Danish Embassy Urges NBR to Clarify Freight Forwarder License Renewal Rules

The Royal Danish Embassy in Dhaka has written to the Chairman of the National Board of Revenue (NBR), seeking clarity on license renewal provisions in the draft Freight Forwarders Rules 2025. The letter also reveals that the European Union has flagged the same regulatory gap as a non-tariff barrier in its ongoing trade dialogue with the Ministry of Commerce.

The embassy's Trade Council sent the letter on June 30, signed by Chargé d'Affaires ad interim Anders B. Karlsen. It states that the issue "has been identified and is currently being raised as a non-tariff barrier" in the EU-Ministry of Commerce dialogue. A copy of the letter was also sent to EU Ambassador to Bangladesh Michael Miller.

The dispute stems from a regulatory gap that has persisted for more than a decade. The Freight Forwarders Rules 2008 allowed wholly foreign-owned companies to obtain licenses and operate in Bangladesh, but a 2015 amendment capped foreign ownership without clarifying what would happen when those existing wholly foreign-owned licenses came up for renewal.

The draft 2025 rules seek to address part of the issue by stating that companies licensed before the new rules take effect will be deemed licensed under the updated framework. While the embassy welcomed this provision, it noted that the draft does not specify the conditions for license renewal. "In the absence of explicit saving language, there appears to be scope for differing interpretations at the time of renewal," the letter states.

To address the gap, the embassy has urged the NBR to include a provision confirming that companies lawfully established as wholly foreign-owned entities under the 2008 rules can renew their licenses without being subject to requirements applicable to new applicants.

The letter argues that the implications extend beyond individual companies. It warns that unresolved ambiguity could lead to fresh disputes and inconsistent regulatory decisions while undermining Bangladesh's reputation as a stable destination for foreign investment. The concern has gained added significance after the EU placed the issue on its trade-barrier agenda. The NBR has yet to issue a public response.