Many foreign traders whose customers are factories in industrial parks want to place their representative office right inside the park for working convenience. The ‘is it allowed’ question has two layers: the location layer — whether the park lets a liaison office lease space; and the activity layer — an office inside a park very easily slides into coordinating production and warehousing, work outside a representative office’s scope.
The location layer: leasing space in the park and licensing authority
Industrial parks under Decree 35/2022/ND-CP are areas for industrial activities and industry-serving services, managed by industrial park and economic zone management boards under a one-stop mechanism. A representative office is a non-production presence; placing its head office inside an industrial park depends on valid leasable office space in the park — usually the infrastructure investor’s office zone or factory premises with a planned office portion — and a lease signed with the party holding leasing rights in the park. Licensing authority for the office establishment remains the Department of Industry and Trade under Decree 07/2016/ND-CP for ordinary cases; the park management board performs delegated state management functions in the park such as labour and investment for in-park projects — businesses should confirm locally the actual receiving points for their office’s reports and procedures to avoid filing at the wrong desk. The baseline condition is unchanged: the lease address must be usable as a head office, with clear property papers and leasing rights, so the licence file is not stuck at the location step — leasing part of a factory without a valid office function to ‘park an address’ is a risky practice detected as soon as the authority verifies the location.
The activity layer: the slide temptation when sitting next to customer factories
The real risk of an in-park office lies not in location but in conduct: next door to production customers, the office easily drifts into tasks such as coordinating orders, inspecting quality with signed confirmations, managing sample or pending-delivery warehouses, receiving complaints and handling payments — many of which are contract performance and service supply, beyond a representative office’s liaison and promotion scope. Office staff are also easily seen by customers and by their own colleagues as the parent’s ‘Vietnam operations team’, creating expectations and documents in that direction. Keeping scope in this setting requires concrete discipline: all quality confirmations, acceptances and delivery documents must be performed by the parent or a licensed unit in Vietnam; the office only observes, reports and relays information; no commercial goods are stored at the office premises; office staff are trained to properly refuse ‘sign for us’ requests from factories. If the in-park presence need is in substance to run part of a supply chain, the correct form is no longer a representative office: the business should consider an FDI enterprise with corresponding functions or hiring a licensed service provider in the park, rather than letting a representative office carry a role it is not permitted to carry.
Frequently asked questions
1. Can a representative office be located inside an industrial park?
Yes, provided valid office space can be leased in the park — through the infrastructure investor or the party holding leasing rights — and activities stay within liaison and promotion scope. The establishment licence is still issued by the Department of Industry and Trade under Decree 07/2016; the park board manages delegated matters inside the park.
2. Can a corner of a factory be leased as the RO’s address?
High risk. The head office location must have valid function and papers for office placement; part of a factory without a planned office area used to ‘park an address’ is easily examined by the licensing authority and refused, or handled after an inspection finds the office not operating at the registered address.
3. May an in-park RO coordinate deliveries and inspect quality for customers?
Coordinating contract performance, signing quality confirmations, acceptances or managing goods warehouses is business performance activity, beyond a representative office’s scope. The office may only observe, gather information and report to the parent; legally effective confirmations must be made by the parent or a licensed unit.
4. Who manages an RO located inside an industrial park?
Licensing and activity reports follow the licensing Department of Industry and Trade; the industrial park and economic zone management board performs state management inside the park in delegated fields such as labour and investment. Businesses should confirm the specific receiving point for each procedure locally to file each item at the right place.
5. When should an in-park presence be a company rather than an RO?
When the purpose is running a supply chain, managing warehouses, performing paid technical services or any revenue-generating activity in the park. That is the need of a business-function enterprise, and forcing it into a representative office creates beyond-scope violations by design.
Key takeaways for investors
- Allowed if valid office space is leased in the park; licensing still via the DOIT under Decree 07/2016.
- Do not use a factory corner without office function to ‘park an address’ — location verification risk.
- The main risk is conduct: coordinating deliveries and signing quality confirmations exceed RO scope.
- A need to run supply chain inside the park is a need for an enterprise, not an RO.
This article has been quality-reviewed by the FLAW AI Legal Council