Import & Export Guides
Importing Precursor and Controlled Chemicals from China into Bangladesh: Licences, Export Permits and Customs Holds
Oct
A paint factory orders solvent. A textile dyehouse orders acid. A pharmaceutical contract manufacturer orders a raw material it has bought for years. None of these businesses think of themselves as dealing in controlled substances, yet several common industrial chemicals sit on international precursor lists because they can also be diverted into illicit drug manufacture. When that is the case, the shipment does not move on a commercial invoice and a bill of lading alone. It needs government authorisation in China before it can be exported and in Bangladesh before it can be released.
This article explains how that dual-permission system works, why it catches importers by surprise, and how to plan an order so that a container of chemicals does not sit at Chattogram while paperwork is chased across two countries. It is a planning guide, not legal advice: the lists of controlled chemicals and the procedures change, and the authority in Bangladesh has the final word on what your specific product requires.
Why ordinary chemicals can be controlled
The international framework comes from the 1988 United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances. It lists precursor chemicals in two tables. Table I generally covers substances closer to illicit end products, and Table II includes widely used industrial solvents and reagents such as acetone, toluene, hydrochloric acid and sulphuric acid, which have enormous legitimate use and are therefore controlled more lightly.
Countries implement the Convention through their own laws and their own control lists, which may be broader or narrower than the international tables. In Bangladesh the relevant law is the Narcotics Control Act 2018, administered by the Department of Narcotics Control (DNC). In China, precursor chemicals are regulated under national regulations on the administration of precursor chemicals, and exports of listed substances require permission from the competent Chinese authorities. The practical consequence is simple: if the substance is controlled at either end, you need to know before you place the order.
The first job, then, is identification. Do not rely on the product’s trade name. Ask the supplier for the chemical name, the CAS number and the safety data sheet, and check those against the current controlled lists with the relevant authority or your licensed agent. Mixtures and solutions can be controlled too, depending on concentration and the rules that apply to them.
The China side: export permission and pre-export notification
A Chinese factory or trading company cannot simply ship a listed precursor abroad. The exporter needs permission for that specific export, and the application normally involves information about the importer and the purpose of use. This is where many Bangladeshi buyers first discover the issue: a supplier asks for documents such as a copy of the buyer’s import authorisation or an end-use statement before it will confirm a shipment date.
Many governments, including China, also use the International Narcotics Control Board’s PEN Online system to send a pre-export notification to the importing country’s authority. The importing authority can then confirm or question the transaction before the goods leave. The mechanism behind this is cross-checking: the quantity, the substance and the parties in the export notification are compared with what the importing country has authorised. If your import authorisation covers less quantity than the supplier is trying to export, or names a different consignee, the export may be stopped at origin.
That is why the order quantity in the proforma invoice should be agreed only after you know what your Bangladesh authorisation will cover. Our guide to the proforma invoice as order confirmation covers the details a PI should contain; for controlled chemicals, the substance name, CAS number, concentration and quantity on the PI must match your permits exactly.
The Bangladesh side: authorisation before the order, not after arrival
On the import side, a business dealing in a controlled precursor generally needs a licence or permit from DNC covering that substance, in addition to the normal import registration requirements described in our guide to the Import Registration Certificate. The Import Policy Order may also attach conditions to specific HS codes, which your agent can confirm; see our explainer on how the Import Policy Order works.
The order of steps matters more than the individual documents. The safe sequence looks like this:
- Identify the substance using CAS number and safety data sheet, and confirm whether it is controlled in Bangladesh, China or both.
- Obtain or confirm your Bangladesh authorisation for the substance and the quantity you plan to import over the period it covers.
- Share the authorisation details with the supplier so it can apply for its export permission using matching information.
- Finalise the proforma invoice and payment terms only once both sides are confident the permits will align.
- Book freight with a carrier that accepts the cargo class, since many precursors are also classed as dangerous goods for transport.
- Prepare the bill of entry with the permit references, so customs can match the release against the authorisation.
Reversing this order, which is what happens when a buyer pays a deposit first and asks about permits later, is the single most common cause of trouble.
Dangerous goods rules apply separately
Being a precursor and being dangerous goods are two different classifications. Acetone, for instance, is a flammable liquid for transport purposes regardless of its precursor status. That means the shipper must provide a correct dangerous goods declaration, the packaging must meet UN packaging standards for that class, and the shipping line or airline must accept the booking. Many carriers restrict or refuse certain classes entirely, and air carriage of flammable liquids is far more limited than sea carriage.
Our guide to sea freight for chemicals and hazardous cargo explains the documents carriers ask for, and the article on warehouse licensing for hazardous and flammable goods covers the storage side once the goods are in Bangladesh, which is a separate licensing question from the import itself.
What a customs hold looks like and why it happens
When a controlled chemical arrives without matching authorisation, customs will not release it. The cargo stays at the port or off-dock depot, storage and container detention charges accumulate, and resolving the issue may involve DNC as well as customs. In the worst cases goods can be seized or must be re-exported.
| Mismatch | Typical consequence |
|---|---|
| Permit covers a different substance name or concentration | Release held until the discrepancy is explained or the permit amended |
| Quantity shipped exceeds authorised quantity | Excess may be refused; the whole consignment can be delayed |
| Consignee on the bill of lading differs from the permit holder | Customs cannot match the permit to the cargo |
| Product declared under a trade name with no chemical identity | Laboratory testing may be ordered before assessment |
| No dangerous goods paperwork for a hazardous chemical | Carrier or port may refuse handling |
Laboratory testing is worth understanding in its own right. If customs is unsure what a liquid or powder actually is, it can draw samples for testing, and the shipment waits for results. Our article on customs laboratory test samples explains that process. Clear chemical identification on every document is the best way to avoid it.
Common mistakes importers make
- Assuming a familiar chemical is uncontrolled. Many buyers have used a solvent for years through local traders without realising the trader held the licence.
- Letting the supplier describe the goods. A Chinese exporter may use a generic product description that does not match your permit wording, which creates a mismatch at both ends.
- Combining controlled and uncontrolled goods in one shipment without planning. A hold on one line can delay the whole container.
- Ordering more than the authorisation covers to get a better unit price, then discovering the surplus cannot be released.
- Ignoring record keeping after release. Controlled substances usually carry ongoing obligations on how stock is recorded and used; check those with the authority before you start.
How DE International can help
We work with importers of industrial and laboratory chemicals from China on the parts of this process that cross borders: confirming chemical identity and documents with the supplier before an order is placed, aligning the proforma invoice with your permits, arranging carriers that accept the cargo class, and coordinating clearance with a licensed C&F team. We do not issue permits and cannot guarantee how any authority will decide, and timelines for permits depend on the authorities involved, so we plan around them rather than promise them.
If you are planning a chemical import and want the documents checked before you commit money, contact us for a review built around your specific product and quantity. You can also explore our import and customs services, our China sourcing and buying agent service, or browse our shop.
