The Chattogram Customs Agents Association (CCAA) has demanded the withdrawal of new guidelines for the physical examination of imported goods, warning that the additional requirements could delay cargo clearance at Chattogram Port, increase business costs and create opportunities for harassment.
In a letter sent to Chattogram Customs Commissioner Md Mahbubur Rahman on Tuesday (10 November), the association said the 14-point office order issued on 2 November could create confusion among customs officials, importers and clearing and forwarding (C&F) agents.
The association also objected to provisions that it believes overlap with the responsibilities of customs assessment sections and contradict existing instructions on physical examinations.
CCAA leaders met the customs commissioner and senior officials on Tuesday afternoon to press for the withdrawal of the order and demand consultations with stakeholders before implementing the new guidelines.
“We have presented our objections and requested the commissioner to withdraw the office order, as it was issued without consulting stakeholders. We also urged him to hold a dialogue before implementing the new guidelines,” CCAA President Saiful Islam told The Business Standard.
Chattogram Customs House spokesperson Sharif Al Amin confirmed receiving the letter and the meeting with the commissioner.
“Senior officials have been informed about the concerns raised by the CCAA. The dispute will be resolved through dialogue,” he said.
Issued under Section 266 of the Customs Act 2023, the new order makes 14 instructions mandatory for customs examination officials. These cover the appointment of examining officers, verification of shipping documents, identification of containers, physical inspection of goods and preparation of examination reports.
Under the guidelines, officers must verify the location of consignments through the port’s Terminal Operating System (TOS) or the customs ASYCUDA system before beginning an examination.
They must also match container and seal numbers with bills of lading and examine goods against letters of credit, bank-certified commercial invoices, detailed packing lists and certificates of origin.
For consignments spread across multiple examination zones, the examination must take place in the zone containing the largest number of containers.
The order also requires an officer not below the rank of assistant commissioner to appoint the examining official. The relevant deputy or assistant commissioner must sign the bill of entry and provide a name seal, while the examining officer’s identity must be recorded in the zone register.
However, the CCAA’s main objection concerns instructions requiring examining officers to identify product specifications that could affect customs duties, taxes and declared values, verify conditions attached to duty exemptions and concessions, and report compliance with import-related laws and restrictions.
The association said these responsibilities primarily belong to customs assessment sections rather than examination zones.
Referring to a permanent order issued by Chattogram Customs on 17 June 2021, it said the respective responsibilities of assessment sections and examination zones had already been clearly defined.
“If the responsibilities of assessment sections, including identifying discrepancies in customs duties, taxes and values and verifying conditions for duty exemptions, are assigned to examination zones through the new order, it is unclear what the role of the assessment sections will be,” the association said in its letter.
It also cited a decision taken at a tripartite meeting involving the National Board of Revenue (NBR), Chattogram Customs House and the association on 3 April 2012.
Another office order issued by Chattogram Customs on 4 November 2018 had explicitly stated that physical examination reports should not contain opinions on the HS codes or values of imported goods, the association said.
The CCAA argued that the new guidelines could contradict these earlier decisions and create uncertainty over the responsibilities of customs officials, leading to additional complications and delays in cargo clearance.
The order also requires examining officers to record false declarations or irregularities in a register and obtain signatures from the C&F agent, examining officer and deputy or assistant commissioner concerned.
If a C&F agent refuses to sign an examination report, the refusal must be recorded, and the report must be sent to the additional or joint commissioner of the examination division for countersignature.
The association warned that these provisions, combined with the expanded scope of physical examinations, could lead to arbitrary interpretations, harassment of importers and C&F agents, and demands for undue benefits.
In its letter, signed by General Secretary Md Shaukat Ali, the association said C&F agents should be treated as partners of customs authorities rather than adversaries, as they represent importers and facilitate government revenue collection and international trade.
It also recalled that the finance and planning minister, at a meeting with senior NBR, customs and port officials and other stakeholders at Chattogram Port on 11 August, had stressed the need to reduce trade barriers, administrative delays and cargo clearance time.
The association said the latest order runs counter to those objectives by potentially adding procedural hurdles to import-export operations.
It has urged the customs commissioner to suspend the order and hold urgent discussions with the association to formulate practical guidelines that ensure transparency and accountability without slowing cargo clearance.
