gaps where they matter
If assessment shows gaps, close them:
- missing or wrong coordinates,
- missing land or legality documents,
- broken links through middlemen,
- suspected plot overlap between operators.
Prefer reuse of verified data first. Collect new field data only where the shipment lot still cannot be supported.
Documents to keep
Build a file you can retrieve when authorities ask:
- supplier and plot files tied to the shipment lot,
- legality evidence and supporting notes,
- risk rationale and what was checked,
- proof of gap-fill actions (or why none were needed),
- retention for at least five years.
Where the Desk helps
The Desk packages Vietnam-side evidence by shipment lot: completeness checks, overlap flags when needed, and a handoff pack your team can use in the declaration workflow. The EU operator remains the statement owner.
Sources
- Regulation (EU) 2023/1115 (EUDR) consolidated text: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A02023R1115-20241226
- Articles 3–4: market conditions and operator obligations
- Articles 8–9: due diligence system and information requirements (including plot location)
- Article 13: simplified approach for low-risk countries (plot location and legality still required)