Logistics Service Providers as Compliance Intermediaries: Reallocating Traceability Obligations in Vietnam’s Agro-Forestry Export Supply Chains

The European Union Deforestation Regulation, applicable from 30 December 2026, shifts the market barrier facing Vietnam’s three leading agro-forestry exports, coffee, rubber and timber and timber products, from product attributes to an obligation of proof grounded in data. Existing scholarship concentrates on smallholders and exporting firms, leaving unanswered the question of who actually creates, holds and transmits traceability data once goods leave the processing plant. Using desk research with a four-tier source-reliability protocol, this study constructs a matrix contrasting statutory responsibility with de facto control over data. The findings reveal a structural misalignment: legal responsibility is concentrated in the EU importer, whereas the data determining compliance resides with collectors and logistics service providers, actors bearing no statutory duty. The study proposes the concept of the compliance intermediary, specifies three conditions for its emergence and four conditions for its effective operation, and cautions that low-risk country status exempts operators only from risk assessment, not from the underlying information requirements.