Vietnam's Coffee Sector and EUDR: Why Low-Risk Status Still Leaves a Data Gap

Vietnam is classified low risk under the EUDR's official country benchmarking, so buyers sourcing coffee from Vietnam get simplified due diligence under Article 13. That is a genuine advantage. It is not, however, a substitute for good supplier data, and Vietnam's coffee sector currently has a real plot-level traceability gap that a low-risk badge does not fix.

Why Vietnam matters to any EUDR coffee strategy

Vietnam is the world's second-largest coffee producer and by far the largest producer of robusta. In 2025 it shipped around 666,000 tonnes of coffee to the EU worth roughly $3.63 billion, up 26% in volume and 68.3% in value on the year before, and the EU regularly takes about 40% of all Vietnamese coffee exports (VnEconomy). Almost any EU roaster or importer buying robusta at scale has Vietnamese coffee somewhere in the mix, whether they specified it or not.

What "low risk" actually buys you

Under the EUDR's country classification (Implementing Regulation (EU) 2025/1093), every country is benchmarked low, standard or high risk. Only four countries are high risk. Vietnam sits in the low-risk tier alongside other major producers that surprise people, such as India, Thailand and Ghana.

Low risk unlocks Article 13 simplified due diligence: operators can skip the in-depth risk assessment and mitigation steps that standard- and high-risk sourcing requires. It does not remove the underlying obligations. You must still collect geolocation for every plot, confirm the coffee was not grown on land deforested after 31 December 2020, confirm it was legally produced, and file a due diligence statement (or, for eligible micro and small primary operators, a simplified declaration) in the EU Information System.

Low risk is also a regulatory classification, not a data quality guarantee. Nothing about the tier tells you whether the geolocation your supplier sent you actually corresponds to the plot the coffee came from.

The data gap on the ground

Two recent findings show why that distinction matters.

A 2025 survey by Forest Trends and Tavina found that nearly 60% of Vietnamese smallholder coffee farmers did not maintain reliable harvest records, and only around 10% kept detailed plot-level data (Koltiva). As one contributor to that report put it, "the key differentiator is not certification logos but access to verifiable, auditable data," and land legality verification, not the geolocation coordinates themselves, is the harder obstacle underneath.

Separately, exporters have flagged a more specific problem: the same farmland is turning up in more than one company's production-area database, because several buyers have independently registered data from overlapping smallholder networks (VnEconomy). One large exporter, Vinh Hiep, has reportedly invested VND30 to 40 billion (roughly $1.15 to 1.54 million) to rebuild and re-verify its production-area database household by household, including GPS coordinates, and says verified coffee now covers around 40% of its EU-bound exports. That is a serious undertaking for one exporter, and it illustrates how much manual verification work sits behind a "low risk, simplified due diligence" label.

What this means if you buy Vietnamese coffee

None of this means Vietnamese coffee is harder to source than coffee from a standard-risk origin. It means the compliance risk has moved from the regulatory tier to the data itself, and that is where your own checks should focus.

• Ask which entity generated the geolocation data, and whether it was collected directly from the farm or inherited from a certification scheme or cooperative register. Certification is useful evidence but is not itself EUDR compliance.
• Watch for duplicate or overlapping plots across your supplier base. If two of your suppliers, or a supplier and its neighbour's, report the same coordinates, that is a sign the underlying data was aggregated rather than collected household by household.
• Keep the reference number, not just the certificate. Once your supplier files a due diligence statement or simplified declaration, the reference and verification numbers from the EU Information System are what you actually need to retain and pass on.
• Do not assume low risk means low urgency. Article 13 simplifies your own risk assessment step; it does not extend the 30 December 2026 deadline for large and medium operators, or push back your need to have geolocation and legality evidence in hand well before then.

This is general guidance, not legal advice, and country risk classifications are reviewed periodically, so it is worth checking the current Country Classification List before you finalise a sourcing decision.

What to do next

• Check a supplier country's current tier against the country risk tool.
• Work through the EUDR Checklist to see what evidence you still need to collect.
• See the coffee compliance guide for the full commodity-level obligations.