A refrigerated bonded warehouse is two regimes stacked: the customs bonded regime treating goods as not yet imported, and the cold-storage regime of the product sector treating temperature as the product’s lifeline. The common misunderstanding is hunting for a ‘standard temperature for bonded cold warehouses’ in the law — that number does not exist; temperature standards follow each product, while bonded law locks only the supervision frame and what happens when goods spoil or expire.
Layer one: the bonded regime applies to a cold warehouse like any bonded warehouse
On the customs side, a refrigerated bonded warehouse is first of all a bonded warehouse: it must be recognised under the conditions in Article 10 of Decree 68/2016/ND-CP (minimum areas, qualifying storage space, management software connected to customs, retrievable surveillance cameras), goods deposited sit under customs supervision with the storage period of Article 61 of the Customs Law 54/2014/QH13 (no more than 12 months, extendable once by up to 12 months), and the operator reports goods status to customs periodically under Article 63. This regime layer contains no temperature clause: it manages goods by declaration and quantity, not storage quality — and no single authority certifies a ‘bonded-standard cold warehouse’ as one merged certificate.
Layer two sits in the business conditions of the goods stored: food must meet food safety conditions for storage facilities, and pharmaceuticals must follow Good Storage Practice (GSP) and Good Distribution Practice (GDP) under the Pharmacy Law 105/2016/QH13 as amended by Law 44/2024/QH15 (effective 1 July 2025). General cold warehouse temperature standards and inspection are analysed in FDI-LC-0837 and EXP-4210; this article handles only the intersection with the bonded regime.
Temperature: standards follow the product, with operator monitoring duties
Storage temperature in a bonded cold warehouse is determined by each consignment’s requirements: the declared storage conditions of the food product (deep frozen, chilled, or controlled room temperature), and for pharmaceuticals the conditions on the label and the drug registration dossier — for example the 2–8°C cold range common for vaccines and biologics. The operator’s legal duty is not ‘achieving one national standard temperature’ but maintaining exactly the committed conditions for each storage zone, recording and monitoring temperature continuously, alerting when temperature leaves the permitted band, and retaining temperature records for inspection by authorities or the cargo owner.
On inspection, ‘who inspects the cold warehouse’ has three answers for three layers: customs inspects bonded warehouse recognition conditions and supervises the goods; the food safety authority inspects food storage conditions under the current framework — and at present it must be noted that Decree 46/2026/ND-CP on food safety has been issued but its application is suspended under Resolution 09/2026/NQ-CP and Resolution 15/2026/NQ-CP until the amended Food Safety Law and new guiding decree take effect, so food safety procedures and conditions in practice still follow Decree 15/2018/ND-CP; and pharmaceutical storage is assessed for GSP/GDP by the health authority. A bonded cold warehouse holding both food and pharmaceuticals must therefore zone its space and bear all three inspection layers at once.
Expired food in the warehouse, and cold storage costs
Food whose shelf life expires while in a bonded warehouse absolutely may not be moved into the domestic market for consumption: expired goods are excluded from every commercial exit and keep only two lawful handlings — re-export out of Vietnam if the receiving country accepts, or destruction under customs supervision under the rules on handling backlogged and expired goods in customs supervision areas, together with food safety rules on recall and destruction of unsafe food. Destruction costs, extended storage and file handling fall on the cargo owner under the warehouse lease and its agreement with the operator; the operator must detect, segregate and report goods nearing or past expiry to the owner and customs rather than let expired stock blend into in-date stock in the warehouse ledger.
On cost, no statutory price table exists for bonded cold storage to answer ‘how many percent more’ precisely: cold storage rent is a market price built from rent for bonded-qualifying premises, continuous refrigeration power, temperature monitoring systems, labour and attached customs service fees — in practice markedly higher than ordinary warehousing at the same location, with the gap varying by the required temperature band (deep freeze costs more than chilled) and storage duration. Businesses should demand itemised quotations rather than one lump figure, because the charges arising when goods stay too long or must be destroyed are what actually blow up cold storage budgets.
Frequently asked questions
What temperature standards must a bonded cold warehouse meet?
There is no single statutory standard temperature for bonded cold warehouses: storage temperature follows each product’s requirements — the declared conditions of the food product, and for pharmaceuticals the label and registration dossier under GSP/GDP principles (Pharmacy Law 105/2016 as amended by Law 44/2024/QH15). The operator’s duty is to maintain the committed band for each zone, record and alert continuously, and retain traceable records.
Who inspects cold warehouses?
Three layers, three authorities: customs inspects bonded warehouse recognition conditions (Decree 68/2016/ND-CP) and supervises goods; the food safety authority inspects food storage conditions — still under Decree 15/2018/ND-CP because Decree 46/2026/ND-CP is suspended by Resolutions 09/2026 and 15/2026/NQ-CP until the amended Food Safety Law and new guiding decree take effect; the health authority assesses GSP/GDP for pharmaceutical storage.
How is expired food in a bonded warehouse handled?
It may not enter the domestic market for consumption. Expired goods may only be re-exported (if the receiving country accepts) or destroyed under customs supervision under the backlogged and expired goods rules, together with unsafe-food recall and destruction rules. The operator must segregate and report expired goods; destruction and storage costs fall on the cargo owner under the lease.
How much more does bonded cold storage cost?
No statutory price table exists for a precise percentage: bonded cold storage rent is a market price (bonded-qualifying premises, 24/7 refrigeration power, temperature monitoring, customs services), in practice markedly higher than ordinary warehousing and varying by temperature band (deep freeze costs more than chilled) and storage time.
This article has been quality-reviewed by the FLAW AI Legal Council