A cold store is not “an ordinary warehouse with air-conditioning”: for food and pharmaceuticals, a few hours of temperature deviation can destroy a whole batch and trigger product-safety liability. When leasing cold storage in Vietnam, an FDI enterprise must check three layers at once: the refrigeration system’s temperature bands and technical reliability; the sector standards tied to licences (GSP for pharmaceuticals, food-safety conditions for food); and lease terms allocating equipment risk. This article organises all three.
1. Temperature bands by goods group: where every requirement starts
The four most common bands: cool storage around 15–25°C for ordinary drugs and heat-sensitive dry food; positive cold 2–8°C for vaccines, biologics and most refrigerated medicines (this is the mandatory band for vaccine storage under the health sector standard); chilled 0–4°C for processed fresh food; and frozen from −18°C down (typically −20 to −25°C) for frozen food and certain special preparations. The core diligence point is not the nominal figure but: temperature uniformity across the store (temperature mapping — where the hot and cold spots are), the swing amplitude when doors open constantly at peak in/out hours, and recovery speed after an incident. Require the lessor’s latest mapping report and 3–6 months of temperature log data — a compliant cold store always has this data; a warehouse unable to produce historical temperature data is the single biggest risk signal in the whole diligence.
2. Pharmaceuticals: the GSP storage standard is a licence condition
For pharmaceuticals, drug storage premises must meet Good Storage Practice for medicines and medicinal ingredients (GSP) under Circular No. 36/2018/TT-BYT: separate zones for each storage condition, continuous automatic temperature/humidity monitoring and recording, out-of-limit alarms, procedures for handling goods exposed to deviations, and trained personnel. GSP compliance assessment attaches to the issuance of the Certificate of eligibility for pharmaceutical business for the storage facility — meaning the leased site and its compliance status directly decide the enterprise’s licence. When leasing a third party’s pharmaceutical warehouse (a service warehouse), diligence must cover that warehouse’s own current GSP certification status and the duty to maintain it throughout the term; if leasing an ordinary warehouse and self-investing refrigeration to seek GSP, factor assessment and remediation time into the opening schedule. Distinguish clearly: storing one’s own medicines differs from commercially storing medicines for others — the latter is a conditional pharmaceutical business line and the service warehouse must hold the corresponding licence itself.
3. Food: the storage warehouse’s food-safety conditions
Food storage warehouses must satisfy food-safety conditions under the Law on Food Safety No. 55/2010/QH12 and fall within the scope of facilities issued a Certificate of food safety eligibility, except cases outside the certification scope. On the applicable framework, investors should know one point specific to October 2026: Decree No. 46/2026/ND-CP is the new framework replacing Decree No. 15/2018/ND-CP on food-safety management; however, the application of Decree 46/2026 is currently suspended under Resolution No. 09/2026/NQ-CP and Resolution No. 15/2026/NQ-CP until the amended Food Safety Law and a new guiding decree take effect — during this suspension, food-safety condition and certification procedures in practice still follow Decree No. 15/2018/ND-CP. Technically, a food cold store must separate zones by goods group (raw/cooked, food products separate), control pests and harmful animals, and trace each lot’s temperature history — major buyers (retail chains, exporters) commonly audit additionally against HACCP/ISO 22000, which are market standards rather than state licences.
4. Specific technical risks and refrigeration lease terms
Three technical risks must enter the contract. First, fire in cold stores — foam-core insulation panels are a fast fire-spread source; suppression in frozen stores must be dry-pipe systems or equivalent because water pipes freeze; the warehouse’s fire acceptance must match the stored goods group. Second, industrial ammonia (NH₃) refrigeration — efficient for large stores but a hazardous chemical: require the operator’s safety appraisal documents, leak detection sensors and incident-response procedures. Third, power: refrigeration is a load that must never lose supply — the contract must fix the supply configuration (dual feed or single feed plus generator), transfer time, minimum reserve fuel, technical availability (SLA) and a penalty/rent-deduction mechanism when temperature deviates due to the lessor’s system failure, plus the tenant’s right to real-time access to temperature logger data. Electricity for refrigeration is usually the cold store’s largest cost and is typically borne by the tenant on a separate meter — settle clearly who owns and who maintains compressors and cooling units, because replacing an industrial refrigeration set costs as much as many months of warehouse rent.
Frequently asked questions
The warehouse holds the owner’s GSP — must a tenant storing its own drugs there be re-assessed?
It depends on the model: if the enterprise buys storage services at a warehouse already certified for pharmaceutical business eligibility (storage activity), the storage occurs under the owner’s licence and GSP standard; if the enterprise itself operates a warehouse zone for its own pharmaceutical activity, that storage facility must be GSP-assessed within the enterprise’s own licensing dossier. Fix the model in the contract, because compliance responsibility differs entirely.
Warehouse temperature deviates for a few hours due to a power cut — how are the drugs handled?
Under GSP standards, a batch exposed to a storage-condition deviation must be quarantined and stability-assessed (the manufacturer’s stability data, deviation duration and amplitude) before deciding on continued circulation or destruction; it must never be mixed back into compliant stock on one’s own authority. This is why a pharmaceutical warehouse lease must contain an immediate-incident-notice clause and full logger-data handover to the tenant.
Can a frozen warehouse with foam panels pass fire acceptance?
It can, if design and materials meet the applicable technical regulation (QCVN 06:2022/BXD) with suppression solutions suited to cold stores and the goods group — in practice many lawfully operating cold stores use insulation panels achieving the fire rating of the appraised design. The check is whether the existing fire acceptance minutes cover exactly your warehouse configuration and goods group, not the panel material standing alone.
How does renting per pallet (storage service) differ from leasing cold-store space?
Per-pallet service is a storage-service contract: you buy storage positions and operating services under the operator’s licence/standards and do not hold the premises. Leasing cold-store space is an asset lease: you operate yourself and bear the sector standards and facility-linked licences yourself. The service model is fast and light on investment; the space model gives higher control and suits large, stable volumes.
This article has been quality-reviewed by the FLAW AI Legal Council
