No. Imports of scrap and recovered materials are permitted only on the conditions set by the Import Policy Order and related customs and environmental rules, which may include restrictions on contamination, hazardous components, pre-shipment inspection and the type of importer. Rules can change when a new Import Policy Order is issued, so each import should be checked against the current text. Materials that are hazardous or contaminated may be prohibited or require specific approval. We review the material, its documentation and the current rules before shipment, so that the waste shipment is accepted on arrival.

The Convention applies to transboundary movements of hazardous wastes and other wastes listed in its annexes, including many plastic wastes covered by the 2019 amendments. Where it applies, the exporting country must notify the importing and transit countries and obtain their written consent before the shipment departs. Bangladesh, as a party, can refuse consent, and an illegal movement may have to be taken back by the exporter. Non-hazardous wastes outside the controlled categories are generally not subject to prior consent, though national rules still apply. We help classify the material and determine whether consent is needed.

The revised EU Waste Shipment Regulation restricts exports of non-hazardous waste from the EU to non-OECD countries such as Bangladesh from 21 May 2027, and plastic waste exports to those countries are banned from 21 November 2026. Other exports are expected to be allowed only if the destination country formally requests to receive specific waste streams and shows that it can manage them in an environmentally sound way, and EU exporters must also show that recipient facilities have been independently audited. Affected Bangladeshi recyclers should prepare audit evidence and discuss waste shipment requirements with European suppliers early.

It depends on the material and how it is handled. Clean, sorted post-industrial textiles sold for recycling are often traded as raw materials, but they may still be treated as waste under some laws, particularly in foreign destination countries. Contaminated or mixed materials raise greater risk. The classification affects which permits, documents and controls apply on export and import. We review how cutting waste is collected, sorted, stored and sold, and advise on contract terms and documents so that the trade is lawful and buyers' recycling claims can be substantiated.

If a shipment is found to be illegal, for example because it contains hazardous material without consent or misdeclared goods, authorities may detain it, impose penalties and require it to be returned or disposed of at the responsible party's cost. Under the Basel Convention, the exporting country may be obliged to take back illegal traffic. Importers can face prosecution and loss of licences. We act quickly to assess the facts, communicate with customs and the Department of Environment, coordinate with the exporter and shipping line, and protect the client against liability for problems it did not cause.

A recycling facility generally needs a trade licence, factory and fire safety approvals, environmental clearance from the Department of Environment under the Environment Conservation Rules 2023, and specific hazardous waste or e-waste licences if it handles those materials. Location matters, as industrial zones and economic zones have their own procedures through BEPZA or Invest Bangladesh. Effluent treatment and emissions controls are commonly required. We help facilities identify the required approvals, prepare applications, maintain compliance and prepare for the audits that foreign suppliers and authorities increasingly require before any waste shipment is sent.

The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships entered into force in June 2025, and Bangladesh is a party. It sets requirements for ship recycling facilities, including authorisation and ship recycling facility plans, and for ships, including an inventory of hazardous materials and a ship recycling plan. These requirements work alongside the Bangladesh Ship Recycling Act 2018 and domestic environmental rules. We advise yards, cash buyers and shipowners on documentation, contracts and compliance, and on how hazardous materials removed from ships must be managed and disposed of.

Liability depends on the contract, the documents and the law. Under the Basel framework and national laws, the exporter or the person who arranged the shipment may have to take the material back or pay for its management, while importers can face penalties if they failed to carry out checks. Commercially, the contract should specify quality, contamination limits, inspection, rejection rights and who pays for return, storage and disposal. We draft these terms, advise when contamination is discovered and pursue or defend claims, including through arbitration or admiralty proceedings where cargo or vessels are involved.