Applicability of duty-free raw-material procurement facilities for Level Up Label Bangladesh Ltd. (LULB)

Date: 9 th September 2026 To: Level Up Label Bangladesh Ltd. (LULB) Subject: TCF Opinion on Applicability of duty-free/raw-material procurement facilities for Level Up Label Bangladesh Ltd. (LULB). Based on the information and documents provided, our review of the applicable laws and notifications, and discussions with several commercial banks and the relevant officials of the National Board of Revenue (NBR), Customs: Export and Bond Department, TCF’ s opinion is set out below. 1. Applicability of SRO No. 384-Ain/2025/106/Customs SRO No. 384-Ain/2025/106/Customs provides eligible industrial establishments with a facility to import raw materials without upfront payment of applicable duties and taxes, against a bank guarantee. However, all conditions prescribed in the notification must be fulfilled. The applicant must be an eligible manufacturer, use the imported raw materials to manufacture exportable products, directly export those products in its own name, and realize the export proceeds in Bangladesh. The applicant must also comply with the requirements relating to Industrial IRC, VAT compliance, bank guarantee, product-specific input-output coefficients, and other Customs formalities. At present, LULB supplies labels, RFID tags, hang tags, cartons, and other accessories to local garment manufacturers/exporters. This is a deemed-export or indirect-supply model. LULB does not directly export the finished products in its own name and does not realize export proceeds in its own name. Accordingly, SRO No. 384-Ain/2025/106/Customs is not applicable to LULB under its current business model. 2. Nature of LULB’s finished products The products manufactured/processed by LULB are: • Paper/Cardboard Folding Boxes/Cartons - HS Code 4819.20.90; • Plastic Apparel/Accessories - HS Code 3926.20.90; • RFID Tag - HS Code 8523.59.20; • Woven Care Label/Size Label - HS Code 5807.10.00; and • Printed Paper Hang Tag - HS Code 4821.10.00. These products are principally accessories, labels, packaging materials, or electronic-identification products. They cannot be treated as ready-made garments for the purposes of the relevant regulatory provisions. In particular, none of the five products falls under HS Chapter 61 or 62. HS Chapter 61 covers knitted or crocheted garments, while HS Chapter 62 covers non-knitted/non-crocheted garments. The fact that these products are ultimately used by RMG exporters does not, by itself, classify LULB as an RMG manufacturer or its products as RMG products. 3. Amendment by SRO No. 203-Ain/2026/58/Customs SRO No. 203-Ain/2026/58/Customs amended SRO No. 384 and added further eligible industrial sectors, including motorcycle, fish processing, handicrafts, diversified jute products, diapers and sanitary napkins, crockery, tents, terry towels, recycled cotton bags with necessary accessories, and speedboats. These additional sectors do not correspond with LULB’s current products or business activities. Therefore, the amendment does not alter the conclusion regarding the inapplicability of SRO No. 384 to LULB’s present deemed-export model. 4. Review of the Import Policy Order, 2026-2029 We have also reviewed the recently published Import Policy Order, 2026-2029. Chapter 4, in particular Article 25(2)(d), refers to the opportunity for certain eligible 100% export-oriented industrial establishments to import buyer-required raw materials on a Free of Cost (FoC) basis against a specified contract. Such import remains subject to a bank guarantee against applicable duties and taxes and compliance with conditions prescribed by the NBR. However, this provision does not create a separate or applicable facility for LULB. Due to LULB’s current accessories-manufacturing and deemed-export business model, the absence of direct exports in its own name, and the fact that its products do not fall within the relevant eligible industrial sectors, no applicable benefit for LULB was identified under the Import Policy Order, 2026-2029. 5. Applicability of SRO No. 196-Ain/2026/51/Customs SRO No. 196-Ain/2026/51/Customs provides a separate facility for direct-exporting industrial establishments to collect raw materials or inputs from warehouse licence holders, use those materials to manufacture products, and directly export the products. To use this facility, the beneficiary establishment must be a direct exporter in its own name and must comply with the applicable requirements relating to export orders, banking arrangements, bond, CBMS, documentation, and completion of export within the prescribed time. As LULB currently supplies accessories to local deemed exporters rather than directly exporting in its own name, the facility under SRO No. 196-Ain/2026/51/Customs is also not applicable to LULB. 6. Confirmations obtained We consulted several commercial banks regarding the above facilities. The banks indicated that relevant banking arrangements may, in principle, be considered for accessories manufacturers. However, a bank’s acceptance does not determine a company’s eligibi lity under Customs law. We also verified the matter with the NBR Customs: Export and Bond Department. The relevant officials confirmed that an accessories manufacturer operating as a supplier to deemed exporters is not eligible to avail itself of the above facilities. Conclusion: Based on the current information and business model, LULB is not eligible to avail itself of: 1. the bank-guarantee-backed raw-material import facility under SRO No. 384- Ain/2025/106/Customs, as amended by SRO No. 203-Ain/2026/58/Customs; 2. the FoC-based raw-material import facility referred to in the Import Policy Order, 2026-2029; or 3. the raw-material collection facility from warehouse licence holders under SRO No. 196- Ain/2026/51/Customs. This opinion is principally based on LULB’s present accessories -manufacturing and deemed-export business model, its lack of direct exports in its own name, and the fact that its finished products do not fall within the relevant eligible industrial sectors. If LULB later enters into contracts directly with foreign buyers, exports the finished products in its own name, and realizes the export proceeds in Bangladesh, the matter may be reassessed based on its revised business model, product scope, licences, and direct-export documentation. TCF Sincerely, ____________ Fumihiro Abe Director Tokyo Consulting Firm Limited (TCF) Disclaimer & Liability Waiver: This opinion is based solely on the information, documents, and verbal confirmations available to TCF as of its date. It is not a binding ruling from any government authority. Customs, NBR, or other authorities may apply or interpret the relevant laws and notifications differently. TCF accepts no liability for any loss, penalty, delay, or consequence arising from reliance on this opinion, changes in law or policy, incomplete information, or an authority’s contrary decision.