Date: 29th February 2024
The Chairman
Bangladesh Economic Zone Authority
Biniyog Bhaban, Plot#E-6/B, W Agargaon, Dhaka 1207
Attention: Mr. Mustafizur Rahman, Deputy Secretary Manager (OSS & Co-ordination)
Subject: Requesting to review the rules of foreign own bonded warehouse (Deemed Exporter) in Economic Zone.
Dear Sir,
This is Kotaro Takeuchi, Managing Director of NICCA BANGLADESH CO., LTD. (100% foreign-owned entity). I would like to inform you that NICCA BANGLADESH CO., LTD. has established a Private Limited Company located in the Bangladesh Special Economic Zone (BSEZ) registered under BEZA (BEZA Investment Clearance Ref. No.: PC-20231115034229089484).
There are two business schemes of this company. First, NICCA BANGLADESH CO., LTD. operation will start by purchasing final chemical products in the middle of 2025 under bond license from other NICCA global sites, such as Indonesia, India and Japan, after having the stock of those chemical products, those will be sold to customers in Bangladesh who have bond license (deemed exporter) and who directly export garments to other countries.
Secondly, in 2026 NICCA BANGLADESH CO., LTD. will start manufacturing textile chemical products in Bangladesh in the same location in BSEZ. On top of selling chemical products purchased and imported from other NICCA sites, the manufactured chemical products will be also sold to customers in Bangladesh who have bond licenses (deemed exporters) and export garments to other countries.
It is not clearly stated in the Bonded Warehouse Licensing Rules 2008 that, product cannot be sold between two bonded warehouses (deemed exporters) and a Bonded warehouse (deemed exporters) can sell their product only to the direct exporter.
It is very significant to mention that, there is a huge customer base who are operating Bonded Warehouses (deemed exporters) in Bangladesh and those customers are interested to buy products from our Bonded warehouse. If we can sell products to these deemed exporter the time and cost will be minimized.
But if we sell our products only to direct exporters then our product line will become very narrow, and we will face a great loss by losing our potential customers.
With the passage of time the business and economic environment has changed a lot. Besides Bangladesh govt. is encouraging FDI by providing several kinds of facilities and incentives.
Hence it is our proposal to review the rules and regulations and make it more business-friendly for the bonded warehouse which helps to attract more FDI, increase employment, minimize time, cost, and import dependency as well as help to industrialization across the country.
Overall, the establishment of a bonded warehousing facility by NICCA BANGLADESH CO., LTD. can have a positive impact on the export sector in Bangladesh. By providing direct and deemed exporters access to bonded warehousing, NICCA BANGLADESH CO., LTD. can help reduce import time and enhance export competitiveness.
So, we would like to emphasize that, as a deemed exporter of textile chemical products, if NICCA BANGLADESH CO., LTD. has the business route not only to direct exporters but also “to deemed exporters”, NICCA BANGLADESH CO., LTD. can contribute to the better supply chain by reducing lead time of textile chemicals and enhance export competitiveness for customers.
It is highly requested to share your valuable opinion on the above issue at your earliest convenient time.
Sincerely,
🗸
______________
Kotaro Takeuchi
Managing Director
NICCA BANGLADESH CO., LTD.