TRW & Co · Shipping, port and admiralty
Off-Dock and ICD Rules for Chattogram Exporters and Importers
The off-dock container depot rules at Chattogram decide who may run a private ICD, what cargo it can handle, how customs supervises it and who pays for loss or delay. Depots handle all exports, most empties and 65 categories of imports. This guide explains licensing, permitted cargo, liability, the 2025 tariff dispute and practical steps.
Key pointDepot charges are no longer purely contractual: after a 2025 court suspension the shipping ministry required Tariff Committee approval for new charges, so check every invoice against the rate officially in force.
At a glance
All exports via depots
Private off-docks around Chattogram handle all export container stuffing and most empty containers, as well as a growing list of permitted import goods.
65 import categories
The NBR expanded the permitted import list in April and July 2025 to 65 categories, handled through 19 operational private depots at Chattogram.
Layered licensing
Depots need NBR permission under its 2021 off-dock policy, no-objections from the shipping ministry and CPA, and a customs bonded area declaration.
Bailee's duty of care
A depot holding cargo or containers is a bailee under the Contract Act 1872, though its terms of business may try to limit liability.
Tariffs need approval
A 2025 tariff increase was suspended by the court, and the shipping ministry said new charges need Tariff Committee approval before they can be imposed.
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The short answer: what the off-dock container depot rules require
The off-dock container depot rules that govern Chattogram's private inland container depots (ICDs) come from three places: the National Board of Revenue's licensing policy and customs orders, approvals from the Ministry of Shipping and the Chittagong Port Authority, and the contracts depots sign with shipping lines and cargo owners. Together they decide who may operate a depot, what cargo it may handle, how customs supervises it and who pays when goods are lost, damaged or delayed.
The stakes are high, which is why the off-dock container depot rules attract so many disputes. The private depots around Chattogram handle all of the country's export cargo, most empty containers and, since July 2025, 65 categories of import goods. When they stop work, exports stop with them.
This guide explains the licensing regime, the permitted cargo, how customs supervision works, the liability rules for damage and delay, the tariff dispute of 2025 and what exporters, importers and depot operators should do. For a live problem, speak to our off-dock and ICD lawyers in Chattogram.
What off-docks do at Chattogram
Off-docks, also called private ICDs or container freight stations, are customs-bonded yards located away from the port terminals. They were encouraged to ease congestion at Chattogram and to move stuffing, unstuffing and storage out of the port.
- Export stuffing. Exporters deliver cargo to the depot, where it is examined and stuffed into containers under customs supervision before moving to the port.
- Empty containers. Shipping lines store, repair and release empty boxes at depots for export stuffing or re-export.
- Selected imports. Containers carrying permitted import goods move from the port to the depot, where they are examined, assessed and delivered.
Scale matters to the legal picture. In December 2025 The Business Standard reported that the 19 private depots supporting Chattogram could store about 106,000 TEUs, nearly double the port's own yard capacity, and handled roughly 2.2 million containers a year. Our guide to clearing goods at Chattogram Custom House explains how depot delivery fits into clearance.
Licensing: who may run an off-dock
A private depot needs several layers of permission. The core licence comes from customs, but other authorities must agree first.
- NBR policy. The NBR's ICD/CFS or Off-dock Construction and Operation Policy 2021 sets the criteria for permission to build and run a depot. A Ministry of Shipping policy from 2016 also applies.
- No-objections. Applicants obtain no-objection certificates from the Ministry of Shipping and the Chittagong Port Authority, and Chattogram Custom House makes a recommendation.
- Bonded area declaration. The NBR declares the depot site a customs bonded area, subject to conditions.
- Physical and system requirements. Reported conditions for a 2021 approval included minimum land area and handling capacity, separate sheds and yards for import, export and empty containers, examination sheds, an auction yard, banking facilities and connection to customs' ASYCUDA World system, according to the Financial Express. Location rules relative to the port also apply.
- Other permits. Trade licence, fire licence and environmental clearance are needed as for any industrial site.
Permission is not permanent or unconditional. In July 2023 the NBR granted, then within days revoked, permission for a proposed rail-linked depot near the port after concerns that it had been approved by relaxing the policy, as the Financial Express reported. New depots have also been allowed to start with empty and export containers only, with import handling added later.
Permitted cargo: exports, empties and the import list
All export containers pass through private depots. Imports are different: only goods on the NBR's approved list may be transferred to, unstuffed at and delivered from a depot, and everything else is cleared at the port.
| Cargo | Off-dock role | Controlling rule | Practical note |
|---|---|---|---|
| Export cargo | Receipt, examination, stuffing and dispatch to port | Customs supervision at the depot; assessment through Chattogram Custom House | All exports go through depots; cut-off times drive disputes |
| Empty containers | Storage, repair and release | Contracts with shipping lines; customs time limits | Damage and repair bills are common claims |
| Listed imports | Transfer, unstuffing, examination and delivery | NBR list of permitted goods, now 65 categories | Routing must be arranged in advance in the shipping documents |
| Other imports | None; cleared at the port | Customs Act 2023 and port rules | Port storage and demurrage apply instead |
The import list has grown. The NBR added 12 categories on 8 April 2025 and 15 on 17 July 2025 to the 38 previously allowed, bringing the total to 65 types of goods across 19 operational depots, according to the Financial Express. In 2026 BIDA, now succeeded by the Invest Bangladesh Authority, proposed gradually allowing most import goods to be cleared through off-docks, as The Business Standard reported. Check the current list before routing any import.
Customs supervision at the depot
A depot is an extension of customs control. Customs officers work on site, examinations happen there, and goods cannot leave without a release order from Chattogram Custom House. The off-dock container depot rules sit within the Customs Act 2023, which governs bonded areas, warehousing, examination and the consequences of goods not being cleared in time.
Two features cause most problems. First, goods held too long can be treated as handed over to the government under the 2023 Act where the delay is the importer's fault, and then sold or destroyed. Secondly, customs agents and depot operators carry their own licence obligations, and errors at the depot can expose both to penalties as well as the cargo owner.
For depot operators, compliance is a condition of the licence itself. Keeping customs records accurate, giving officers access, maintaining the required facilities and keeping systems connected to ASYCUDA World are ongoing obligations. A depot that falls short risks penalties, suspension of particular functions or, at worst, loss of its bonded status, which would also strand its customers' cargo. Operators should audit themselves against the conditions in their permission letter at least annually.
An import container can be routed to a private depot only if the arrangement is set up before arrival, with the depot named in the shipping documents and the necessary no-objections obtained. If it is not, the container is cleared at the port and port storage and demurrage apply. Build the routing into the purchase contract and the LC, not after the vessel berths.
How cargo moves through a depot, step by step
The off-dock container depot rules are easiest to understand by following a consignment. The sequence below is for a typical export; imports on the permitted list run broadly in reverse.
- Booking. The exporter or its forwarder books space with the shipping line, which nominates a depot and releases an empty container there.
- Cargo delivery. The exporter's trucks deliver cartons to the depot gate, where the depot records receipt and condition on a tally or receipt document.
- Customs formalities. The C&F agent lodges the export declaration through ASYCUDA World, and customs officers at the depot examine the cargo as required.
- Stuffing and sealing. The depot stuffs the container under customs supervision, and the container is sealed and documented.
- Movement to port. The container moves to the port terminal before the vessel cut-off, with gate-out and gate-in records at each end.
- Loading and documents. The line loads the container and issues the bill of lading; the bank handles the export documents and the proceeds.
Each handover creates a record, and each record is evidence if something goes wrong. Most disputes under the off-dock container depot rules come down to who had custody when the loss or delay happened, so keep copies of every receipt.
Liability for damage, loss and delay
The relationship between a depot and its customers is contractual, but the general law fills the gaps. Where a depot holds goods or containers, it is a bailee under the Contract Act 1872 and must take the care a person of ordinary prudence would take of their own goods.
- Who contracts with whom. Shipping lines usually nominate depots and hold service agreements with them. Exporters and importers may book directly or through a freight forwarder or C&F agent. The party with the strongest claim may not be the one that paid the invoice.
- Limitation clauses. Depot and forwarder terms often cap liability or exclude certain losses. Whether those terms bind a cargo owner depends on whether they were incorporated into the contract and how they are worded.
- Delay. Missed vessel cut-offs, slow examination or depot shutdowns can cause shipment delays, buyer penalties and extra storage charges. Recovery depends on the cause and on what the contract says about timing.
- Evidence. Equipment interchange receipts, gate-in and gate-out records, tally sheets, CCTV and survey reports usually decide damage claims.
For cargo lost or damaged in the chain, see our cargo claim lawyers in Chattogram.
Charges and the 2025 tariff dispute
Depot charges used to be treated as private pricing. That changed in 2025. The depots' association sought to raise charges for stuffing, ground rent, lift-on and lift-off, documentation and transport by 30 to 63 per cent from 1 September 2025. Port users refused to pay, the matter went to court and the revised tariff was suspended. The shipping ministry then clarified that new charges could not be imposed without Tariff Committee approval.
In December 2025 individual depots told shipping lines they would stop handling export cargo and empties, before the threat was deferred. The off-dock container depot rules on charges therefore now include an official approval layer, and any invoice should be checked against the rate formally in force on the relevant dates. Our guide to container demurrage charges covers the related line charges.
Illustrative scenario: export cargo damaged at the depot
This scenario is illustrative only; the parties are generic.
A garment exporter delivers cartons to a private depot for stuffing. Rain enters a damaged shed roof overnight and several cartons are soaked. The depot stuffs the cargo anyway, the container misses the feeder and the buyer rejects part of the shipment.
The exporter's forwarder booked the depot, the shipping line nominated it and the depot's terms cap liability. The exporter's lawyers first secure the evidence: depot receipts, the tally sheet, photographs, a joint survey and the forwarder's booking terms. They then assess claims against the depot as bailee, against the forwarder under its contract and under the exporter's cargo insurance. The outcome turns on the documents gathered in the first few days, which is why the off-dock container depot rules matter less than the paperwork at the gate.
Risks and common mistakes
Assuming an import can go off-dock
Only goods on the NBR's current list can be unstuffed and delivered at a private depot, and only if the routing was arranged in advance. Importers sometimes assume their goods qualify, or try to redirect after arrival, and end up paying port storage and line demurrage while the paperwork is corrected. Check the HS code against the current list, name the depot in the shipping documents and confirm no-objections before the vessel arrives.
Not documenting condition at gate-in
Damage claims against depots fail more often for lack of evidence than for lack of merit. If cargo or containers enter the depot without a clean, signed record of condition, the depot can argue the damage happened earlier. Insist on an equipment interchange receipt or tally record that records condition, photograph cargo at delivery, and call a joint survey immediately if damage is found.
Paying unapproved charges without protest
Since the 2025 court suspension and ministry direction, charges above the officially approved tariff can be challenged. Paying without protest makes recovery harder. If an invoice includes charges you consider unapproved, pay under written protest where you must release cargo, keep copies, and raise the issue through the depot, the shipping line and, where necessary, the CPA or the courts.
Leaving goods at the depot too long
Storage charges rise with time, and under the Customs Act 2023 goods not cleared within the permitted period because of the importer's default can be treated as handed over to the government and later auctioned. Track every consignment, clear disputes about value or documents quickly and seek extensions formally.
The cross-border angle
Foreign buyers, shipping lines and freight forwarders deal with Chattogram depots through local agents, and contractual terms are often set abroad. When cargo is damaged or delayed, the buyer's insurer may be in Europe or the US, the line in Singapore or Dubai and the depot in Chattogram. Claims must be coordinated so that time limits are met in each contract. TRW & Co's offices in Singapore, Dubai and London work with our Chattogram team on these chains. For investors considering a new depot, our import and export lawyers advise on licensing and approvals.
What to do next: a checklist
- Check whether your import goods are on the current off-dock list before shipment.
- Name the depot in the shipping documents and obtain no-objections in advance.
- Get signed condition records at gate-in and gate-out.
- Read the depot's, forwarder's and line's terms for limitation clauses.
- Check invoices against the officially approved tariff.
- Track storage time and customs deadlines for every consignment.
- Notify claims in writing promptly and arrange a joint survey.
For advice on the off-dock container depot rules or a depot dispute, contact TRW & Co's law firm in Chattogram through our contact page, at info@trw.co or on +880 1779 127165. We are at Room 4022, Annex 2, District and Sessions Judge Court Building, Court Hill (Porir Pahar), Kotwali, Chattogram 4000.
Frequently asked questions
01What is an off-dock or private ICD in Chattogram?
It is a privately operated, customs-bonded container yard located away from the port terminals. At Chattogram, private off-docks stuff all export containers, store and repair empty containers for shipping lines and handle a list of permitted import goods. Customs officers work on site, and goods leave only after Chattogram Custom House issues a release order. The depots are licensed by the NBR with approvals from the Ministry of Shipping and the Chittagong Port Authority.
02Which import goods can be delivered from off-docks?
Only goods on the NBR's approved list. As of July 2025 the list covered 65 categories, after 12 were added on 8 April 2025 and 15 on 17 July 2025 to the 38 previously allowed. The list mainly covers lower-risk goods and is updated periodically, and there have been proposals to widen it. Check the current list against your HS code before shipment and arrange routing in advance.
03Who is liable if my cargo is damaged at a depot?
It depends on the contracts and the evidence. A depot holding goods is a bailee and must take reasonable care, but its terms may limit liability. The shipping line, forwarder or C&F agent may also be liable under their own contracts. Secure condition records, photographs and a joint survey at once, notify all parties in writing and check your cargo insurance. The documents gathered in the first days usually decide the claim.
04Can off-docks increase their charges freely?
Not any more in practice. When the depots' association tried to increase charges from 1 September 2025, port users objected, the court suspended the revised tariff and the shipping ministry clarified that new charges could not be imposed without Tariff Committee approval. Check whether the rate on your invoice was officially approved for the period concerned, and pay disputed amounts under written protest if you must release cargo.
05How do I get a licence to set up a private ICD?
Apply to the NBR under its off-dock construction and operation policy, with no-objection certificates from the Ministry of Shipping and the Chittagong Port Authority and a recommendation from Chattogram Custom House. The site must meet conditions on land, capacity, sheds, examination areas, auction yard, banking and ASYCUDA World connectivity, as well as location rules. Environmental, fire and trade licences are also needed. Permission can be conditional, phased and revoked if conditions are not met.
06What happens if goods stay at a depot too long?
Storage charges increase, and under the Customs Act 2023 goods not released within the permitted period because of the importer's default can be treated as handed over to the government. They may then be sold or destroyed after notice. If clearance is delayed by a dispute over value, classification or documents, act early, seek any available extension in writing and keep evidence of the steps you took.
Sources and official materials
- NBR moves to boost import-export activities (Financial Express, July 2025) — Import list expanded to 65 categories through 19 depots
- 19 private ICDs to halt export cargo handling (The Business Standard, December 2025) — Capacity, tariff dispute, court suspension and ministry direction
- New private ICD approved (Financial Express, 2021) — Licensing conditions for a new Chattogram off-dock
- NBR pulls plug on Saif Logistics off-dock project (Financial Express, 2023) — NBR off-dock policy 2021 and revocation of permission
- Bida proposes 80% off-dock unloading (The Business Standard, 2026) — Proposal to widen off-dock import clearance
- Contract Act 1872 (Bangladesh laws portal) — Bailment and the bailee's duty of care
- Chittagong Port Authority — Port authority and tariff process
General information only, current as at 2 November 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.
