A casual look at the import policy may give one an impression that sample import is very easy. But entrepreneurs actually encounter a lot of difficulties in importing samples for export-oriented businesses.
According to the Import Policy Order 2015-18, import of samples, advertising materials and gifts only requires payment of certain cost and freight (CFR) and no permit or approval of Chief Controller of Import & Export (CCI&E) is required. It also says if foreign suppliers do not agree to supply samples free of cost, concerned exporters or manufacturers can import samples on payment through normal banking channel after taking permission from the Export Promotion Bureau (EPB) and the Office of Chief Controller of Imports and Exports (CCI&E). And with the permission of the CCI&E, one can import samples more than the allowable limit.
Entrepreneurs have to pay duty on sample-import. Since these are offered free by the buyers, while fixing duty during import, customs officials determine the prices based on their assumption.
Usually samples are imported by air by paying higher costs to maintain the lead time. But despite the introduction of online payment and checking system it takes more than 10 days to get the delivery.
Samples are one of the pre-requisites for export competitiveness, as buyers' want to have a finished product as per the samples sent by them.
In the process of sample-import Bangladesh Biman, courier companies and customs play crucial roles. Agent of Biman submits the manifest while courier companies issue notice of arrivals. Duties can be paid online while deliveries are being done by the C&F agent or courier companies.
So for smooth delivery of the samples a concerted effort from all of these groups are necessary.
On the other hand, if full automation can be carried out 'notice of arrival' can be obtained instantly which takes almost two days at present.
Almost eight agencies are involved in the process of importing samples. These are: importer/exporter of sample, C&F agent, courier service company, Bangladesh customs, Biman Bangladesh Airlines, Civil Aviation Authority of Bangladesh, National Board of Revenue (NBR), Office of the Chief Controller of Import & Export (CCI&E).
Sample may include consumer goods, consumer durables, prototypes of engineering goods or even high value equipment, machineries (including agricultural machinery) and their accessories. Import of samples can be done by the trade, industry, individuals, companies, associations, research institutes or laboratories. These can also be imported by the representatives of foreign manufacturers as part of their personal baggage.
An e-Manifest needs to be submitted to the computerised customs management system ASYCUDA World (AW) by the courier service company. The e-Manifest contains a description of imported sample item, mark number, manifest line number, quantity of goods, gross weight of goods, consignee name, description of route, airplane number, container number, house airway bill, etc. Officer of courier service company may submit the manifest from their office or from the customs office via online.
Dhaka Customs House, the prime gateway for air cargo in Bangladesh, introduced electronic submission of manifest from March 01, 2014. It provides an User ID and Password to the designated officer of the Airlines Operator Committee. A specific process needs to be followed to submit the e-manifest.
For submission of tax and duty on imported samples, Bangladesh Customs introduced a prepaid payment system. Importer opens a prepaid account in a bank which is linked up with the ASYCUDA. Tax and duty are automatically adjusted and paid from this account.
The courier service company needs to submit each House Airway Bill (HAWB) of the MAWB. For an example, 10 bill of entries need to be submitted under a single Master Airway Bill (MAWB). That means 10 clearance certificates are required for a single MAWB. This is costly and time consuming. The importers of Malaysia and Sri Lanka are free from this hassle. There is a practice of Console system in countries like Malaysia and Sri Lanka. They need to have the clearance of a single MAWB instead of 10 HAWBs. This system reduces the cost of importing samples for manufacturing industries.
Ready-made garments (RMG) factories, shoe factories, foreign manufacturer's agents, factories in both export processing zone (EPZ) and non-EPZ exporters, bonded warehouses are the major importers of samples in Bangladesh. And all of them face serious hassles at different stages in importing samples.
There are more than 50 multinational and national courier service companies in Bangladesh who handle 60 per cent of the samples imported to the country. But the quality of service of most of these companies is not up to the mark.
As per the section 207 of Customs Act, 1969, it is mandatory to have licenses for each entity who want to work with Bangladesh Customs. They also need license from the postal department.
Role of C&F agent is very significant in the process. Importer appoints an authorised dealer (C&F agent) to deal with the whole process. Quick and swift release of imported sample depends on the efficiency of the C&F agent. But many lack efficiency.
Bangladesh Customs is the highest authoritative body to take care the export-import issue. While daily number of bill of lading through Chittagong port is about 1200-1500, the customs of Dhaka airport deal about 2500-2700 per day. It requires skilled manpower and sufficient logistics to handle such a huge volume of bill of landing. Consignments of sample is very small but it requires huge paper work.
Biman Bangladesh Airlines is the ultimate custodian of imported goods/sample when these come by air-cargo. Samples are stored in the warehouse of Biman Bangladesh, but these samples are often stolen from the warehouse, allegedly by a syndicate consist of concerned officers and staffs of Biman.
There are problems from the side of the importers also like miss-declaration, submission of wrong import generated manifesto (IGM), importing more than the prescribed limit. Some importers even import commercial goods under the declaration of import of samples.
Problems related to the ASYCUDA like slow server, bandwidth problem, release of locked B/E and payment order need to be solved. There should be policy consistency between import policy and customs act and rule.
Import of sample is subject to payment of tax and duty and government should take initiatives to resolve confusions in this procedure.
Rules regarding IM4 & IM7 of ASYCUDA system should be included in Import Policy and Customs Act.
In short, the total mechanism of import of sample is still in disarray causing sufferings to exporters and harming export competitiveness.
