Chinese-invested factories in Vietnam must do more than complete licensing before commencing operations — throughout operation, they must be ready to receive fire prevention and fighting (FPF) and environmental inspection teams. This article guides enterprises on preparing dossiers, on-site conditions and personnel ahead of each inspection, under the current legal framework as of 14 October 2026. (Licensing procedures belong to a separate article and are not repeated here.)
1. The legal framework governing inspections
- Law 55/2024/QH15 on Fire Prevention, Fighting and Rescue (effective 1 July 2025) — the new FPF law replacing the old framework;
- Decree 105/2025/ND-CP — implementing guidance, with Article 13 on periodic inspections;
- Decree 106/2025/ND-CP — administrative penalties for FPF violations (amended by Decree 69/2026/ND-CP, effective 20 April 2026);
- Circular 36/2025/TT-BCA — FPF equipment and facilities;
- Law on Environmental Protection 2020 — Articles 39 and 40 (environmental licenses), Article 46 (trial operation), Article 160 (inspection).
Terminology note under the new framework: official documents use “appraisal of fire prevention designs” — not the old term “approval” (tham duyet). All citations from superseded FPF and environmental decrees (136/2020, 50/2024, 167/2013, 144/2021; 18/2015, 40/2019) have expired.
2. Periodic FPF inspections: who inspects, and in what order?
Under Article 13 of Decree 105/2025/ND-CP, the commune-level People’s Committee organizes annual periodic FPF inspections of facilities in its area under a strict procedure:
- The inspection plan must be prepared before 15 December of the preceding year;
- The facility must be notified at least 3 days in advance;
- The inspection is recorded in minutes using Form PC03.
Enterprises may proactively request to see the annual inspection plan to prepare in advance, rather than reacting after receiving the notice.
3. FPF dossiers to have ready before the inspection team arrives
- Document on appraisal of fire prevention designs for the factory;
- Document on acceptance of FPF commissioning results — proving the facility was accepted before being put into use;
- Dossiers of the grassroots FPF force (roster, establishment decision, training records);
- The approved firefighting and rescue plan;
- Certificate of compulsory fire and explosion insurance;
- Logs of inspection and maintenance of FPF systems and equipment under Circular 36/2025/TT-BCA;
- Minutes of previous inspections and records of remedying outstanding issues (if any).
4. On-site conditions the inspection team will examine
- FPF equipment within its service life, operational, and periodically maintained;
- Escape routes, signage and fire alarm systems unobstructed;
- The grassroots FPF force present and familiar with the factory firefighting plan;
- Warehouses and workshops storing flammable goods arranged in compliance with safety rules.
In practice, many Chinese-invested factories are cited more often for incomplete dossiers than for missing equipment — reviewing dossiers during the 3-day notice window is the cheapest way to avoid violations.
5. Environmental inspections during operation: what to prepare
- A valid environmental license (GPMT) matching the licensed scope (Articles 39 and 40 of the 2020 Environmental Protection Law);
- Periodic environmental monitoring results (emissions, wastewater, waste) at the frequency the license requires;
- The hazardous waste generator register and handover records to licensed handlers;
- Trial operation dossiers for waste treatment facilities before official operation (Article 46);
- Waste treatment facilities operating as designed, with complete operation logs.
6. Factories inside industrial parks
For factories in industrial parks, export processing zones or hi-tech parks: part of the FPF and environmental work is handled through the Industrial Park Management Board. Enterprises must clarify which tasks the Board is responsible for and which the enterprise must perform itself — to avoid the “we thought the Board handled it” situation when inspectors request dossiers.
Frequently asked questions
What if the FPF inspection team arrives before we have prepared the dossiers?
The law requires at least 3 days advance notice (Article 13 of Decree 105/2025) — enterprises should use exactly this window to review and supplement dossiers and check the site.
Can a newly operational factory be inspected right away?
Yes. Besides annual periodic inspections under the plan, authorities may conduct surprise inspections upon signs of violation or incidents.
Which factories must buy compulsory fire and explosion insurance?
Factories on the list of fire- and explosion-hazardous facilities must buy it — keep the insurance dossier ready when inspectors request it.
What does periodic environmental monitoring cover?
Depending on the environmental license: typically emissions and wastewater monitoring, plus hazardous waste management reports — keep all results for presentation.
Sources
- Law 55/2024/QH15 on Fire Prevention, Fighting and Rescue — effective 1 July 2025;
- Decree 105/2025/ND-CP: Article 13 (periodic inspection: plan before 15 December, 3-day notice, Form PC03 minutes);
- Decree 106/2025/ND-CP (FPF administrative penalties, amended by Decree 69/2026/ND-CP effective 20 April 2026);
- Circular 36/2025/TT-BCA (FPF equipment);
- Law on Environmental Protection 72/2020/QH14: Articles 39, 40 (environmental licenses), Article 46 (trial operation), Article 160 (inspection).
For reference only; not legal advice. This content was prepared by AI and will undergo quality review by the AI Legal Council of FLAT Law Firm before any publication consideration; it is not the legal opinion of a licensed human lawyer. Laws and regulations may change; verify the current legal texts before applying them.
Does your factory need a readiness review for FPF and environmental inspections? Contact FLAT Law Firm for advice.
