Logistics Law in Bangladesh: Carriers, Forwarders, Warehouses and Claims in 2026

Logistics law in Bangladesh: the 2026 framework

Logistics law in Bangladesh is not found in one statute. It is assembled from a Victorian carriers statute, the Contract Act's rules on bailment, the Road Transport Act 2018, the Inland Shipping Ordinance 1976, the Customs Act 2023 and a growing body of National Board of Revenue licensing rules, with the National Logistics Policy 2025 sitting above them as a statement of direction rather than binding law. For a shipper, forwarder, trucking operator, warehouse owner or e-commerce platform, the practical consequence is that liability, licensing and insurance must be worked out leg by leg, because each leg of a journey can be governed by a different rule.

This guide maps that patchwork as it stands in October 2026. It covers freight forwarders and clearing and forwarding agents, trucking and road carriage, rail and inland water transport, the absence of a multimodal transport regime, inland container depots and bonded warehouses, the liability of carriers and forwarders, cargo insurance, contracts and claims, and last-mile e-commerce delivery. It also explains where the 2025 and 2026 reforms are taking the sector, and what to do now to protect a supply chain that runs through Chattogram, Dhaka and the inland waterways.

Summary: Bangladesh has no single logistics code. Road and inland carriers are governed by the Carriers Act 1865 and contract law, warehouses and depots by the law of bailment and the Customs Act 2023, agents by NBR licensing rules made under section 243 of that Act, and vehicles and vessels by the Road Transport Act 2018 and the Inland Shipping Ordinance 1976. The National Logistics Policy 2025 sets the reform agenda but had not been implemented by mid-2026. Contracts, documents and insurance therefore carry most of the risk allocation.

Key point: A freight forwarder's house bill of lading is not a bill of lading in law. The High Court Division has held that a forwarder that neither owns nor charters the vessel has no authority to issue one, so its house bill is at most a receipt and is not a document of title. Banks, buyers and insurers who treat it as one take a risk the law does not cover.

At a glance

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Table of Contents

How logistics law in Bangladesh is put together

The first thing to understand about logistics law in Bangladesh is that it is organised by mode and by activity, not by supply chain. A container of garments moving from a factory in Gazipur to a buyer in Europe may pass through a trucking contract, an inland container depot, a clearing and forwarding agent, a freight forwarder's house bill, the port and the ocean carrier. Each of those relationships has its own source of law, its own standard of liability and its own time limits for claims.

Four layers do most of the work. The first is general private law: the Contract Act 1872 on agency, bailment and damages, and the Carriers Act 1865 on common carriers. The second is transport regulation: the Road Transport Act 2018 for vehicles and drivers, the Railways Act 1890 for rail, and the Inland Shipping Ordinance 1976 for inland vessels. The third is customs control under the Customs Act 2023, which licenses agents and warehouses and decides when goods may move. The fourth is sector policy, now led by the National Logistics Policy 2025. The bodies that administer logistics law in Bangladesh are correspondingly spread across government and industry.

Ocean carriage under bills of lading, the Hague Rules and the Admiralty Court is a related but distinct regime, covered in our guides to maritime law in Bangladesh and cargo loss and short-delivery claims. This guide concentrates on the land, inland water, warehousing and agency legs that sit either side of the sea voyage, where most disputes in practice begin.

The National Logistics Policy 2025: direction, not yet law

Bangladesh adopted its first National Logistics Policy on 28 April 2024, after drafting that began at the end of 2020. The interim government revised it on 6 November 2025, on the view that the original did not adequately address graduation from least developed country status.[11] The revised National Logistics Policy 2025 was announced in a gazette on 19 November and aims to position Bangladesh as a leading regional trade and logistics hub by 2050.[12]

What the policy commits to

The policy calls for a technology-driven, integrated logistics system; priority for multimodal infrastructure; digitised tracking and tracing; the harmonisation of laws, regulations and procedures on trade, investment, customs and logistics; measurable performance indicators; and more domestic and foreign investment across logistics sub-sectors.[12] The Ministry of Commerce is the lead ministry for formulation and implementation.[11]

Why it does not yet change legal rights

A policy is not a statute. It does not create causes of action, alter limitation periods or override the Carriers Act or the Customs Act. Its importance lies in the regulatory direction it signals.

That direction has so far moved slowly: in July 2026, nine months after the revision, reports said no working group had been formed, no stakeholder meetings had been held and no implementation roadmap existed. Implementation would require coordination among more than a dozen ministries and agencies, and some business groups have proposed a national logistics authority instead of the committees the original policy envisaged.[11] Businesses should plan on the existing statutes for the foreseeable future and treat the policy as a guide to where licensing and digitisation reforms will come from.

Freight forwarders: licensing, ownership and the house bill problem

Freight forwarders arrange carriage, consolidate cargo and issue their own transport documents. They are not carriers in the traditional sense, but they often contract as if they were, and that tension drives many disputes.

The licensing framework

The Customs Act 2023 defines an agent to include a shipping agent, a clearing and forwarding agent, a cargo agent and a freight forwarding agent, and section 243 provides that no person may act as an agent for business relating to the entry or departure of a conveyance, or the import or export of goods, at any customs station without a licence, with the procedure left to rules.[1] Freight forwarders have been licensed under the Freight Forwarders Rules 2008, which allowed wholly foreign-owned companies to obtain licences. A 2015 amendment capped foreign ownership without saying what happens when an existing wholly foreign-owned licence is renewed.[3]

The 2025 to 2026 rewrite

The National Board of Revenue has circulated draft Freight Forwarders Rules 2025. The draft would treat companies licensed before it takes effect as licensed under the new framework, but it does not state renewal conditions, and in June 2026 the Danish Embassy asked the NBR to confirm that firms lawfully established as wholly foreign-owned under the 2008 rules can renew without meeting the requirements for new applicants. The EU has raised the issue as a non-tariff barrier.[3]

The debate sharpened in September 2026. Ahead of an NBR meeting on the licensing rules on 20 September, the Bangladesh Freight Forwarders Association (BAFFA) urged the NBR not to license fully foreign-owned companies, asked for a full economic and regulatory impact assessment before any major change, and proposed removing the one per cent tax deducted at source on gross billing. Officials at the Investment Bangladesh Authority, the successor to BIDA, took the opposite view, arguing that fully foreign-owned firms would improve efficiency, transparency and competition.[4] Until the final rules are gazetted, foreign-owned forwarders should keep their licence history, ownership records and renewal correspondence in order, because the transitional wording will decide their position.

The house bill of lading is not a document of title

In Freight Management Ltd v Bangladesh Bank, decided on 23 December 2013 and reported at 68 DLR (2016) 493, freight forwarders challenged a Bangladesh Bank practice on the endorsement of house and master bills. The High Court Division refused the writ and, in doing so, held that a forwarder that is neither owner nor charterer of the vessel has no authority to issue a bill of lading. A house bill issued by a forwarder acting only as agent is at most a receipt for the goods and an authority to contract for carriage; it is not a document of title, falls outside the Bills of Lading Act and is unlikely to be good tender under a CIF contract.[7]

The commercial consequences are significant. For logistics law in Bangladesh this is one of the most important rulings of the last decade. A buyer paying against a house bill under a letter of credit may not acquire the rights a true bill would give. A cargo claimant may find that its contract is with a forwarder whose own terms limit liability, while its claim against the ocean carrier depends on a master bill it never held. Shippers should know which document they are getting and in what capacity the forwarder signs: as agent, or as contracting carrier.

C&F agents and customs brokerage

Clearing and forwarding agents act for importers and exporters before customs. Since 2026 they are licensed under the Customs Clearing and Forwarding Agent Licensing Rules 2026, made under section 243 of the Customs Act 2023, which replaced the Customs Agent Licensing Rules 2020. Applicants need at least a bachelor's degree, joint local and foreign companies qualify only where foreign ownership is 49 per cent or less, an individual may hold only one licence, and each application must name a single customs station. Accepted applicants sit written and oral examinations run by the Customs, Excise and VAT Training Academy in Chattogram.[2]

The principal is bound by the agent

Section 245 of the Customs Act is the provision importers most often overlook. Anything an owner of goods is bound or empowered to do under the Act may be done by an authorised agent, and anything the agent does is presumed, unless the contrary is proved, to have been done with the owner's knowledge and consent, so that the owner is exposed to proceedings as if it had acted itself. The agent carries the same rights, obligations and liabilities as the owner, although duty short-levied for reasons other than the agent's wilful act, negligence or default is not recoverable from the agent.[1]

In practice this means a misdeclaration by a careless agent becomes the importer's problem. A written agency agreement should define the agent's authority, require the importer's sign-off on classification and value, allocate penalties caused by the agent's default and require professional indemnity cover where available. Licensees, importers, exporters and agents must also keep business records for three years and produce them on demand.[1] Our C&F agent licensing practice advises on applications, renewals and licence changes.

Road carriage: trucking under the Road Transport Act 2018 and the Carriers Act 1865

Most domestic freight in Bangladesh moves by truck, and two quite different laws apply. The Road Transport Act 2018 is regulatory: it governs vehicles, drivers and roads and is enforced by the authorities. The Carriers Act 1865 is private law: it decides who pays when goods are lost or damaged in transit.

Regulatory compliance for goods vehicles

The Road Transport Act 2018 was passed on 19 September 2018 and took effect nationwide on 1 November 2019. Overloading, meaning exceeding the approved laden weight of vehicle, goods and fuel combined, carries a fine of up to Tk 1 lakh, a year's imprisonment or both. Driving without a licence carries Tk 25,000 or six months; running an unregistered vehicle Tk 50,000 or six months; operating without a fitness certificate a Tk 25,000 fine; and unlawful modification of a vehicle's dimensions, wheels or brakes up to Tk 3 lakh.[8]

These penalties fall primarily on drivers and owners, but cargo interests have reasons to care. Overloaded or unfit trucks are more likely to be detained, to crash and to give an insurer grounds to dispute cover. A shipper's transport contract should require the haulier to use registered, fit vehicles within their laden weight, with licensed drivers, and should allocate fines and delay caused by non-compliance.

Proposed amendments

Transport owners and workers have pressed for changes since the Act came into force. On 13 March 2024 the cabinet approved an amending bill that would reduce punishments in a number of sections and fines in others, make most previously non-bailable offences bailable except where a crash causes death or serious injury, and add a requirement for vehicle insurance with a Tk 3,000 fine for an uninsured vehicle.[9] Cabinet approval is not enactment. Until an amendment is passed and in force, compliance programmes and contracts should be built on the 2018 text, and any reduced figure should be checked against the law actually in force on the date of the offence.

Common carrier liability for goods

The Carriers Act 1865 defines a common carrier as a person, other than the government, engaged in the business of transporting property for hire from place to place by land or inland navigation for all persons indiscriminately. Its scheme is short and demanding:

• Declared-value goods: under section 3 a carrier is not liable for loss of goods of the kinds listed in the Schedule, such as valuables, above a low statutory value, unless their value and description were expressly declared at handover; under section 4 the carrier may charge extra for the risk.
• No contracting out by notice: under section 6 liability for ordinary goods is not limited by a public notice, although a carrier may limit it by a special contract signed by the owner or the owner's authorised agent.
• Negligence and criminal acts: under section 8 the carrier is liable for loss caused by the criminal act or negligence of itself or its agents or servants.
• Reverse burden: under section 9 the plaintiff need not prove negligence or a criminal act in a suit for loss, damage or non-delivery.
• Notice before suit: under section 10 no suit may be brought unless written notice of the loss or injury was given before the suit and within six months of the time the loss first came to the plaintiff's knowledge.[5]

Two practical lessons follow. First, a haulier's printed conditions mean little unless the shipper signed a special contract accepting them, so trucking companies that want to cap liability should obtain signed terms, and shippers should read what they sign. Second, the six-month notice is a trap for the unwary: a cargo owner who negotiates informally for months without serving written notice can lose the claim entirely.

Rail and inland water carriage

Bangladesh Railway

Carriage by rail sits outside the Carriers Act. The 1865 Act's provision on railways was repealed by the Railways Act 1890, which now governs the liability of the railway administration for goods it carries.[5] Rail freight, including container services between Dhaka and Chattogram, therefore needs its own review of the railway's conditions of carriage, its claim procedure and the risk notes signed at booking.

Inland waterways

Inland water transport carries a large share of bulk cargo such as cement clinker, fertiliser, fuel and grain. The Inland Shipping Ordinance 1976 requires inland ships to be surveyed and registered; a certificate of survey is generally valid for one year, or four for dumb barges and similar unpowered craft; and a ship may not proceed on a voyage without valid survey and registry certificates. Owners and masters must provide reasonable facilities for receiving, forwarding and delivering goods without discrimination between shippers, dangerous goods may be carried only on prescribed conditions, and loading that endangers the vessel or carrying goods above the load line are offences.[10]

The Ordinance does not contain a cargo liability code. A cargo claim against an inland vessel operator is therefore usually framed under the Carriers Act, which expressly covers carriage by inland navigation, and in contract and bailment.[5] Before chartering a lighter vessel, check its survey and registry certificates, its load line and the owner's insurance; an unregistered or unsurveyed vessel is both an enforcement risk and a warning sign for any later claim.

Multimodal transport: a gap in the statute book

Many shipments move under a single contract covering truck, depot, feeder and ocean legs. Bangladesh does not have a dedicated statute regulating multimodal transport operators or prescribing a uniform liability regime for door-to-door carriage; the National Logistics Policy 2025 lists multimodal infrastructure as a priority but does not itself create such a regime.[12] The practical result is a network system by default: the rule that applies depends on the leg on which loss occurred, which is often impossible to prove for a sealed container.

Parties fill the gap by contract. A well-drafted multimodal contract should state who the contracting carrier is, the liability regime for each leg and for concealed loss, monetary limits, notice periods and time bars, the governing law and the forum. Where FIATA or carrier standard terms are used, read their incorporation carefully, because the Carriers Act requires a signed special contract to limit liability for ordinary goods.[5] Our practice pages on successive-carrier rail consignments and electronic road consignment records address cross-border structures.

Warehousing, inland container depots and bonded warehouses

Warehouses and depots as bailees

A warehouse, depot or transport yard that takes possession of goods is a bailee under the Contract Act 1872. The High Court Division has treated the Chittagong Port Authority as a statutory bailee whose liability for landed goods is governed by sections 151, 152 and 161 of the Contract Act, subject to the port's own working rules.[6] In broad terms the bailee must take the care of the goods that a person of ordinary prudence would take of its own goods, is not liable for loss despite that care absent a special contract, and is responsible for loss caused by failure to return the goods at the proper time.

The fire and explosion at the BM Container Depot in Chattogram on 4 June 2022 shows how these principles play out in court. Cargo destroyed while held at the depot under terminal receipts, before shipment, became the subject of an admiralty suit by the subrogated insurer for about USD 674,641. On 10 March 2026 the Admiralty Court returned the plaint under Order VII rule 10 of the Code of Civil Procedure, treating the depot as a bailee providing storage before any loading and the claim as one for warehouse negligence or bailment, triable in the ordinary civil courts.[6] Depot claims therefore follow civil-court procedure and time limits, not the maritime regime.

Port and depot exclusions

Ports and depots rely heavily on their published regulations and tariffs to limit liability. In the same judgment the court noted port working rules under which the port is not responsible for goods landed under nil or wrong marks.[6] The lesson is to read the receiving terms of every depot and terminal before entrusting cargo to it, to mark goods properly and to insure the storage period specifically.

Customs and bonded warehouses

Customs warehousing adds a public-law layer. Under the Customs Act 2023 the NBR may declare warehousing stations, Commissioners may designate public warehouses and license private warehouses, and imported goods may be placed under the warehousing procedure without payment of duty against a general bond, for a storage period fixed by rules.[1] Goods awaiting a customs procedure sit in temporary storage only in a designated or licensed warehouse or an approved place, and cannot be removed until released.[1]

Section 130 makes the warehouse-keeper or licensee responsible for due receipt, delivery and safe custody of warehoused goods according to the quantity assessed by customs, but provides that no owner may claim compensation from a customs officer or public warehouse-keeper for loss or damage unless it was caused by the wilful act or neglect of the warehouse-keeper or a customs officer.[1] Private bonded warehouse operators should therefore treat custody and stock reconciliation as compliance obligations, not merely commercial ones. Our guide to bonded warehouses in Bangladesh covers licences, the general bond and audits in detail.

Who answers for loss under logistics law in Bangladesh

The question every claim turns on is simple to state and hard to answer: who held the goods when the loss occurred, and on what terms? The table below summarises how logistics law in Bangladesh allocates liability between the main actors. On a phone, scroll it sideways.

Three patterns recur in practice. Forwarders acting as agents argue that they only arranged carriage and owe nothing beyond reasonable care in selecting carriers; forwarders who issued their own transport documents or quoted an all-in price are more exposed as principals. Depots and ports rely on exclusion terms and act of God; customers should test whether storage arrangements were reasonable. And road hauliers frequently fail to obtain the signed special contract that the Carriers Act requires to limit liability for ordinary goods, which leaves them exposed to the full value of the loss.[5]

Insurance across the logistics chain

Insurance often decides whether a logistics loss is recovered at all. Under Bangladesh's import policy, marine cover for imports must be procured from a domestic insurer, and the Insurance Development and Regulatory Authority has set minimum premium rates since August 2020: 0.45 per cent for Institute Cargo Clauses A and B and 0.30 per cent for clauses C. Importers commonly choose clauses C because it is cheapest.[13]

That choice has consequences. Clauses C cover a narrow list of major casualties and do not cover theft, pilferage, non-delivery or most handling damage, which are exactly the risks that materialise in trucks, depots and warehouses. Businesses should check whether their cover extends to inland transit and storage, whether it is warehouse-to-warehouse, and whether the insurer requires survey within a fixed time. Carriers, forwarders and warehouses should consider liability policies matched to the terms they actually trade on. Our guides to insurance law in Bangladesh and marine insurance claims explain recovery and subrogation.

Logistics contracts and claims: how matters unfold

Because statute fills so few gaps, logistics law in Bangladesh is largely made in the contract. The terms that most often decide disputes are the capacity of the service provider, the liability cap and its exclusions, the notice and time-bar clause, the lien clause, and dispute resolution. The Contract Act gives bailees a particular lien over goods for their charges, and general liens arise only for certain trades or by express agreement; a forwarder that wants to hold cargo against an old unpaid account needs clear written terms.

When a loss occurs, the sequence below protects the claim. It reflects how matters typically unfold between the discovery of loss and settlement or suit.

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Most logistics claims settle once the evidence is assembled and liability is clear, often between insurers. Where they do not, claims against road carriers, depots and forwarders are money suits in the civil courts, subject to the forum and arbitration clauses in the contract; our guide to contract law in Bangladesh explains damages and enforcement. Keep in mind that a claim against the ocean carrier may be subject to a much shorter time bar than the claim against the forwarder or depot, so assess every defendant at the outset.

E-commerce delivery and last-mile logistics

The growth of online retail has made last-mile delivery one of the most active areas of logistics law in Bangladesh. The Ministry of Commerce issued the Digital Commerce Operation Guidelines 2021 on 4 July 2021 under the National Digital Commerce Policy. Once full payment is made, products should be delivered within five days to a buyer in the same city and within ten days to a buyer in another city, with faster delivery for perishables; marketplaces must pay third-party sellers within ten days; complaints must be resolved within 72 hours; and records must be kept for at least six years.[14]

The guidelines place delivery responsibility on the seller, not on the courier. A platform or seller that misses the deadline cannot simply point to its delivery partner. Its contract with the courier should therefore mirror the guideline timelines, set service levels and compensation for late, lost or damaged parcels, govern cash-on-delivery collection and remittance, and require the courier to hold the licence that mailing and courier operators need to trade lawfully. Our courier and mailing operator licensing practice and our guide to e-commerce law in Bangladesh cover both sides of that relationship.

Foreign investment in logistics

For foreign investors, logistics law in Bangladesh currently sends mixed signals. C&F agent licences are capped at 49 per cent foreign ownership.[2] Freight forwarding has been more open historically, but the 2015 cap and the uncertain transitional language in the 2025 draft have left wholly foreign-owned forwarders unsure about renewal.[3] The Investment Bangladesh Authority supports full foreign ownership, while BAFFA opposes it.[4]

The prudent structure for a foreign entrant depends on the activity. Warehousing, contract logistics and technology platforms raise fewer licensing questions than customs-facing agency work, which may require a local partner or a joint venture within the ownership cap. Shareholder agreements should anticipate a rule change in either direction, with clear provisions on licence ownership, deadlock and exit.

Logistics law in Bangladesh: what to watch in 2026 and beyond

Four developments will shape logistics law in Bangladesh over the coming year. First, the final Freight Forwarders Rules, which will settle foreign ownership and renewal.[3] [4] Second, implementation of the National Logistics Policy 2025, and whether it leads to a logistics authority and legislation on multimodal transport.[11] Third, the fate of the proposed amendments to the Road Transport Act 2018, including the reintroduction of compulsory vehicle insurance.[9] Fourth, continuing customs digitisation under the Customs Act 2023, which is changing how agents, warehouses and carriers interact with the NBR.[1]

The businesses that manage logistics risk best do three things consistently: they know which entity holds their goods at every stage, they contract in writing on terms that the law will actually enforce, and they serve notice and preserve evidence the moment something goes wrong. TRW advises shippers, forwarders, carriers, warehouse operators and platforms on all three. Explore our customs and trade compliance practice or contact TRW in Dhaka.

Frequently asked questions

Is there a single logistics law in Bangladesh?

No. Logistics is governed by several statutes, including the Carriers Act 1865, the Contract Act 1872, the Road Transport Act 2018, the Inland Shipping Ordinance 1976 and the Customs Act 2023, with the National Logistics Policy 2025 setting the reform direction.[1] [12]

Do freight forwarders need a licence in Bangladesh?

Yes. The Customs Act 2023 treats freight forwarding agents as agents, and section 243 requires a licence to act at a customs station. Forwarders are licensed under the Freight Forwarders Rules 2008, which are being replaced.[1] [3]

Can a foreign company own a C&F agency in Bangladesh?

Only partly. Under the Customs Clearing and Forwarding Agent Licensing Rules 2026, joint local and foreign companies qualify if foreign ownership is 49 per cent or less.[2]

Is a house bill of lading a document of title?

No. The High Court Division has held that a house bill issued by a forwarder acting only as agent is at most a receipt and authority to contract for carriage, not a document of title.[7]

Is a trucking company liable if goods are lost in transit?

Generally yes, if it is a common carrier and the loss arose from its negligence or criminal act or that of its staff, and the claimant need not prove negligence. Liability for listed valuables depends on a declaration of value.[5]

What notice must be given to a carrier before suing?

Written notice of the loss or injury must be given before the suit and within six months of the time the loss first came to the claimant's knowledge.[5]

Where do claims against inland container depots go?

Usually to the ordinary civil courts. In March 2026 the Admiralty Court returned a depot fire claim because the depot held the goods as a bailee before shipment and the claim was not maritime.[6]

Must imports be insured locally?

Yes. Marine cover for imports must be bought from a domestic insurer, subject to minimum premium rates set by the Insurance Development and Regulatory Authority.[13]

What are the delivery deadlines for e-commerce orders?

Under the Digital Commerce Operation Guidelines 2021, delivery is due within five days in the same city and ten days elsewhere after full payment, and complaints must be resolved within 72 hours.[14]

Has the National Logistics Policy changed the law?

Not directly. The policy was revised in November 2025, but by July 2026 implementation had not started, and the existing statutes continue to govern rights and liabilities.[11] [12]