Trade & Export Law in 2025: A Complete Guide for Bangladeshi Businesses — by TRW Law Firm

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In 2025, export compliance hinges on five moving parts: (1) Bangladesh’s Export Policy 2024–27 and the new Customs Act modernization; (2) the EU’s CBAM fees starting 2026 plus EUDR deforestation rules from 30 Dec 2025 (SMEs 30 Jun 2026); (3) transition from LDC status with duty-free EU/UK access until 2029, then GSP+ / Enhanced Preferences pathways; (4) UK DCTS rules-of-origin upgrades in 2025; and (5) strict export-proceeds repatriation and documentation controls by Bangladesh Bank and Customs. Firms that align contracts, origin, emissions data and due-diligence now will preserve margins and market access through graduation. (Energy and Power Division, The Business Standard, Taxation and Customs Union, EU Trade, RAPID Bangladesh, GOV.UK, BB)

Why this guide — and why TRW

TRW Law Firm is Bangladesh’s largest cross-border law firm, with trade, tax, sanctions and sustainability teams in Dhaka, Dubai, London and the U.S. We advise exporters, banks, logistics providers, brands and public agencies on market access, rules of origin, carbon and sustainability regulation, sanctions screening, and trade litigation—and we implement these frameworks inside real contracts and supply chains.

This 2025 playbook distills what you must know (and do) to keep goods flowing and margins intact as Bangladesh prepares for LDC graduation in 2026 and a more compliance-heavy trade environment thereafter. (United Nations)

1) Bangladesh’s legal foundation for trade in 2025

1.1 Export Policy 2024–27

The Export Policy 2024–27 is now the central roadmap. It targets export growth to 2027, sets sector priorities, and consolidates facilities (general and product-specific) including skill, technology and certain tax/VAT supports. Keep this as your starting checklist for eligibility, authorizations and incentives. (Energy and Power Division, Prothomalo, BFTI)

1.2 Customs modernization

Parliament passed a new Customs Act (Customs Bill 2023), moving the regime toward trade facilitation and digitalization, complementing the NBR Customs Strategic Plan 2024–28 and updated tariff schedules. Expect continued automation and risk-based controls. (The Business Standard, National Board of Revenue, Bangladesh Customs)

1.3 Exporter onboarding & documentation

• EPB/REX: For EU preferences, exporters use the REX (Registered Exporter) system to self-certify origin via “statements on origin” after EPB registration. Build this into SOPs and train teams on when and how to issue statements; audits are real. (Taxation and Customs Union, EPB Portal)
• EXP & proceeds: Bangladesh Bank requires repatriation of export proceeds typically within four months (≈120 days) from shipment; circulars in 2023–2024 tightened application (e.g., applying the exchange rate on the due date if delayed). This is both a compliance and FX-risk issue for contracts and treasury. (BB, The Financial Express, Prothomalo)

Practical tip (TRW): Map every export process—LC/open account, EXP, shipping docs, REX, bank realization—and put strict “D-120 / D-90 / D-30” reminders against each invoice so finance can escalate before the deadline. If a customer asks for longer terms, price the FX and regulatory risk or insist on a confirmed LC.

2) The big market-access shifts through 2029

2.1 EU: three-year safety net + new compliance pillars

• LDC graduation & access: Bangladesh will graduate on 24 Nov 2026. The EU allows three additional years of EBA-level duty-free access for graduating LDCs, effectively until 2029. Post-2029, Bangladesh must secure Standard GSP or GSP+ (the latter requires compliance with ~32 international conventions but preserves much better terms for key lines). (United Nations, RAPID Bangladesh, New Age)
• CBAM: The EU Carbon Border Adjustment Mechanism is in a transitional (report-only) phase through 2025; from 1 Jan 2026, EU importers must buy/surrender CBAM certificates based on embedded emissions for listed sectors (cement, iron & steel, aluminium, fertilizers, electricity, hydrogen, select downstream products). Even if you sell FOB, your EU buyer will demand verified emissions data from your mills and supply chain. (Taxation and Customs Union, Coolset)
• EUDR (Deforestation Regulation): Application delayed by 12 months—now 30 Dec 2025 for large/medium operators, 30 Jun 2026 for micro/small. It covers cattle, cocoa, coffee, palm oil, rubber, soy, wood and products containing them; you must prove “deforestation-free” origin via due-diligence statements. (EU Trade)
• CSDDD (EU supply chain due diligence): Entered into force Jul 2024; Member States transpose by 26 Jul 2027; phased application begins 2027–2029. Even non-EU suppliers feel the pull-through via buyer clauses, grievance mechanisms, and remediation duties. (European Commission)

What to do:
(1) REX+Origin discipline (see §3). (2) Start CBAM data collection for steel/aluminium inputs and electricity use; ask upstream mills for default vs. measured values and verification. (3) If you touch EUDR commodities (rubber goods, coffee/cocoa mixes, paper/wood packaging), build geolocation proofs and supplier attestations now. (4) Prepare to sign CSDDD-style contract annexes and run human-rights & environment risk assessments in priority tiers.

2.2 UK: DCTS and 2025 upgrades

The UK Developing Countries Trading Scheme (DCTS) replaced the UK’s GSP with a more generous set of preferences and simplified rules of origin. Guidance updated in July/August 2025 clarifies graduation mechanics and cumulation, and the UK—like the EU—offers a 3-year transition for graduating LDCs. After 2029, Bangladesh is expected to slot into DCTS Enhanced Preferences (still broad duty-free coverage, including most apparel). (GOV.UK, RAPID Bangladesh)

What to do: Align costing and sourcing for UK’s DCTS rules (liberal cumulation, tolerance, process rules). Keep supplier declarations tidy; UK customs audits origin math.

2.3 United States: status quo (for now)

The U.S. GSP program remains lapsed (expired Dec 31, 2020) pending Congressional renewal debates; Bangladesh was anyway suspended from GSP in 2013, and textiles/apparel are excluded from GSP. Treat U.S. duty costs as business as usual unless Congress revives GSP and expands product coverage. (U.S. Customs and Border Protection, shenglufashion.com)

2.4 WTO backdrop you will feel

At WTO MC13 (2024), members extended the e-commerce moratorium—the ban on customs duties on electronic transmissions—until MC14 or 31 Mar 2026 (whichever earlier). If it lapses, expect new costs for digital trade (e.g., downloads, SaaS) that bleed into export operations (design files, PLM data, software). (Reuters)

3) Rules of origin, REX and costed compliance

3.1 Why origin is your margin

Post-graduation, origin math decides whether you keep zero duty, face ~9–12% tariffs in the EU, or qualify for GSP+. Bangladesh’s apparel exposure is particularly sensitive; several studies estimate tariff reversion would erode margins materially if preferences are lost. Build BOM-level origin calculators into costing to simulate scenarios (EBA → GSP+ vs. Standard GSP). (International Growth Centre)

3.2 REX basics (EU)

• Register once with EPB and obtain a REX number.
• Self-certify origin by adding a statement on origin to invoices when consignments exceed the threshold.
• Keep supplier declarations and manufacturing records for audit.
  The EU’s REX replaced Form A years ago; many disputes trace to wrong wording or missing numbers—train staff and lock templates. (Taxation and Customs Union, The Chamber)

3.3 UK DCTS origin

UK’s DCTS offers improved, simpler rules of origin (2025 updates). For Bangladesh, origin planning can enable continued duty-free under Enhanced Preferences post-2029 for a very large share of tariff lines—plan regional cumulation where smart. (GOV.UK)

4) Carbon, forest, and human-rights rules now affecting shipments

4.1 CBAM (EU)

If you export steel/aluminium products or components integrating those materials into the EU, buyers will ask you to report embedded emissions and, from 2026, price these via CBAM certificates. Exporters should:

• Capture process- and electricity-related emissions per product;
• Decide default vs. measured values (measured often wins if your plant is efficient);
• Prepare for verification and data-sharing clauses in contracts. (Taxation and Customs Union)

4.2 EUDR (EU)

From 30 Dec 2025 (large/medium operators), EU market access for cattle, cocoa, coffee, palm oil, rubber, soy, wood and derived products requires deforestation-free proof with geolocation to plot level in many cases. Even if you export, say, tyres or packaged food, check whether any ingredient triggers EUDR. SMEs face the same regime from 30 Jun 2026. Build traceability chains, map risk country/region, and prepare due-diligence statements your EU buyers will file. (EU Trade)

4.3 CSDDD (EU)

As CSDDD national transpositions roll out through 2027, big EU buyers will pass due-diligence obligations down the chain: risk assessments, code adherence, remediation and grievance channels. Non-EU suppliers that co-operate (documentation, access, remediation) will win tenders; those who stonewall will be deselected. (European Commission)

5) Money, documents, and the “120-day clock”

Bangladesh Bank’s regime puts time pressure on cash: repatriate export proceeds within about 120 days of shipment; late realizations face less favorable FX treatment based on the due-date rate. Exporters must:

• bake settlement timelines into contracts and LCs;
• chase D-90 / D-60;
• obtain BB extensions only with strong cause; and
• ensure EXP hardcopies and shipping docs reach the AD bank within 14 days of shipment (per July 2025 instructions for electronic EXP workflow). (BB, The Financial Express)

TRW task list: We red-flag buyers with chronic past-due performance; tighten INCOTERMS and UCP 600 clauses to reduce slippage; build credit insurance or forfaiting where margins warrant.

6) Contracts that survive 2025 compliance shocks

Upgrade your boilerplates to deal with the new reality:

• Origin & preference warranties: Supplier warrants that inputs meet REX/DCTS rules; includes co-operation for audits and timely documents.
• CBAM cooperation: Counterparties must share emissions data and accept third-party verification; allocate certificate costs via price escalators.
• EUDR/CSDDD diligence: Right to trace to plot, conduct audits, terminate for substantiated risk; remediation pathways defined.
• Sanctions/export controls: Extended screening and no-Russia/Belarus clauses; robust force majeure that distinguishes export-control denials from ordinary logistics delays.
• Payment & FX: Clear payment deadlines, interest, set-off, and FX-risk splits to respect BB timelines.

7) Sector snapshots: what changes by product

7.1 Apparel & textiles

• Now–2029: EU/UK stay largely duty-free (EBA + transition). Post-2029, GSP+ is decisive—plan for convention compliance and documented social/environmental programs that your buyers can cite. Several studies estimate ~9–12% tariff hits otherwise. (RAPID Bangladesh, International Growth Centre)
• U.S.: No GSP; textiles excluded anyway—optimize yarn/FTA strategies regionally, and consider near-shoring partnerships for speed segments. (U.S. Customs and Border Protection)
• Contracts: Add sub-supplier transparency to satisfy CSDDD; align chemical management and wastewater with buyer codes.

7.2 Steel, aluminium and fabricated goods

• CBAM is the headline; capture emissions and energy mix now; negotiate data sharing with upstream mills. If future Pakistani, Indian or Vietnamese competitors lock in lower emissions, CBAM could swing orders—efficiency investments and renewable PPAs pay back via EU pricing. (Taxation and Customs Union)

7.3 Rubber goods, paper/wood, foods with cocoa/coffee/palm

• EUDR applies in 2025/26. You will need geolocation and no-deforestation proofs back to sourcing plot/plantation; coordinate with suppliers and consider satellite-verified traceability. (EU Trade)

7.4 Leather & footwear

• Focus on chemicals compliance, traceability to abattoir/farm where possible (some buyers apply EUDR-like asks to leather). Prepare origin planning for EU GSP+ and UK DCTS Enhanced.

7.5 Pharma & medical

• Main changes are quality and IP (not tariffs), but CSDDD will pull in ethical supply chain documentation; some EU buyers bundle scope 3 requests—prepare LCA basics.

8) Logistics, digital and the WTO horizon

• WTO e-commerce moratorium runs until MC14 / 31 Mar 2026. If it expires, your software, design files, and digital services could face tariffs in some markets—price those contingencies. (Reuters)
• Customs digitization under NBR’s strategic plan should reduce dwell times, with more risk-based controls and electronic data. Keep your data quality high; bad data triggers inspections. (National Board of Revenue)

9) Finance and risk: how banks will underwrite your 2025 trade

Banks in 2025 look for clean AML/KYC + sanctions screening, document perfection, and evidence that your shipments won’t be stuck at EU/UK customs for CBAM/EUDR reasons.

What lenders want to see:

• REX/Origin file for each SKU/HS code.
• CBAM emissions pack (process data, electricity, third-party verification plan).
• EUDR due-diligence trail for exposed commodities.
• CSDDD-style code & grievance process with supplier coverage.
• Collections discipline vs. 120-day timeline. (BB)

10) A 2025–2029 compliance calendar (pin these dates)

• Now (2025): Export Policy 2024–27 live; Customs Act modernization; UK DCTS rules-of-origin improvements active. (Energy and Power Division, The Business Standard, GOV.UK)
• 30 Dec 2025: EUDR applies to large/medium operators; SMEs from 30 Jun 2026. (EU Trade)
• 1 Jan 2026: CBAM definitive regime; EU importers start buying/surrendering certificates. (Taxation and Customs Union)
• By 26 Jul 2027: CSDDD transposed in EU Member States; phased application through 2027–2029. (European Commission)
• 24 Nov 2026: Bangladesh graduates from LDC. (United Nations)
• Until 2029: EU/UK duty-free transition for graduating LDCs. Prepare dossiers for GSP+ (EU) and DCTS Enhanced (UK). (RAPID Bangladesh)
• Until MC14 / 31 Mar 2026: WTO e-commerce moratorium in force. (Reuters)

11) Step-by-step playbooks you can run this quarter

A) Origin & preference survival plan

1. Map HS codes and identify where preferences matter (EU/UK priority).
2. Confirm REX status, templates and sign-offs; run a mock origin audit. (Taxation and Customs Union)
3. Build a BOM-to-origin calculator: simulate post-2029 GSP+ vs. Standard GSP duty hits and adjust sourcing accordingly.
4. UK: refresh to DCTS rules and cumulation options. (GOV.UK)

B) CBAM readiness (steel/aluminium/related)

1. Identify SKUs heading to the EU; map mills and processes.
2. Start collecting embedded emissions data (scope, meters, allocation).
3. Pick verification partners; add CBAM clauses splitting certificate costs and data duties. (Taxation and Customs Union)

C) EUDR traceability (rubber/wood/cocoa/coffee/palm/soy)

1. Flag products/packaging with EUDR commodities.
2. Build geolocation and no-deforestation attestations; choose GIS/satellite tools.
3. Draft supplier side letters with termination for substantiated risk; align with buyer portals. (EU Trade)

D) Contract tune-up

• Insert REX/CBAM/EUDR/CSDDD schedules;
• Tighten payment clocks for BB timelines; set interest and set-off;
• Integrate sanctions/dual-use warranties and KYC triggers. (BB)

E) Treasury discipline

• Dashboard D-120 exposure; weekly review with sales.
• Use LC confirmations for risky buyers; consider credit insurance where pricing allows.
• Escalate overdue receivables before exchange-rate penalties bite. (The Financial Express)

12) FAQs we get from exporters (and straight answers)

Q: We sell FOB. Why should we care about CBAM or EUDR?
Because buyers will. You’ll be asked for emissions numbers (CBAM) and deforestation proofs (EUDR). Non-cooperative vendors will be replaced—even if the legal obligation sits with the importer. (Taxation and Customs Union, EU Trade)

Q: Does the EU really keep Bangladesh duty-free after graduation?
Yes—three more years of EBA-level access (i.e., to 2029), then GSP/GSP+. But you must prepare now for post-2029. (RAPID Bangladesh)

Q: Is U.S. GSP coming back?
As of 2025, GSP remains lapsed; even if revived, apparel is historically excluded. Plan your U.S. landed-costs without GSP. (U.S. Customs and Border Protection, shenglufashion.com)

Q: How strict is Bangladesh Bank on the 120-day rule?
Very. Circulars in 2023–2024 tightened late-realization treatment; plan contracts, LCs and credit control to cash in time. (BB, The Financial Express)

Q: What if WTO ends the e-commerce moratorium in 2026?
Some countries may add duties on digital transmissions—factor potential SaaS/file transfer costs into your budgets and pricing. (Reuters)

13) Common failure points we fix for clients

• Origin statements gone wrong: Missing REX number, wrong wording, or supplier declarations not aligned with tolerances. Customs then re-rates at MFN duty. We implement templated packs and internal audits. (Taxation and Customs Union)
• Contracts that ignore compliance costs: No clause for CBAM certificate pass-through or EUDR traceability → margins evaporate. We add indexed price adjustments and data-sharing terms. (Taxation and Customs Union, EU Trade)
• FX surprises: Sales teams grant 150–180-day terms without telling finance; BB due-date FX rule bites. We hard-gate payment terms and LC conditions. (BB)

14) The TRW advantage: cross-border, cross-discipline

We’re not just policy wonks. TRW lawyers, trade economists and sustainability engineers work together:

• Market access & origin: REX onboarding, origin calculators, supplier declarations, UK DCTS mapping. (Taxation and Customs Union, GOV.UK)
• Carbon & sustainability: CBAM data architecture, verifier onboarding, EUDR traceability blueprints, CSDDD supplier governance. (Taxation and Customs Union, EU Trade, European Commission)
• Contracts & finance: New templates with CBAM/EUDR/CSDDD schedules, sanctions clauses, LC/FX structures meeting Bangladesh Bank rules. (BB)
• Government & strategy: Advising on post-graduation EU/UK pathways, sector diplomacy, and trade-facilitation projects. (RAPID Bangladesh)

15) A one-page 2025–2029 action plan (copy/paste into your PM tool)

Quarter 1 (now):

• Confirm REX registration; run an origin audit.
• Map EU/UK shipments against CBAM and EUDR exposure; start data capture.
• Amend Ts\&Cs (origin/CBAM/EUDR/CSDDD); calibrate payment terms to BB timelines. (Taxation and Customs Union, EU Trade, BB)

Quarter 2:

• Pilot CBAM verification with a test SKU; stand up EUDR geolocation for at-risk items.
• Train suppliers on DCTS rules; lock supplier declarations cadence. (GOV.UK)

Quarter 3–4:

• Negotiate CBAM pass-through and due-diligence cooperation in all EU contracts.
• Build dashboard for D-120 receivables; escalate at D-90. (BB)

2026:

• CBAM certificates start; tighten emissions reporting.
• WTO e-commerce moratorium outcome: adjust digital cost model if needed. (Taxation and Customs Union, Reuters)

2027–2029:

• Track CSDDD national rules; align grievance and remediation systems.
• Finalize EU GSP+ application strategy; ensure convention compliance evidence. (European Commission)

16) Closing thought

Trade in 2025 is less about finding buyers and more about earning market permission—with origin math, emissions math, and ethics math all rolled into your price. The winners are teams that treat compliance as an operating system, not a paperwork chore.

TRW is uniquely positioned as Bangladesh’s largest cross-border firm to build that operating system with you—from factory gates to foreign customs, from bank counters to boardrooms.

Sources & key references

• Bangladesh: Export Policy 2024–27 (EPB); Customs Bill 2023; NBR Customs Strategic Plan 2024–28; Tariff 2024–25; Bangladesh Bank circulars on export-proceeds and EXP. (Energy and Power Division, The Business Standard, National Board of Revenue, Bangladesh Customs, BB)
• LDC graduation: UN LDC Portal (graduation 24 Nov 2026) and multiple policy briefs confirming EU/UK 3-year transition to 2029. (United Nations, RAPID Bangladesh)
• EU: CBAM (definitive 2026); EUDR (large/medium 30 Dec 2025, SMEs 30 Jun 2026); CSDDD transposition by 26 Jul 2027, phased application to 2029. (Taxation and Customs Union, EU Trade, European Commission)
• UK: DCTS overview and July/Aug 2025 rules-of-origin improvements; LDC graduation 3-year transition and Enhanced Preferences thereafter. (GOV.UK, RAPID Bangladesh)
• U.S.: GSP lapsed since 2020; textiles historically excluded. (U.S. Customs and Border Protection, shenglufashion.com)
• WTO: E-commerce moratorium extended to MC14/31 Mar 2026. (Reuters)

Talk to TRW’s International Trade & Regulatory Team
Phones: +8801708000660 • +8801847220062 • +8801708080817
Emails: info@trfirm.com • info@trwbd.com • info@tahmidur.com
Offices: Dhaka — House 410, Road 29, Mohakhali DOHS • Dubai — Rolex Building, L-12 Sheikh Zayed Road.