In response to Official Letter No. 2873/BCT-PC dated April 24, 2026 from the Ministry of Industry and Trade regarding comments on the Draft Resolution on reducing, decentralizing, and simplifying administrative procedures and business conditions, the Vietnam Chamber of Commerce and Industry (VCCI) stated that the draft contains several notable reform efforts, including the removal of business conditions for petroleum port and storage leasing services as well as petroleum transportation services.

However, according to VCCI, the level of reform in this sector remains relatively modest compared to its potential, particularly as many structural barriers have yet to be fundamentally addressed.

The Ministry of Industry and Trade’s process of removing petroleum business conditions remains modest compared to its potential.

Specifically, regarding infrastructure ownership requirements, the draft still maintains conditions that effectively impose a predetermined business model. Under the proposal, wholesale petroleum traders must own or lease a port capable of receiving vessels with a minimum tonnage of 7,000 tons and storage facilities with a minimum capacity of 15,000 cubic meters. They must also operate at least 10 retail outlets (including at least five owned directly by the trader) and maintain at least 40 distributors or agents.

VCCI argued that these regulations essentially allow the State to “pre-design” the scale and organizational model of businesses instead of allowing the market to decide. Under market economy principles, enterprises should be free to choose business models that match their capabilities and development strategies, provided they fully comply with requirements on safety, quality, and environmental protection.

These minimum infrastructure thresholds are considered major barriers to market entry, effectively limiting participation to only a small number of large enterprises. According to VCCI, this not only restricts competition and preserves a concentrated market structure, but may also indirectly affect consumer interests through retail fuel prices.

Regarding the requirement for a minimum lease term of five years, VCCI stated that the regulation is no longer suitable in the context of an increasingly flexible commercial real estate market and the accelerating global energy transition. Mandatory long-term lease contracts may increase financial risks for businesses, particularly as petroleum demand could decline with the growing adoption of clean-energy vehicles.

Based on these analyses, VCCI proposed that the Ministry of Industry and Trade reconsider its regulatory approach by shifting from detailed regulations on business scale and organizational models toward management based on technical standards, reserve obligations, reporting obligations, and market supervision mechanisms.

Specifically, the organization recommended abolishing or significantly reducing requirements related to the number of owned retail outlets, minimum storage capacity, and minimum port tonnage, while replacing them with criteria focused on financial capacity, compliance with safety standards, and minimum reserve obligations. According to VCCI, such an approach would both ensure energy security and create greater opportunities for new enterprises to enter the market, thereby promoting fair competition and delivering practical benefits to consumers.