VCCI recently submitted its official feedback to the Ministry of Industry and Trade regarding the drafted dossier for the “Project on Developing Specialized Industrial Clusters and Large-Scale Industrial Complexes” (hereafter referred to as the Draft).

According to VCCI, the initiative is both timely and essential, providing a cohesive strategic framework for two distinct industrial models that, despite featuring prominently across various Party and State policy documents, have consistently underperformed against expectations.

VCCI has welcomed several positive shifts within the draft, notably its conceptual distinction between industry clusters (built on network connectivity) and industrial complexes (characterized by integrated production systems). This organization also commended the framework for recognizing that the State’s role is to facilitate collaboration rather than enforce it via administrative fiat, while aligning foreign investment incentives with commitments to cultivate domestic supply chains.

However, to ensure the project's success, VCCI has advised drafters to refine several policy mechanisms. The overarching goal must be to foster a transparent, equitable business environment that avoids imposing additional administrative friction on enterprises.

Eliminating redundant approvals and legal overlaps

A primary concern flagged by VCCI centers on the assessment and approval process for industrial complexes. The Draft’s summary report outlines a legal framework governing development criteria, application dossiers, core enterprise commitments, and the regulatory authority required for project approval. It further stipulates that individual complexes must present comprehensive operational plans before receiving formal authorization.

VCCI cautions that, if operationalized, these stipulations could saddle component projects with a redundant layer of bureaucratic hurdles over and above existing investment, industrial zone, and economic zone procedures.

Crucially, the draft remains ambiguous as to whether securing approval for an industrial complex serves as a mandatory pre-condition for launching component projects or simply acts as a baseline qualifier for State support. Without clear demarcation, this novel mechanism risks inflating administrative overhead and compliance costs for businesses.

Furthermore, while the concept of "industrial complexes" already appears within specialized legislation, including the Railways Law, the Chemicals Law, and regulations governing national defense and security industries, and is currently proposed in the draft Law on Key Industries, the draft fails to harmonize these new provisions with existing statutes.

Consequently, VCCI recommends explicitly defining that the selection of priority complexes and the approval of their blueprints serve strictly to channel State support, rather than constituting a new tier of investment or business licensing for component projects. Policymakers must also clarify how this policy framework interfaces with existing legal instruments to prevent regulatory duplication.

Guarding against unfair competition

Another critical issue raised is the latent risk of market distortion and inequality between "core enterprises" and independent investors operating within the same complex.

Under the draft, priority complexes are designated based on existing core projects helmed by specific major corporations. These core enterprises help identify supply gaps and investment prospects and qualify for infrastructure development incentives. Simultaneously, they shoulder the responsibility of sharing operational data regarding production demands, technological requirements, supplier networks, and future investment blueprints.

VCCI warns that when a single core enterprise simultaneously controls shared infrastructure and contributes to mapping out component projects, independent investors may find themselves at a severe disadvantage when attempting to access essential utilities such as ports, power grids, gas pipelines, and waste treatment systems.

Although the draft report nods to core tenets of transparency, voluntary participation, fairness, and competition law compliance, these principles are conspicuously absent from the text of the draft decision itself.

Moreover, data disclosures mandated by core enterprises could inadvertently compromise proprietary commercial secrets. VCCI has therefore pressed for explicit safeguards to guarantee non-discriminatory, open access to shared infrastructure, alongside statutory provisions ensuring that data-sharing remains strictly voluntary and stringently confidential.

Adopting open criteria to foster innovation

Reviewing the historical bottlenecks affecting industrial clusters and complexes, VCCI asserts that the Draft must conduct a more rigorous evaluation of the legal barriers, procedural bottlenecks, and compliance costs that currently stifle production linkages.

Regarding geographic targeting and priority sectors, the current draft hones in on specific industries and localities, such as electronics in Bắc Ninh and Hải Phòng or automotive manufacturing in Hải Phòng and Đà Nẵng.

While localized targeting can successfully anchor industrial policy, an overly restrictive scope risks blunting competitive dynamics and shutting out other regions and sectors possessing high growth potential from vital policy support mechanisms.

To counteract this, VCCI advocates for the establishment of open, merit-based criteria for industrial agglomeration. This would enable localities that meet specific benchmarks in scale and collaborative capacity to be officially recognized as industry clusters, thus unlocking access to appropriate support frameworks.