Explosives Licensing and Controls in Bangladesh

by Barrister Tahmidur Rahman | Sep 14, 2026

Trade, Competition & RegulationLicences for explosives and magazines9 min read

Explosives Licensing and Controls in Bangladesh

Practical legal advice from our Dhaka team on explosives licensing in Bangladesh for mining, quarrying, construction, energy, seismic survey and industrial clients, covering Department of Explosives licences for import, manufacture, storage, transport, use and sale, magazine approvals, contracts, renewals and enforcement.

Overview

Explosives licensing in Bangladesh: the legal framework

Explosives are used in Bangladesh for coal and hard-rock mining, stone quarrying, tunnelling, foundation and demolition work, oil and gas seismic surveys and well services, and in some manufacturing processes. Every stage of their life, from import or manufacture through storage, transport and use to disposal, requires authorisation. Explosives licensing is administered by the Department of Explosives under the Energy and Mineral Resources Division. We advise project companies, contractors, suppliers and industrial users on these requirements within our regulatory practice in Bangladesh, coordinating with technical safety specialists. Our advice covers the full life of a licence.

The core legislation is the Explosives Act 1884, which continues to apply in Bangladesh, and the Explosives Rules made under it, most recently the Explosives Rules 2004 as amended. These require licences for the manufacture, possession, use, sale, transport and import of explosives, set requirements for magazines and storage, and give inspectors powers of entry, inspection and seizure. The Explosive Substances Act 1908 creates serious criminal offences for unlawful possession and use, which is one reason the regulators and security agencies treat compliance strictly and expect complete, accurate records. Explosives licensing therefore demands careful preparation.

Licence categories distinguish between the type and quantity of explosives, the activity, and the premises. A magazine licence, for example, depends on approved site plans, safety distances from buildings, roads and other installations, construction standards, security arrangements and a competent person in charge. Use licences for blasting typically require qualified personnel and procedures for each site. Imports usually need both an explosives licence and compliance with the current Import Policy Order, and the agencies involved may consult security authorities before approval. Each category has its own conditions. Security clearance can take time and should be planned for.

For foreign contractors on major infrastructure and energy projects, explosives licensing often sits on the critical path. Blasting may be needed early in a project, but licences cannot be obtained until the contractor has a local entity or arrangement, approved premises and qualified staff, and the licence will generally be held by a named Bangladeshi licensee. Construction contracts should allocate responsibility for obtaining and maintaining licences, the consequences of delay, and the handling of explosives at completion. Getting the structure right early avoids costly interruptions. Explosives licensing should be planned before mobilisation.

We advise on the legal steps: identifying licences, structuring who holds them, preparing applications with technical consultants, drafting supply, storage and blasting subcontracts, and responding to inspections or enforcement. Barrister Tahmidur Rahman advises on project and contract aspects, and our litigation team acts where a licence is suspended or cancelled or an incident leads to investigation. We do not provide blast design or safety engineering. For project disputes, see our dispute resolution practice, or contact our Dhaka office. We work in Bangla and English. Our role is legal and documentary.

01 · What we handle

Core workstreams

  • Licensing roadmap
  • Applications and documentation
  • Import and supply arrangements
  • Project and subcontract terms
02 · How it runs

Four clear stages

  1. 01Scope the activity
  2. 02Prepare applications
  3. 03Contract and comply
  4. 04Respond and close out
03 · Start here

Talk to a partner

Consultations in Dhaka or by video. Scope, team and fees are agreed in writing first.

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How we help

How we help project companies and contractors

Workstream 01Trade, Competition & Regulation

Licensing roadmap

  • Scope the activity
  • Prepare applications
  • Contract and comply
  • Respond and close out
Workstream 02Trade, Competition & Regulation

Applications and documentation

  • Scope the activity
  • Prepare applications
  • Contract and comply
  • Respond and close out
Workstream 03Trade, Competition & Regulation

Import and supply arrangements

  • Scope the activity
  • Prepare applications
  • Contract and comply
  • Respond and close out
Workstream 04Trade, Competition & Regulation

Project and subcontract terms

  • Scope the activity
  • Prepare applications
  • Contract and comply
  • Respond and close out
Workstream 05Trade, Competition & Regulation

Renewals and changes

  • Scope the activity
  • Prepare applications
  • Contract and comply
  • Respond and close out
Workstream 06Trade, Competition & Regulation

Inspections, incidents and enforcement

  • Scope the activity
  • Prepare applications
  • Contract and comply
  • Respond and close out
01

Licensing roadmap

We identify every authorisation the activity requires, from import and magazine licences to transport, use and sale licences, and the related environmental, fire, factory and local approvals. We set out the order in which applications should be made, which entity should hold each licence, and the documents and technical inputs needed, so that blasting can start when the project programme requires. Gaps in documents or technical inputs are flagged early, with a timetable showing which approval depends on which.

02

Applications and documentation

We prepare explosives licensing applications with the client's technical team, including site plans, magazine designs, safety distance assessments, security arrangements, personnel qualifications and standard operating procedures. We check for consistency between technical documents and the application, manage correspondence with the Department of Explosives and attend meetings and inspections where appropriate. Explosives licensing queries are answered promptly and in writing. Before any site inspection, we brief the client's team on the likely questions and the documents inspectors will ask to see.

03

Import and supply arrangements

We advise importers and end users on import licences, Import Policy Order conditions, customs clearance, and transport from the port to licensed storage. We draft and review supply agreements covering specifications, packaging and labelling, licensing responsibilities, delivery to licensed premises, risk and title, insurance and the return or destruction of surplus or deteriorated explosives at the end of the contract. Title and risk are clearly allocated. Cover for transit and storage should be checked against the licence conditions and the contract.

04

Project and subcontract terms

On construction, mining and energy projects, we draft the clauses that allocate explosives licensing responsibilities between employer, main contractor and blasting subcontractor: who applies, who holds the licence, who bears delay risk, compliance obligations, incident reporting and indemnities. Clear terms avoid disputes when a licence is delayed or a regulator orders blasting to stop. Explosives licensing risk is priced properly.

05

Renewals and changes

Licences must be renewed on time and amended when quantities, premises, personnel or ownership change. We maintain renewal calendars, advise on notifications for changes such as a new magazine or a change in the person in charge, and plan the licensing consequences of mergers, share sales, project transfers and the demobilisation of foreign contractors. Reminders are sent well before each expiry date so that renewal papers can be assembled without a last-minute rush. Explosives licensing calendars are shared.

06

Inspections, incidents and enforcement

Where inspectors identify breaches, issue directions, suspend or cancel a licence, or an incident leads to investigation by the regulator or police, we advise immediately on the client's rights and obligations, preserve evidence, prepare responses and represent the client in proceedings. Prompt, accurate engagement often limits the damage, while poorly handled communications can make an incident far worse. Site records, logbooks, inspection reports and communications should be preserved from the outset, as they often decide the outcome.

RecognitionThe Legal 500Asia Pacific ranks Tahmidur Remura Wahid (TRW) Law Firm for dispute resolution in Bangladesh.
Cross-border reach6 jurisdictionsMatters coordinated with counsel in the UK, US, UAE, China, India and Singapore.
Bar and admissionsDhaka and LondonBarristers and advocates in Bangladesh, with a solicitor of England and Wales (non-practising).
HeadquartersDhakaHouse 410, Road 29, Mohakhali DOHS. Consultations in person or by video.
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01

Who issues explosives licensing approvals in Bangladesh, and which other agencies are involved?

Licences under the Explosives Act 1884 and the Explosives Rules are issued by the Department of Explosives, headed by the Chief Inspector of Explosives, under the Energy and Mineral Resources Division of the Ministry of Power, Energy and Mineral Resources. Depending on the activity and location, other authorities are also involved, including the district administration, the police and security agencies, the Department of Environment, the fire service and local authorities. We identify every body involved for a given project, because a missing approval from any of them can delay operations even when the explosives licence itself is granted.

02

Can a foreign contractor on an infrastructure project hold an explosives licence directly?

Licences are generally issued to a person or entity in Bangladesh with responsibility for licensed premises and activities. A foreign contractor without a local presence will usually need a Bangladeshi entity, a registered branch or a licensed local partner or subcontractor. Investment and branch registrations, now handled through Invest Bangladesh, trade licences and tax registrations must be in place first. The structure affects liability, insurance and control over the explosives. We advise foreign contractors on the options early, so that explosives licensing does not hold up mobilisation. The chosen structure should be settled before tendering.

03

What does a magazine licence application involve, and where do problems arise?

A magazine licence application typically includes a site plan showing safety distances from buildings, roads, power lines and other installations, construction drawings meeting prescribed standards, details of the maximum quantity and types of explosives to be stored, security and fire protection arrangements, and the name and qualifications of the person in charge. Inspectors usually examine the site before approval. Problems commonly arise where land is acquired before safety distances are checked. We coordinate with engineers so the legal application reflects a site that can actually be approved. Site selection is the decisive step.

04

Do we need a separate licence to transport explosives?

Transport of explosives is regulated, and licences or permits are generally needed covering the vehicle, the route or movement, quantities, packaging, escort and security arrangements. Transport from a port to a magazine, from a magazine to a blasting site, and between sites can each raise requirements. Carriers and drivers must meet conditions, and incidents during transport carry serious consequences. Contracts with logistics providers should require compliance and allocate responsibility clearly. We review the explosives licensing position for each movement in the client's supply chain. Each movement must be covered. Route planning should be documented.

05

How long does it usually take to obtain explosives licences for a new project?

Timing depends on the licence category, the quality of the application, site inspection scheduling and consultation with other agencies. Simple renewals can move relatively quickly, while new magazines and import licences take longer, especially where security clearance is required. We do not quote fixed timelines because they vary. For project planning, we recommend starting explosives licensing as soon as the site and the responsible entity are known, and building realistic regulatory time and float into the construction programme and the contract. Delay clauses should reflect this. Explosives licensing delay is a foreseeable project risk.

06

What are the consequences of using explosives without a valid licence?

Unlicensed manufacture, possession, storage, transport or use of explosives is an offence under the Explosives Act and can also engage the Explosive Substances Act 1908, which carries severe penalties. Explosives can be seized, sites closed and individuals prosecuted. Lapsed licences, use beyond licensed quantities and storage at unlicensed premises are all treated seriously. Directors and managers should understand that personal exposure is possible. We advise on immediate corrective steps if a lapse is discovered and represent clients in any resulting investigation or prosecution. Quick legal advice protects individuals. Lapses should never be ignored.

07

Are fireworks and pyrotechnics covered by explosives licensing?

Fireworks and pyrotechnic articles generally fall within the explosives framework, and their manufacture, import, storage and sale require licences, with particular attention to retail storage and public safety. Event organisers and importers of display fireworks should confirm the position well in advance, as approvals may also be needed from the police and local administration. Safety flares and pyrotechnics carried on vessels or used in industry may raise their own questions. We advise on the licences needed for each activity and the conditions typically attached. Seasonal demand needs planning ahead. Retail sellers face particular scrutiny.

08

What should happen to surplus explosives at the end of a project?

Surplus, deteriorated or unused explosives must be dealt with in accordance with licence conditions and the rules, which may mean return to the supplier, transfer to another licensee with approval, or destruction under supervision. Licences may also need to be surrendered or amended when a magazine closes. Contracts should address these steps, including costs and responsibilities, before work begins. We advise on demobilisation planning for contractors leaving Bangladesh so that explosives licensing obligations are closed out properly and no residual liability remains. Final reports should be kept on file. Documents should be retained afterwards.

How a matter runs

From first call to resolution.

  1. 01

    Scope the activity

    We review the project, the explosives involved, sites, quantities and timetable, identify every licence and approval needed, and agree which entity will hold each explosives licensing approval and when applications start. We flag likely risks, such as a missing local entity or qualified staff, and agree a realistic timetable with you.

  2. 02

    Prepare applications

    With the client's engineers and safety specialists, we compile site plans, technical documents, personnel records and security arrangements, then file applications and follow up queries from the Department of Explosives. We support the client during inspections and keep a complete file of submissions, correspondence and approvals.

  3. 03

    Contract and comply

    We draft supply, transport, storage and blasting subcontracts that match the licences, and set up renewal calendars, record-keeping and internal compliance checks for the operational phase of the project. Site staff are briefed on licence conditions, and periodic compliance checks are scheduled so problems surface before inspectors find them.

  4. 04

    Respond and close out

    We respond to inspections, directions and incidents, defend enforcement proceedings, and manage licence surrender, transfer or destruction of surplus explosives when operations end. After any incident, we record the lessons learned and update site procedures. At project end, we obtain written confirmation that each licence has been properly closed out.

“Demonstrates an extraordinary command over both domestic litigation and international arbitration.”

The Legal 500 Asia Pacific, Bangladesh: Dispute resolution, client feedback

FAQ

Questions, answered.

Still unsure? Email info@trw.co with a short outline of the matter.

What is explosives licensing?
Explosives licensing is the system of permissions required to manufacture, import, store, transport, sell or use explosives. In Bangladesh it is governed by the Explosives Act 1884 and the Explosives Rules, and administered by the Department of Explosives. Licences specify the activity, premises, types and quantities of explosives, and conditions on safety, security and record-keeping. Explosives licensing also covers renewals, amendments when circumstances change, and the closing out of licences when an activity ends. Because explosives carry obvious security risks, the regulator expects licensees to treat their conditions as continuing obligations rather than a one-off approval.
Does the Department of Explosives also regulate LPG, petroleum and gas cylinders?
Yes. Alongside explosives, the Department of Explosives administers licensing for petroleum storage, LPG and compressed gas cylinders and certain other dangerous substances under separate legislation and rules. Businesses handling several of these materials may need multiple licences from the same department, each with its own conditions and renewal dates. Coordinating these applications in one plan saves time and reduces the risk that one lapsed licence disrupts operations. It also means the department sees a consistent picture of the business across every file it holds. Renewal dates should be tracked together.
Are explosives licences transferable when a business or project is sold?
Licences are issued to a named licensee for specified premises and activities and are not freely transferable. A share sale may leave the licensee unchanged but can still require notification. An asset sale or project transfer usually requires the buyer to obtain its own licences. Explosives licensing should be part of transaction due diligence and completion planning. Buyers should verify every licence, check renewal dates and inspection history, and build conditions and warranties into the sale documents so that operations can continue lawfully from completion day. Sellers should prepare a clear licence schedule in advance.
What records must explosives licensees keep?
Licensees are generally required to keep registers of receipts, issues, consumption and stock of explosives, with details of quantities, dates and persons involved, and to make them available for inspection. Accurate records are essential, because discrepancies can suggest loss or diversion and lead to serious consequences. Registers should be reconciled regularly with physical stock, checked by a responsible manager and kept for the period required. Electronic records are useful but should be backed up and protected against alteration. Gaps in records are one of the first things inspectors look for during an explosives licensing review.
Do we need to report a theft or loss of explosives?
Loss or theft of explosives must be reported promptly to the authorities, including the police and the licensing authority, under the rules and licence conditions. Delay in reporting can itself be an offence and can raise suspicion. Licensees should have a written procedure for immediate reporting and evidence preservation. Early legal advice helps make sure the report is accurate, that internal investigation does not compromise the police inquiry, and that the business protects its position while cooperating fully. Insurers may also need prompt notice under the policy terms.
Is environmental clearance also needed for blasting operations?
Often yes. Quarrying, mining and major construction projects generally require environmental clearance from the Department of Environment, and blasting operations may be subject to conditions on vibration, noise, dust and community safety. Explosives licensing and environmental approvals should be planned together. Environmental conditions may affect permitted blasting hours, charge sizes and monitoring requirements, so the two sets of approvals must be consistent. Community complaints about vibration or flyrock can quickly escalate into regulatory action, which careful planning and good records help to avoid. Explosives licensing applications should refer to the environmental position.
Can we import explosives for a single construction or mining project?
Project-specific imports are possible, subject to licences, import policy conditions, customs procedures and security clearance. The importer must have licensed storage ready before arrival. Quantities should be planned carefully, because surplus explosives at project end must be returned, transferred with approval or destroyed. Explosives licensing for a single project should also anticipate delays in the project programme, since explosives held in storage longer than expected may deteriorate or exceed licensed periods, and licence conditions can limit how long stocks may be kept. Planning quantities carefully saves cost.
Can TRW design our blasting programme or safety distances?
No. Blast design, safety distance calculations and handling procedures are technical work for qualified explosives engineers and safety professionals. Our role is legal: licensing strategy, applications, contracts, regulatory engagement and enforcement. We work with the technical experts our clients appoint. This division of roles keeps explosives licensing applications technically sound and legally accurate, and ensures that each document is prepared by someone qualified to stand behind it if the regulator asks questions.

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