TRW & Co · Shipping, Port & Admiralty
Off-Dock ICD Lawyer in Chittagong: Inland Container Depots Serving Chattogram Port
An off-dock ICD lawyer in Chittagong advises the private inland container depots around Chattogram port and the exporters, importers and shipping lines that rely on them. These depots handle all export stuffing and 65 categories of imports, and after a court-suspended tariff rise and a threatened shutdown in 2025, charges and liability need careful handling.
Key pointDepot charges are no longer purely contractual: in 2025 the High Court Division suspended an increase and the shipping ministry required approval through the CPA tariff process, so any bill must be checked against the rate officially in force on the dates in question.
At a glance
All exports go through
The 19 private depots around Chattogram handle all export cargo, most empty containers and 65 categories of import goods.
Import list expanded
The NBR added 12 import categories on 8 April 2025 and 15 on 17 July 2025, bringing the total allowed through off-docks to 65.
Licence conditions apply
Customs requires depots to be within 20 kilometres of the port, with customs office space, handling equipment, secure warehousing and CCTV.
Tariffs were contested
A 2025 depot tariff rise was suspended by the High Court Division; an interim 20 per cent increase was agreed in January 2026 for six months.
Documents must name the depot
For eligible imports to go off-dock, the depot must be named beforehand in the letter of credit and bill of lading.
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What an off-dock ICD lawyer in Chittagong deals with
An off-dock ICD lawyer in Chittagong advises the private inland container depots that surround Chattogram port, and the exporters, importers, shipping lines, freight forwarders and C&F agents who use them. The work covers licensing and compliance, tariff and service disputes, liability for lost or damaged cargo and containers, customs issues at the depot, and the contracts between depots and their customers.
Off-docks are not a side issue at Chattogram. The 19 private depots around the city handle all of the country's export cargo, most empty containers and a growing list of import goods. Reports in early 2026 put their combined storage capacity at about 106,000 TEUs, nearly double the port's own yards, and their annual throughput at around 2.2 million containers. When depots stop work, as they threatened to in December 2025, garment shipments and port operations are immediately at risk.
Because off-docks sit between the port, the Custom House and private contracts, disputes about them often fall through the gaps. This page explains how the regime works and where to take a problem. It sits alongside our pages on port authority disputes, customs clearance and port terminals.
What private ICDs and CFSs do
Private inland container depots (ICDs) and container freight stations (CFSs) were encouraged to ease congestion at Chattogram and speed up clearance by allowing unstuffing and delivery outside the port. According to Bangladesh Customs, they perform three main functions: handling import containers of selected items, handling all export containers, and storing and handling empty containers.
| Function | What happens at the depot | Who controls it | Typical disputes |
|---|---|---|---|
| Export stuffing | Goods received, stuffed into containers under customs supervision, then moved to the port | Customs officials at the depot; assessment at Chattogram Custom House | Missed cut-offs, damaged or short-shipped cargo, stuffing and ground rent charges |
| Selected imports | Containers scanned at the port gate, moved on chassis to the depot, examined, assessed and delivered | Custom House for assessment and release; depot for custody | Delay, examination damage, pilferage, storage charges |
| Empty containers | Storage and repair for shipping lines, release for export stuffing or re-export | Contract between depot and line; customs time limits for disposal | Detention, damage and repair bills, lost containers |
| Transport | Movement between port and depot | Depot or transport contractor; port gate controls | Haulage charges, accidents, custody gaps |
The list of imports that can go through private off-docks has expanded. The NBR added 12 categories on 8 April 2025 and 15 more on 17 July 2025, bringing the total to 65 types of import goods, as The Financial Express reported. The list covers mainly low-risk, low-duty bulk and agricultural goods, and the NBR updates it periodically.
The legal framework an off-dock ICD lawyer in Chittagong works with
Licensing and permissions
A private ICD or CFS needs permission from several authorities: the National Board of Revenue, the Ministry of Shipping, the Chittagong Port Authority, the Department of Environment and other relevant agencies. To obtain a warehouse licence from the Custom House, it must meet conditions that include location within 20 kilometres of the port, a proper office for customs officials, adequate container handling equipment, and a secure warehouse with CCTV. An NBR order sets the criteria for granting the licence and operating a private ICD or CFS.
Customs law
The Customs Act 2023 governs customs control, warehousing and the treatment of goods not cleared in time. Customs procedures at the depot follow the NBR order and Custom House instructions: the depot's name must appear in the letter of credit and bill of lading beforehand for an import container to be routed there, and no-objection letters are needed from the shipping agent and the CPA. Customs assessment is done at Chattogram Custom House, which issues the release order; the goods are then unstuffed and delivered from the depot.
Contract and bailment
The relationship between a depot and its customers is contractual. Where goods or containers are in the depot's custody, the bailment provisions of the Contract Act 1872 apply, including the duty of a bailee to take the care a person of ordinary prudence would take of their own goods. Depot terms often try to limit liability, and their effect depends on how they were incorporated and whether they are reasonable in the circumstances.
Who contracts with whom
Off-dock relationships form a triangle that is easy to misread. Shipping lines usually nominate depots for their empty containers and for export stuffing, and contract with them under service agreements. Exporters and importers book space and services, sometimes directly and sometimes through a freight forwarder or C&F agent. Haulage between the port and the depot may be run by the depot or by a separate contractor. When a problem arises, the party with the strongest claim may not be the party that paid the invoice.
An off-dock ICD lawyer in Chittagong will reconstruct this chain before advising on liability. The line's service agreement may contain performance standards and indemnities that help a shipper indirectly; the forwarder's terms may cap its liability at a low figure; and a depot may be able to rely on terms it never actually gave the shipper. Each answer depends on the documents, so collecting them is the first step.
Tariffs and charges
Depot charges are set by the operators but have become subject to official oversight. When the depots' association raised charges from 1 September 2025, the increase was suspended by the High Court Division and the shipping ministry directed that new charges should not be imposed without approval through the CPA's tariff committee process. In January 2026, at a meeting chaired by the CPA chairman, depots and port users agreed a 20 per cent increase for export and empty container handling for six months, according to the Daily Observer. Anyone disputing a depot bill should check the rate in force on the relevant dates.
The 2025 to 2026 tariff standoff and what it shows
The dispute over depot charges illustrates how off-dock problems escalate. Operators said their handling rates had been unchanged since 2016 despite rising wages and costs. In mid-2025 the Bangladesh Inland Container Depots Association announced increases averaging around 50 per cent. Traders challenged them, and a writ petition led to a court order suspending the revised charges.
With no resolution after three months, depot owners told clients they would stop handling export cargo and empty containers from 11 December 2025. The halt was deferred after the CPA promised to review their demands, as The Financial Express reported, and the interim 20 per cent increase followed in January 2026. For users, the lesson is that depot charges can change, be challenged and be suspended in quick succession, so contracts and invoices need to be read against the current official position.
Off-docks are private businesses doing a public job. That is why a depot bill can be a contract question one week and a writ question the next.
Policy may shift further. In May 2026 BIDA, now succeeded by the Invest Bangladesh Authority, proposed gradually allowing 80 per cent of imports to be cleared through private off-docks, according to The Business Standard. Any expansion would bring new licensing, customs and liability questions for depots and their customers.
Common off-dock disputes
Export delays and missed vessels
Because all export containers are stuffed at off-docks, delays at the depot directly affect shipment dates. Garment exporters facing buyer penalties or air-freight costs may have claims against the depot or the forwarder, depending on who contracted with whom and what the terms say. An off-dock ICD lawyer in Chittagong will start with the booking, cut-off and gate-in records.
Damage, shortage and pilferage
Cargo can be damaged during stuffing, unstuffing, storage or haulage, or go missing from the depot. Liability depends on custody at the moment of loss and the terms in force. Joint surveys, CCTV footage and tally sheets are decisive, and they are best requested immediately. Our cargo claims team coordinates insurer and carrier claims.
Empty container disputes
Shipping lines and depots argue over repair bills, lost containers and storage charges, while importers argue with lines over detention while empties wait for return. Empty containers not disposed of within the allowed time are liable to auction under customs rules. Our demurrage and detention page covers line charges in detail.
Haulage between port and depot
Containers move on chassis between the port gate and the depot, often several times a day and through heavy city traffic. Accidents, overturned trailers, seal breaks and theft in transit create disputes about whether the loss happened in the port, on the road or at the depot. The answer depends on the equipment interchange receipts and seal numbers recorded at each handover, and on the haulier's contract and insurance. Where the haulier is a separate company, the depot may deny responsibility altogether.
Licensing and regulatory action
Depots themselves face show-cause notices, suspension or cancellation of customs licences, environmental compliance issues and safety concerns. Responses must address the specific licence conditions and be supported by records. Unlawful or unfair decisions may be challenged by writ petition in the High Court Division; see our writ practice.
How to handle an off-dock problem, step by step
- Identify the custodian. Establish whether the goods or container were in the port, in transit, at the depot or with a haulier at the relevant time, using gate-in and gate-out records.
- Preserve evidence. Request the depot's container history, tally sheets, CCTV and examination records in writing, and arrange a joint survey for any damage.
- Read the terms. Collect the booking, depot terms, invoices and the tariff in force on the dates in question, including any court orders affecting charges.
- Notify every potential party. Put the depot, carrier, forwarder, C&F agent and insurer on notice within any contractual time limits.
- Protect the cargo. If release is urgent, pay disputed charges under written protest and reserve your rights, so the dispute does not hold up the shipment.
- Escalate. Raise unresolved issues with the depot's management, then with the CPA or Custom House where regulation is involved, before choosing litigation, arbitration or a writ.
Most off-dock claims are won or lost on records created in the first 48 hours: the container event history, the gate pass, the tally sheet and a joint survey. Ask for them in writing at once, because depots overwrite CCTV and containers move on quickly.
Timing matters for another reason. Depot terms and forwarder conditions often impose short notice periods for claims, and insurers expect prompt notification. An off-dock ICD lawyer in Chittagong will diary these limits on the first day, alongside any customs deadlines that keep running while the dispute is resolved.
Documents and evidence to assemble
- Letter of credit and bill of lading showing the nominated depot, and the no-objection letters from the shipping agent and CPA.
- Bill of entry or export declaration, assessment and release orders from the Custom House.
- Depot booking confirmations, terms and conditions, invoices and payment receipts.
- Gate-in and gate-out records, equipment interchange receipts and container event history.
- Stuffing or unstuffing tally sheets, survey reports, photographs and CCTV requests.
- Correspondence with the depot, line, forwarder and C&F agent, especially about delays and cut-offs.
- Any court order, ministry direction or tariff committee decision relied on for the charges.
Risks and common mistakes
Not naming the depot in the LC and bill of lading
For eligible imports to be taken to a private ICD, the depot's name must appear beforehand in the letter of credit and the bill of lading. Importers who decide late that they want off-dock delivery often find that the documents do not allow it, so the container stays in the port and accrues charges. Plan the delivery route when the LC is opened and confirm that the goods fall within the current list of 65 import categories. An off-dock ICD lawyer in Chittagong can review the documents before shipment.
Paying disputed charges without protest
When a shipment is urgent, it is tempting to pay whatever the depot invoices. Payment without protest can later be treated as agreement to the rate. If a charge is in doubt, for example because a court has suspended an increase or a tariff decision is pending, pay under written protest and keep the evidence. This preserves the right to recover the overpayment without delaying the cargo.
Claiming against the wrong party
A container may pass through the port, a haulier, a depot and a forwarder within days. Each has different terms, limits and notice periods. Claims made against the wrong party, or out of time, often fail. Use the gate and event records to identify who had custody when the loss happened, and notify everyone who might be responsible while the facts are being established.
Depots overlooking licence conditions
Depot operators sometimes treat customs and environmental licence conditions as formalities. Lapses in security, CCTV, equipment or environmental compliance can lead to show-cause notices, suspension of customs functions and loss of business. Keep a compliance register for each licence, renew on time and respond to notices with documents rather than general assurances.
Ignoring empty container time limits
Empty containers that are not disposed of within the permitted time can be auctioned under customs rules, and lines continue to charge detention while empties wait. Lines, depots and importers should agree who is responsible for return and for paperwork, and track deadlines, especially when a dispute over damage or charges is holding a container back.
Foreign buyers, lines and investors
Most off-dock disputes have a foreign party: an overseas apparel buyer whose order missed its vessel, a global shipping line disputing container repair bills, or a foreign investor considering a stake in a depot business. An off-dock ICD lawyer in Chittagong explains the local regime to foreign counsel and insurers, gathers evidence locally and pursues or defends the claim here.
TRW & Co's offices in Dhaka, Singapore, Dubai and London support clients whose contracts, insurers or head offices sit abroad. For investors entering the depot sector, our foreign investment practice and due diligence lawyers review licences, land, environmental status, tariff exposure and pending litigation.
How TRW & Co helps as your off-dock ICD lawyer in Chittagong
Depot licensing and compliance
Advising new and existing depots on NBR, CPA, shipping ministry and environmental permissions, licence conditions and responses to show-cause notices.
Terms of business
Drafting depot terms, customer contracts and service agreements with shipping lines, including liability limits, notice periods and dispute clauses that will stand up.
Tariff and charge disputes
Advising depots and users on charges, protest payments, tariff committee processes and writ petitions over charges imposed without approval.
Cargo and container claims
Pursuing and defending claims for damage, shortage, pilferage and lost containers, coordinating with insurers, carriers and forwarders.
Customs issues at the depot
Handling examination disputes, release delays and seizure matters with Chattogram Custom House, alongside our customs team.
Transactions and investment
Due diligence, acquisitions and joint ventures in the depot and logistics sector, including land and lease review.
We give a clear view of options and risk without promising outcomes. To discuss a matter, contact our Chattogram office, see all our practices, or read our explainers on off-dock and ICD rules and C&F agent liability. The Chattogram office page explains how to reach us.
Checklist for depot users and operators
- Check that the import falls within the current NBR list of goods allowed through private off-docks.
- Name the depot in the LC and bill of lading before shipment, and obtain the required no-objection letters.
- Confirm the depot tariff in force, including any court order or interim agreement.
- Pay disputed charges under written protest when release is urgent.
- Request gate, event and CCTV records in writing as soon as a problem appears.
- Arrange a joint survey for damage before goods leave the depot.
- Notify all potentially liable parties within contractual time limits.
- For operators, maintain a licence compliance register and renew on time.
- Track empty container return deadlines to avoid detention and auction risk.
Frequently asked questions
01Which imports can be cleared through private off-docks at Chattogram?
Only goods on the NBR's approved list. After additions on 8 April and 17 July 2025, 65 categories of import goods can be transferred, unstuffed and delivered through private ICDs and off-docks approved by Chattogram Custom House. The list focuses on lower-risk bulk and agricultural goods and is updated periodically. Check the current list before opening the letter of credit, because the depot must be named in the LC and bill of lading in advance.
02Who is liable if my cargo is damaged at an off-dock?
Usually the party that had custody when the damage happened, subject to its terms. A depot holding goods is a bailee under the Contract Act 1872 and must take reasonable care, but its terms may limit liability or impose short notice periods. Establish custody through gate and event records, arrange a joint survey, and notify the depot, carrier, forwarder and insurer promptly. An off-dock ICD lawyer in Chittagong can assess whether any limitation clause is enforceable.
03Can a depot increase its charges whenever it wants?
Not in practice. When depots raised charges from 1 September 2025, the High Court Division suspended the increase and the shipping ministry directed that new charges should not be imposed without approval through the CPA's tariff committee process. An interim 20 per cent increase for export and empty container handling was then agreed in January 2026 for six months. Check the rate officially in force on the relevant dates before paying a disputed bill.
04What licences does a private ICD need?
According to Bangladesh Customs, a private ICD or CFS needs permission from the NBR, the Ministry of Shipping, the Chittagong Port Authority, the Department of Environment and other relevant agencies, and a warehouse licence from the Custom House. Conditions include being within 20 kilometres of the port, providing an office for customs officials, adequate container handling equipment, and a secure warehouse with CCTV. An NBR order sets out the detailed criteria.
05My export missed its vessel because of depot delay. Can I claim?
Possibly. It depends on who you contracted with, what the depot or forwarder promised about timing, the cut-off and gate-in records, and any exclusion clauses. Losses such as buyer penalties or air-freight costs are recoverable only if they were foreseeable and caused by a breach. Gather the booking, cut-off notices, gate records and correspondence immediately. An off-dock ICD lawyer in Chittagong will identify the right defendant and the time limits.
06Where are customs formalities completed for off-dock imports?
Import containers of eligible items are scanned at the port gate and moved on chassis to the depot, where goods are physically examined following risk management. Customs assessment is done at Chattogram Custom House, which issues the release order, and the goods are then unstuffed and delivered from the depot. For exports, customs officials at the depot supervise stuffing, assessment is done at the Custom House, and the container then moves to the port.
07What happens to empty containers left too long at a depot?
After unstuffing, shipping lines move empties to their nominated depots for storage, repair or reuse. Customs rules allow empty containers that are not disposed of within the permitted time to be auctioned. Meanwhile, lines may charge detention to the importer if empties are not returned on time. Agree in writing who is responsible for return and paperwork, especially when a damage or charges dispute is holding a container back.
Sources and official materials
- Bangladesh Customs: Off-Dock procedures — Functions, licensing conditions and customs procedure for private ICDs and CFSs
- NBR moves to boost import-export activities (Financial Express, July 2025) — Import list expanded to 65 categories through 19 off-docks
- Depots and port users agree 20 per cent tariff increase (Daily Observer, January 2026) — Interim tariff deal, court suspension and ministry direction
- Ctg ICDs defer export handling halt (Financial Express, December 2025) — Threatened shutdown and CPA assurance
- Bida proposes 80% off-dock unloading (The Business Standard, May 2026) — Proposal to expand off-dock import clearance
- Chittagong Port Authority — Port authority and tariff committee process
- Contract Act 1872 (Bangladesh laws portal) — Bailment and the bailee's duty of care
General information only, current as at 27 October 2026. It is not legal advice and does not create an advocate–client relationship. It reflects the law of Bangladesh unless stated otherwise, and the law, court practice and official fees change frequently. Check current official sources and take advice on the facts of your matter.
