Letter from the table: A threshold should not be the only test

To the Trade Council,

I oppose a clause that would make an importer’s annual import value the sole test for whether small-trader safeguards apply. I am offering this objection while TR-001 is still gathering evidence, not responding to an adopted rule. If a value-only clause is being considered for the draft, please do not carry it forward in that form.

My objection comes from a shipment that reached Chattogram in February. On 3 February, I received a forwarding estimate of BDT 118,000 for freight and handling. I planned around that figure. The shipment arrived on 11 February. When I sought the final amount needed to complete clearance, the total listed for freight and handling was BDT 146,500. That was BDT 28,500 more than the estimate. It was not the whole cost of importing: duties and taxes were assessed separately through the customs process, according to the applicable classification and valuation.

I did not treat the estimate as a customs ruling. I know that a forwarding estimate cannot determine what the National Board of Revenue will assess, and that the amount of duty depends on the goods’ classification and the rules in force. I also know that a trader has to meet the documentation requirements for importing. My concern is narrower: before the shipment was moving, I could not see a dependable, itemised picture of the costs that would fall to me, or a clear explanation of which amounts were estimates and which could still change.

I asked for the charges to be separated so I could compare the estimate with the final amount. I checked the papers I had received and followed up through the forwarding process. I had to make arrangements for the additional BDT 28,500 while also keeping money available for the separate customs payment. For a small trader, that is not an accounting inconvenience. It is money unavailable for other obligations, and it can turn a workable order into a cash-flow problem at the point when there is little room to change course.

A threshold based only on annual import value would not answer that problem. A trader can have a modest annual total and still face a large, unpredictable cost on one shipment. Another trader may cross a value line while having better access to finance, experienced staff, and a stable freight arrangement. Annual value can be useful, but it is not a reliable substitute for the practical burden of understanding and paying the costs of a particular import.

I am not asking the Council to make a forwarding estimate binding on customs, or to prevent lawful duties from being collected. I am asking for a rule that distinguishes between the public charge and the service provider’s estimate, and that gives a small trader enough information to plan. A useful landed-cost statement should show the known charges separately, identify estimates, state what may change and why, and provide an updated itemisation when the amount changes. Where new trade rules or tariffs apply, plain-language guidance and a reasonable phase-in should help smaller traders understand what they must do.

Please consider replacing the value-only wording with this clause:

“Annual import value may be considered when identifying small traders, but shall not be the sole basis for determining access to small-trader guidance, transition periods, or other proportionate safeguards. Any applicable landed-cost disclosure should itemise known charges, identify estimates and amounts subject to reassessment, and explain material changes in plain language. Nothing in this clause limits the lawful assessment or collection of customs duties and taxes.”

This wording would not promise that every cost is fixed before arrival. It would make the uncertainty visible earlier and make changes easier to understand. It would also avoid excluding someone simply because a single shipment, or a short period of higher import costs, pushes them across an annual line.