Customs & Trade Compliance in Bangladesh

by Barrister Tahmidur Rahman | Sep 8, 2026

Trade, Competition & RegulationClear goods, avoid disputes9 min read

Customs & Trade Compliance in Bangladesh

Customs and trade compliance advice for importers, exporters, manufacturers, project sponsors and logistics operators in Bangladesh: we handle tariff classification, valuation, exemptions, bonded warehouse and duty drawback schemes, import and export controls, audits, seizures and appeals under the Customs Act 2023.

Customs & Trade Compliance in Bangladesh: customs with TRW & Co
Matter planTrade, Competition & Regulation
  1. Review the trade flows
  2. Set the position
  3. Engage the authorities
  4. Maintain and defend
Overview

How customs and trade compliance work in Bangladesh

Bangladesh is a trading economy. Garment exporters import fabric and accessories under bond, manufacturers bring in machinery and raw materials, distributors import consumer goods and pharmaceuticals, and infrastructure projects rely on large shipments of equipment. Every consignment passes through a customs process that determines duty, timing and risk. The Customs Act 2023, which replaced the Customs Act 1969, is administered by the National Board of Revenue and its customs houses and stations. We advise businesses on trade compliance through our regulatory practice in Bangladesh, from planning a supply chain to defending a seizure or demand.

Duty liability depends on three questions: what the goods are, what they are worth and where they come from. Classification under the Harmonised System decides the tariff rates, supplementary duty, regulatory duty and VAT that apply, and small differences in description can change the total substantially. Valuation follows transaction value principles, adjusted for items such as royalties, assists and related party pricing. Origin matters for preferential tariffs under regional agreements. Disputes on any of these points can delay release, lead to demands for unpaid duty and penalties, and in serious cases trigger allegations of misdeclaration or money laundering through trade.

Export-oriented industries depend on duty relief schemes. Bonded warehouse licences allow eligible exporters to import inputs without paying duty, subject to strict entitlement, utilisation and reconciliation rules, and duty drawback and exemption schemes provide alternatives for others. Projects approved through Invest Bangladesh, which replaced BIDA and BEZA in August 2026, or operating in BEPZA zones, may benefit from capital machinery concessions and zone procedures. These benefits come with obligations to record, account for and use goods as declared. Diversions, shortages and expired licences are common sources of enforcement action that can cost far more than the duty originally saved.

Trade compliance extends beyond duty. The import policy order and export policy regulate which goods may be traded and on what conditions, many products require permits, certificates or standards approvals before release, and trade is monitored for sanctions, dual-use and money laundering risks. Bangladesh Bank rules on letters of credit and foreign exchange interact with clearance documents. Bangladesh's planned graduation from least developed country status will also change preferential access to key export markets over time. We help businesses map these requirements, build internal controls and keep documents consistent across banks, freight forwarders, clearing agents and officials.

When disputes arise, timing is critical and early decisions often shape the outcome. Customs may hold goods at the port, issue show cause notices, reassess duty after release through post-clearance audit, or start penalty and confiscation proceedings. The law provides adjudication, appeals and alternative dispute resolution, and further routes to the Appellate Tribunal and the High Court Division, each with strict time limits and, in some cases, pre-deposit requirements. Our regulatory lawyers work with the firm's dispute resolution team to secure release of goods, challenge assessments and negotiate settlements, while protecting the client's licences, bank relationships and reputation.

01 · What we handle

Core workstreams

  • Classification and valuation
  • Bonded warehouse and duty relief
  • Import and export controls
  • Audits and internal controls
02 · How it runs

Four clear stages

  1. 01Review the trade flows
  2. 02Set the position
  3. 03Engage the authorities
  4. 04Maintain and defend
03 · Start here

Talk to a partner

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

Book →
How we help

What our customs and trade compliance work covers

Workstream 01Trade, Competition & Regulation

Classification and valuation

  • Review the trade flows
  • Set the position
  • Engage the authorities
  • Maintain and defend
Workstream 02Trade, Competition & Regulation

Bonded warehouse and duty relief

  • Review the trade flows
  • Set the position
  • Engage the authorities
  • Maintain and defend
Workstream 03Trade, Competition & Regulation

Import and export controls

  • Review the trade flows
  • Set the position
  • Engage the authorities
  • Maintain and defend
Workstream 04Trade, Competition & Regulation

Audits and internal controls

  • Review the trade flows
  • Set the position
  • Engage the authorities
  • Maintain and defend
Workstream 05Trade, Competition & Regulation

Seizures, demands and appeals

  • Review the trade flows
  • Set the position
  • Engage the authorities
  • Maintain and defend
Workstream 06Trade, Competition & Regulation

Trade agreements and origin

  • Review the trade flows
  • Set the position
  • Engage the authorities
  • Maintain and defend
01

Classification and valuation

We review HS classification and valuation for new products, contracts and supply chains, prepare technical submissions, and advise on related party pricing, royalties, assists and transfer pricing adjustments. Where rulings are available, we apply for them and rely on them consistently. Getting classification and value right before the first shipment avoids demands and penalties later, and supports consistent treatment across ports, consignments and years. We also review past declarations for errors.

02

Bonded warehouse and duty relief

We advise exporters and manufacturers on obtaining, renewing and amending bonded warehouse licences, entitlement and utilisation documentation, and the periodic reconciliation of imported inputs against exports and remaining stock. We also advise on duty drawback, exemptions, capital machinery concessions and zone procedures, and help clients resolve audit findings on shortages, wastage and diversion before they turn into penalty proceedings. Regular reconciliations are the best protection for any bond licence holder.

03

Import and export controls

We review products and transactions against the import policy order, export policy, licensing requirements and conditions such as standards certification, quarantine, drug or chemical permits. We advise on registration as an importer or exporter, restricted and prohibited items, sanctions and dual-use screening, and the documents banks require for letters of credit, so shipments clear without avoidable delay. Early checks on permits and certificates prevent goods sitting at port while approvals are obtained.

04

Audits and internal controls

We carry out trade compliance reviews and prepare businesses for post-clearance audits by examining declarations, contracts, invoices, payments and bond records. We design internal procedures, training and oversight of clearing and forwarding agents, and advise on voluntary correction of past errors. For eligible businesses we also support applications for Authorised Economic Operator status and other trusted trader arrangements, which can bring faster clearance and fewer physical examinations.

05

Seizures, demands and appeals

When goods are held, demands issued or penalty proceedings started, we respond quickly with clear written submissions, evidence and hearings before customs officers. We pursue release against security where possible, use alternative dispute resolution where suitable, and take appeals to the appellate authorities, the Appellate Tribunal and the High Court Division, including writ petitions against unlawful action. Throughout, we keep the commercial priority in view, which is usually getting goods released and production running.

06

Trade agreements and origin

We advise on rules of origin, certificates of origin and preferential tariffs under regional and bilateral arrangements, and on how the planned graduation from least developed country status may affect market access. We help exporters plan sourcing and documentation, respond to origin verification requests from importing countries, and coordinate with counsel abroad on trade remedy and market access issues, including anti-dumping and safeguard investigations affecting Bangladeshi products.

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.
Who leads this work

Partner-led, on every matter.

Trade, Competition & Regulation matters at TRW are led by partners, supported by associates, with one responsible lawyer from first advice to final outcome.

Meet the firm →
01

What changed under the Customs Act 2023?

The Customs Act 2023 replaced the Customs Act 1969 and substantially modernised the legal framework for import, export and transit. It updated provisions on declarations, assessment, valuation, post-clearance audit, penalties, appeals and electronic processing, and reflects international practice more closely. Many day-to-day procedures continue through the electronic clearance system, but businesses should review contracts, internal procedures and past assumptions against the new law, particularly on time limits, penalties, record keeping and audit powers. We advise importers and exporters on how the Act affects their specific operations and risk profile, and update compliance documents to reflect the current position.

02

How can we avoid HS classification disputes?

Start well before the goods are shipped. Prepare clear technical descriptions, specifications and, where helpful, samples or catalogues, and analyse the tariff headings, section notes and explanatory notes carefully. Where an advance ruling is available, consider applying for one, and keep classification consistent across ports, suppliers and time. If customs officers propose a different heading, respond promptly in writing with technical and legal reasoning rather than accepting a reassessment that becomes a precedent for future shipments. We prepare classification opinions and submissions and represent clients when classification disputes reach adjudication, alternative dispute resolution or appeal.

03

How is customs value determined for related party imports?

Customs value is generally based on the transaction value, the price actually paid or payable, adjusted for certain costs such as royalties, licence fees and assists. Where the buyer and seller are related, the authorities may examine whether the relationship influenced the price, and the importer should be ready to show, with evidence, that it did not. Transfer pricing documentation prepared for income tax helps but is not always sufficient for valuation purposes. We review intra-group pricing, prepare valuation evidence and align the customs position with tax and foreign exchange documents to reduce the risk of reassessment.

04

What are the main risks for bonded warehouse users?

Bonded warehouse licences allow duty-free import of inputs for export production, but they carry strict obligations. Imports must stay within the approved entitlement, inputs must be used for the declared purpose, records must reconcile imports, consumption, wastage and exports, and licences must be renewed on time. Selling bonded goods in the local market, or failing to account for them, can lead to duty demands, penalties, suspension of the licence and, in serious cases, criminal proceedings. We review bond records, prepare for audits, help resolve discrepancies, regularise expired licences and defend clients when the bond authorities allege misuse.

05

Our goods are held at the port. What should we do?

Act quickly, because demurrage and storage charges accumulate daily. Find out the reason for the hold, whether a classification or valuation query, a document issue, a missing permit or a suspicion of misdeclaration, and obtain any written notice. Many holds can be resolved by supplying documents or making written submissions. Where the dispute is genuine, release against payment under protest, a bank guarantee or other security may be possible while the issue is decided. We engage with officials, prepare submissions and pursue the fastest lawful route to release, escalating to appeal or writ proceedings if necessary.

06

What is post-clearance audit and how should we prepare?

Post-clearance audit allows the authorities to examine declarations after goods have been released, often covering several years of imports. Auditors may review contracts, invoices, payment records, bond accounts and accounting entries, and can issue demands for unpaid duty, interest and penalties long after the goods were sold. Preparation means keeping complete and well-organised records, reconciling customs declarations with accounts, and correcting known errors before an audit begins. We carry out mock audits, help businesses assemble records, respond to audit queries and challenge findings that are wrong in law or unsupported by evidence, while negotiating sensible outcomes on genuine errors.

07

Can we challenge a customs demand or penalty?

Yes. Assessments, demands and penalty orders can be challenged through the routes provided by law, including appeals to the appellate authorities and the Customs, Excise and VAT Appellate Tribunal, and further references or petitions to the High Court Division. Alternative dispute resolution may also be available for some matters. Time limits are strict and, in some cases, a portion of the disputed amount must be deposited before an appeal is heard. We assess the merits and the commercial stakes, choose the most effective route, prepare grounds and evidence, and represent clients through each stage of the dispute.

08

How does LDC graduation affect exporters?

Bangladesh's planned graduation from least developed country status will gradually affect preferential access to some export markets after the applicable transition periods, and may change the rules of origin and conditions that exporters must satisfy. The precise impact depends on the market, the product and any new trade arrangements negotiated by the government. Exporters should review current preference use, origin documentation and sourcing strategies now, rather than wait for changes to take effect. We advise exporters on their exposure, monitor developments in key markets and coordinate with counsel abroad on market access and trade remedy questions.

How a matter runs

From first call to resolution.

  1. 01

    Review the trade flows

    We map the client's imports and exports in detail, including products, suppliers, ports, schemes and agents, and review declarations, contracts and permits, to identify classification, valuation, origin and licensing risks and any immediate customs disputes or holds requiring urgent action.

  2. 02

    Set the position

    We prepare written opinions on classification, valuation and scheme eligibility, recommend corrections or voluntary disclosure where past declarations were wrong, and agree clear documentation standards with the client's logistics, finance and procurement teams and their clearing agents.

  3. 03

    Engage the authorities

    We handle applications, rulings, licence and registration renewals, audit responses and dispute submissions, attend hearings and meetings with officials, and keep a complete written record so that positions remain consistent across shipments, ports and years and can be defended later.

  4. 04

    Maintain and defend

    We provide ongoing support on new products, regulatory changes and audits, train staff and agents, and act promptly when goods are held, demands are issued or appeals are needed, protecting supply chains, licences, bank relationships and the client's standing with customs.

“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.

Which authority administers customs in Bangladesh?
The National Board of Revenue oversees customs administration, working through customs houses at the main sea, air and land ports, customs stations and specialised offices such as the bond commissionerates and the duty exemption and drawback office. Investigation and intelligence units handle serious cases. Appeals go to the appellate authorities and the Appellate Tribunal. Knowing which office is responsible for a particular issue saves considerable time. Policy and rates come from the Board, while assessment and release happen at the port of arrival.
What duties apply on imports?
Imports may attract customs duty, regulatory duty, supplementary duty, VAT, advance tax and advance income tax, depending on the goods and the importer. Rates are set mainly through the annual Finance Act and related notifications, and exemptions or concessions may apply to certain goods, projects or zones. Because several layers apply, a small classification change can make a large difference to the total cost of an import. Importers should model the full landed cost before signing contracts and check each year's Finance Act, because rates and concessions change regularly.
Do we need an import registration certificate?
Most commercial and industrial importers need registration with the import and export control authority, and exporters need equivalent export registration, which must be renewed periodically. Banks will not open letters of credit without valid registration. Some goods also require separate permits. We help businesses obtain and maintain the registrations they need for their trade, including changes of name, address, capacity or ownership. Allowing a registration to lapse can halt imports at short notice, which is easily avoided with a simple compliance calendar.
What is an Authorised Economic Operator?
An Authorised Economic Operator is a business recognised by customs as compliant and secure, which may receive simplified procedures and faster clearance. Eligibility depends on compliance history, financial standing, record keeping and security standards. Applying requires preparation and a review of internal controls. We assess readiness, help prepare the application and address any gaps identified during the review. The process itself often improves internal controls, which reduces the risk of disputes even for businesses that ultimately decide not to apply.
Are customs penalties only financial?
No. Besides duty demands and fines, consequences may include confiscation of goods, suspension of licences or bond facilities, blacklisting, and in serious cases criminal prosecution for smuggling, fraud or money laundering. Directors and employees can face personal exposure. Early legal advice helps contain the risk and distinguish genuine errors from deliberate misconduct, which strongly affects the outcome. Voluntary disclosure of a genuine mistake is usually treated very differently from an error discovered by investigators after a tip-off.
How long does a customs appeal take?
Timelines vary with the forum and the complexity of the dispute. First-level appeals may be decided relatively quickly, while cases before the Appellate Tribunal or the High Court Division can take considerably longer. Alternative dispute resolution can shorten the process where both sides are willing to settle. We give a realistic timetable at the outset and seek interim protection, such as release of goods, where the business needs it. In many cases a well-prepared appeal also opens the door to a negotiated resolution, which saves time and legal costs for both sides.
Can clearing and forwarding agents expose us to liability?
Yes. Agents prepare and submit declarations on the importer's behalf, but the importer usually remains responsible for errors in description, value or origin. Poorly supervised agents are a frequent cause of disputes. Clear written instructions, document checks and agreements that set standards and responsibilities reduce risk. We review agent arrangements and train internal staff to supervise them effectively. Agents should be licensed, properly instructed and required to share copies of everything they file on the importer's behalf.
Can TRW help foreign suppliers and buyers with customs issues?
Yes. We advise foreign suppliers, buyers, logistics companies and investors on Bangladeshi customs and trade compliance, including contract terms, Incoterms, documentation, origin and disputes, and coordinate with counsel in the UK, US, UAE, China, India and Singapore. This helps international partners understand local requirements and resolve problems quickly when shipments are delayed. We can also review supply and distribution contracts so that responsibility for duties, documents and delays is allocated clearly between the parties before the first shipment arrives.

Keep your goods moving and your duties right

Speak with the partners about customs in Bangladesh or across borders.

Book a consultation →
customs: TRW & Co, Dhaka
Call the Dhaka office+880 1708 000660WhatsApp · message usMessage our team
Message TRW on WhatsApp