In Bangladesh, poor oversight of unlawful cross-border trade in hazardous electronic waste continues, turning the country into a net importer of electronic waste.
The country has rules to control e-waste. It is also a party to the Basel Convention and has introduced its own laws, like the Hazardous Waste (E-waste) Management Rules (2021).
However, enforcement of these frameworks remains weak.
Mongabay obtained and reviewed the document outlining Bangladesh’s import and export of e-waste, revealing key details on trade flows and regulatory gaps.
The document, by the National Board of Revenue (NBR), shows that 40 companies imported e-waste under HS code 8549 — the international customs code for trading e-waste — at various times between 2022 and 2025, in apparent violation of the Basel Convention, an international treaty to reduce the movements of hazardous waste between nations.
The textiles and apparel industry leads at 27 per cent, or about one quarter, of all e-waste importers.
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Hazardous heavy metals from e-waste are entering the environment and food chain, eventually reaching our dining tables. This is becoming a major public health and environmental crisis.
Shahriar Hossain, senior technical adviser, Environment and Social Development Organization
No response from importers
Mongabay reached out to Unilever Bangladesh Limited, one of the 40 e-waste importing companies and the only one that responded.
Shamima Akhter, director of corporate affairs, partnerships & communications of Unilever Bangladesh Limited, said in an email on May 21, “We confirm that we have not imported any e‑waste or restricted items. The product concerned is a load cell, which is a precision measuring instrument, and the correct HS Code for this item is 90318, as declared in our import documentation. Any change to HS Code 8549 during the clearance process was made independently by the customs authority.”
Other companies Mongabay reached out to, such as Square Toiletries Limited, Hazarat Amanat Shah Spinning Mills, Shah Cement Industries Limited, and Bangladesh Atomic Energy Commission, didn’t respond by the time of publication.
Mongabay also did not receive any formal response from the National Board of Revenue.
Illegal import and trade imbalance
Data reviewed from the obtained NBR document, along with the findings of a study by the NGO Transparency International Bangladesh (TIB), show that imports under HS 8549 amounted to about US$700,000 during the previous years, from 2022 to 2025.
During the same period, an estimated 14,985 tons of e-waste and scrap were imported, compared to 4,040 tons of printed circuit boards (PCBs) and scrap exported.
The TIB study cautions that this figure is likely an underestimation due to possible misdeclaration under other HS codes.
Md. Ziaul Haque, additional director general of the Department of Environment (DoE), said it is “a matter of great concern” that illegal e-waste trade is taking place through declared import channels under specific HS codes.
He said Bangladesh laws allow e-waste imports only when they are necessary and not harmful to the environment, and stressed the need for stronger scrutiny.
“We need to further explore and investigate what products are coming in under the label of e-waste,” he said, adding that certain items, such as old refrigerators, have already been banned due to their environmental hazards.
Haque also noted that Bangladesh permits the export of certain recyclable components, such as circuit boards that cannot be recovered locally, to countries including Japan, South Korea, Spain and Singapore.
Weak screening and informal financial practices
Though the imports of refurbished electronics and e-waste are officially banned, the TIB study points out that shipments continue to enter the country due to a lack of effective identification systems for screening such cargo.
The study also reports that informal e-waste businesses have raised concerns about illegal financial transactions, including alleged payments to obtain licenses or maintain operations outside regulatory oversight.
Shahriar Hossain, senior technical adviser at the NGO Environment and Social Development Organization (ESDO), told Mongabay that both the customs authority under the National Board of Revenue (NBR) and DoE are aware of the unlawful trade in e-waste but enforcement remains weak.
“Despite the ban on e-waste imports under the Basel Convention, cross-border regulations and local laws, the responsible agencies are not taking effective action,” he said. “Given the serious environmental and public health risks, the issue now requires intervention from the prime minister’s office.”
Hossain said old and refurbished electronic products, including laptops sold at very low prices, are still widely available in the market, indicating continuing illegal imports.
He also said weak enforcement has allowed the informal e-waste recycling sector to expand. “There are rules, but there are still no proper implementation guidelines,” he said. “Hazardous heavy metals from e-waste are entering the environment and food chain, eventually reaching our dining tables. This is becoming a major public health and environmental crisis.”
Monitoring gaps and enforcement weaknesses
Abdullah Zahid Osmani, research associate at TIB, said weak enforcement and poor coordination among regulators are allowing hazardous electronic waste to enter Bangladesh despite existing laws and international commitments.
He said, “Around 90 per cent of import consignments pass through customs with only basic checks, while only 10 per cent undergo detailed physical inspection.”
Customs officials also lack the training and resources to identify used or refurbished electronics, Osmani added.
He said inconsistencies between customs records and environmental clearance systems expose major monitoring gaps and called for stronger coordination among the DoE, Bangladesh Telecommunication Regulatory Commission (BTRC), customs authorities, law enforcement agencies and concerned ministries.
“Even with the e-waste rule of 2021 in place, the system still lacks effective coordination between agencies, which creates space for e-waste to enter the country through both legal loopholes and mis-declared shipments,” Osmani said.
This story was published with permission from Mongabay.com.
