Yes. The rules treat importers of covered electrical and electronic equipment as producers alongside manufacturers and assemblers, because they place products on the Bangladesh market. An importer of branded phones, laptops or appliances can therefore carry take-back, collection and reporting obligations even if it has no factory in Bangladesh. Distributors and retailers have their own duties, such as supporting collection. Where a foreign brand sells through a local importer, responsibilities should be allocated clearly in the distribution agreement, rather than each party assuming the other is handling compliance. We help draft the allocation clauses.

The rules list categories of electrical and electronic equipment, broadly covering large and small household appliances, information technology and telecommunications equipment, consumer electronics, lighting equipment, tools, medical devices and monitoring instruments, among others, and the category determines which duties apply. Whether a specific product is covered depends on the schedules and any DoE guidance, and borderline items such as components, batteries and devices built into other products need careful analysis. We review a client's product list against the current schedules before compliance planning begins. Accessories and spare parts may be classified differently from the main product.

The rules set collection targets that increase over time, expressed as a proportion of products placed on the market. How quantities are measured, what evidence counts, and how the DoE assesses performance have developed in practice and may be clarified further. Producers should keep reliable records of sales, collection and handover to authorised recyclers, with supporting documents from each partner. We do not recommend relying on estimates. We help clients set up record systems that would stand up to DoE review or a customer audit of their e-waste performance. Consistent records also help with buyers.

Collective approaches, where several producers share collection infrastructure or appoint a common service provider, can reduce costs and are common internationally. Whether a collective arrangement satisfies each producer's individual obligations depends on the rules and DoE practice. Members should agree how collected volumes are allocated, who reports, how costs are shared and what happens if the scheme underperforms. Competition law also needs attention when competitors cooperate. We advise on structuring such schemes and drafting the membership and service agreements. Members should be able to leave on reasonable notice and share only the information the scheme needs.

Start with legal status: the recycler should hold current DoE authorisations for the activities it performs, plus the usual factory, fire and trade licences. Then check practical capability: facilities, safety practices, downstream destinations for recovered materials and its ability to provide documents for each batch. Visit sites where possible and contract for audit rights. Producers remain exposed if their partner is found to be dumping or passing material to informal operators, so contracts should require transparency and allow termination. We prepare the due diligence checklist and contract terms. Keep inspection notes and repeat visits periodically, because practices can change.

Breaches of rules made under the Bangladesh Environment Conservation Act can lead to enforcement action by the DoE, including directions to take corrective steps, compensation or penalty orders, and in serious cases prosecution, subject to appeal rights under the environmental legislation. The commercial consequences, such as loss of supplier status with international brands, refused financing or reputational damage, may be more significant than the formal penalties. We advise on responding to notices and on fixing compliance gaps before they reach enforcement. Answering notices on time and recording corrective steps can influence how the DoE treats a first breach.

Imports of used electronics are restricted and subject to conditions under import policy and environmental controls, and anything that is in substance e-waste rather than usable goods faces strict controls under Bangladesh's Basel Convention obligations. The line between second-hand goods and waste depends on age, condition, testing, packaging and documentation. Shipments that fall on the wrong side can be held, returned at the importer's cost or lead to penalties. We advise importers and refurbishers on the current rules and documentation before shipment, and act when consignments are held. Pre-shipment checks are the best protection.

Returned phones, laptops, servers and storage devices often contain personal data. Under the Personal Data Protection Act 2026, businesses handling such data have obligations on security and processing, and producers, retailers and recyclers in the take-back chain need clear rules on who wipes or destroys data, to what standard, and with what evidence. Contracts should allocate those responsibilities and require certificates of destruction. Corporate clients disposing of IT equipment face the same questions, and certificates of destruction should be retained for each batch. We combine e-waste and data protection advice so that both regimes are satisfied.