How zone factories pay for what they buy: the three ownership types, when no IMP form is needed, the Taka route for DPA enterprises in economic zones, whose money may pay for zone imports, and the special route for capital machinery.
In Lesson 28, Inland LCs in foreign currency: making local trade easier, we watched local buyers and sellers trade in dollars without leaving Bangladesh. Now we walk through a different gate: the gate of a specialized zone.
On a rainy Tuesday, Sabrina comes into Sadia's branch with an umbrella in one hand and a fat file in the other. She is the finance head of a shoe factory inside an export processing zone in Chattogram. The factory imports leather, soles and glue, and it exports finished shoes. "We have a big new export order," she says, "and I need an import LC for the inputs. Also, we want a new stitching machine. Can the bank lend us the dollars?"
Rakib, the new officer on Sadia's team, reaches for the usual LC checklist. Sadia stops him gently. "Wait. A zone factory is not an ordinary importer. The money rules are different."
Luckily, today's training guest is Shely, a retired Commissioner of Customs. She has watched zone gates open and close for years. "Inside the fence, the first question is always the same," Shely says. "Who owns the factory? Then: where is the money coming from?"
If you read the export room's Part B (Export Lessons 10 and 11), you already know the zones and the three types of factory from the seller's side. This lesson looks at the same zones from the buyer's side: paragraphs L-1 to L-3 of Part L.
L-1 sets the scene. Import trade in the specialized zones (EPZ, PEPZ, EZ and HTP) is guided by the regulations of each zone. So a zone factory has its own rule book, and the foreign exchange rules in Part L work alongside it.
The factories inside come in three types, based on who owns them:
Type A: 100% foreign owned. This includes factories owned by Bangladeshi nationals who ordinarily live abroad.
Type B: a joint venture between foreign entrepreneurs and Bangladeshi entrepreneurs who live in Bangladesh.
Type C: 100% owned by Bangladeshi entrepreneurs who live in Bangladesh.
Why should an import desk care about ownership? Because, as you will see in L-3, the type decides which money may pay for some imports. A Type C factory gets a route for capital machinery that a Type A factory does not. So the first question on any zone file is simple: "Which type are you?"
These are the same three types you met in Export Lesson 10, Zones and who's who. Same factories, same labels; only now they are buying instead of selling.
At the desk
Rakib opens Sabrina's file and finds the ownership papers: a foreign shoe company holds part of the shares, and a Chattogram family living in Bangladesh holds the rest. "Two kinds of owners in one company," Shely says. "That is a joint venture, so this is a Type B factory." Rakib writes "Type B" in big letters on the cover of the file.
Key words
Specialized zones
Areas set up by law for industry and export: EPZs, private EPZs, economic zones and hi-tech parks.
Type A enterprise
A zone factory that is 100% foreign owned, including one owned by Bangladeshis who normally live abroad.
Type B enterprise
A zone factory owned jointly by foreign owners and Bangladeshi owners living in Bangladesh.
Type C enterprise
A zone factory 100% owned by Bangladeshis living in Bangladesh.
Read the rule as written (Para L-1)
Operations of import trade in specialized zones (EPZ/PEPZ/EZ/HTP) are guided by respective regulations. The following types of industrial enterprises operate in specialized zones:
(a) Type A: 100 percent foreign owned including those owned by Bangladeshi nationals ordinarily resident abroad;
(b) Type B: Joint venture projects between foreign and Bangladesh entrepreneurs resident in Bangladesh;
(c) Type C: 100 percent Bangladeshi entrepreneurs resident in Bangladesh.
Source: Bangladesh Bank, FEPD-1 Circular No. 30, 13 August 2026, Part L, paragraph 1 (page 34). The original circular is the authority.
Imports by enterprises operating in specialized zones
In plain words
L-2 has two parts. Both are about when the usual import paperwork falls away.
(1) No IMP form for some zone purchases. The IMP form procedure does not apply to:
intra-zone transactions (one factory buying from another factory in the same zone);
inter-zone transactions (buying from a factory in another zone); and
imports from Bangladesh, meaning from the non-zone area.
Does that mean nobody reports them? No. These transactions are reported in the relevant monthly schedules, quoting the EXP forms issued at the export leg. Think of it as one deal with one form: the seller's EXP form does the job, and the buyer's bank points to it. You saw the seller's side of this in Export Lesson 11.
(2) The Taka route for DPA enterprises in economic zones. The National Board of Revenue (NBR), by its order no. 288/2017/Customs/529 dated December 21, 2017, amended the Customs (Economic Zones) Procedures, 2017. The amendment waives EXP/IMP formalities for transactions between enterprises in the Domestic Processing Area (DPA) of EZs and the Tariff Area (TA) of Bangladesh. As a result:
DPA enterprises in EZs, whatever their ownership status (Type A, B or C), may settle their liabilities for imports and other permissible expenses from the money in their Taka accounts;
so the restriction on using an AD's own fund for import settlement, which the circular places in "paragraph 3(a) of this part", does not apply to EZ enterprises operating in the DPA. In this lesson, the "no AD's own foreign exchange" rule appears in L-3(1).
Note the limits: this Taka route is for DPA enterprises in EZs. L-2(2) doesn't extend it to EPZs, PEPZs or HTPs.
At the desk
Sabrina's factory buys shoelaces from another factory in the same EPZ, paying in dollars. Rakib starts filling in an IMP form. Sadia shakes her head: "Intra-zone deal. No IMP form. We report it in the monthly schedule and quote the seller's EXP form number." Later, a different customer, an enterprise in the DPA of an economic zone, asks to pay a supplier's import bill from its Taka account; Sadia confirms that L-2(2) allows this, whatever the owner type.
Key words
Inter-zone transaction
A deal between an enterprise in one specialized zone and an enterprise in another zone.
NBR
National Board of Revenue: the government body in charge of taxes and Customs.
Domestic Processing Area (DPA)
The part of an economic zone named in B-5 whose enterprises may sell to the Tariff Area in Taka without EXP/IMP formalities.
Tariff Area (TA)
The ordinary part of Bangladesh outside the zones, where the usual customs rules apply.
Read the rule as written (Para L-2)
(1) IMP Form procedures will not be applicable for intra/inter zones transactions and import from Bangladesh (Non-zone area). These transactions are to be reported in relevant monthly schedules with reference to EXP forms issued at export-leg.
(2) National Board of Revenue (NBR) vide its order no. 288/2017/Customs/529 dated December 21, 2017 effects relevant amendment in the Customs (Economic Zones) Procedures, 2017 to waive export/import formalities (EXP/IMP) for transactions between enterprises operating in Domestic Processing Area (DPA) of EZs and in Tariff Area (TA) of Bangladesh. Accordingly, transactions by DPA enterprises in EZs irrespective of their ownership status are allowed to settle their liabilities for imports and other permissible expenses out of the fund held in their Taka accounts. Hence, the restrictions to use AD’s own fund for import settlement as mentioned in paragraph 3(a) of this part will not be applicable for EZ enterprises operation in DPA.
Source: Bangladesh Bank, FEPD-1 Circular No. 30, 13 August 2026, Part L, paragraph 2 (page 34). The original circular is the authority.
L-3 answers Sabrina's big question: whose money pays for a zone factory's imports?
(1) The main rule for Type A, B and C enterprises. When an AD opens import LCs for zone enterprises, it must keep this in mind:
import payments may be made only from
– the foreign exchange earnings of the unit concerned, or
– its borrowings abroad credited in its FC accounts;
no money from the AD's own foreign exchange resources may be used for this.
In short, the zone factory pays from its own dollars, not the bank's. (Remember L-2(2): DPA enterprises in EZs are outside this restriction.)
There is also a duty of care. Before opening an inputs import LC against an export LC or export order received by a zone enterprise, the AD should satisfy itself completely about three things:
the clarity of the conditions in the export order or LC;
the standing and credit of the foreign buyers; and
the enterprise's ability to execute the export order on time.
Why? Because the inputs are paid for out of the export money. If the export fails, the import bill still waits.
(2) Capital machinery: a special route for Type C and Type B.
Type C enterprises shall be allowed to obtain foreign exchange from ADs to pay for imported capital machinery, by converting an equal amount of their equity and/or authorised loan received in local currency.
Type B enterprises may be allowed to convert their local equity or authorised loan received in local currency into foreign exchange for capital machinery, but only if the equity or authorised foreign loan received from abroad falls short of the obligation.
L-3(2) names only Type C and Type B. It doesn't give Type A this route, and it doesn't say here who authorises the loan.
At the desk
Sabrina's Type B factory wants a USD 200,000 stitching machine. Its foreign partner has sent USD 150,000 of equity from abroad. Sadia explains that the factory may ask to convert local equity received in Taka into foreign exchange to cover the USD 50,000 shortfall. For the leather LC, Rakib first checks that the export order's conditions are clear, the foreign buyer has a good standing, and the factory can ship on time; the leather will be paid from the factory's export earnings, not the bank's own dollars.
Key words
Foreign currency account
A bank account held in a foreign currency, such as US dollars, rather than Taka.
Capital machinery
Machines and equipment a factory uses to make its products, as opposed to the raw materials that go into them.
Equity
Money the owners put into a business in return for a share of its ownership.
Export order
A buyer's order to an exporter for goods, which may come with or without an export LC.
Read the rule as written (Para L-3)
(1) In establishing import LCs on account of Type A, B and C enterprises in specialized zones, ADs shall bear in mind the position that the import payments may be made only out of the foreign exchange earnings of the concerned units or out of their borrowings abroad credited in their FC accounts, and that no funds from AD's own foreign exchange resources can be used for this purpose. Before opening inputs import LC against an export LC or export order received by zone enterprises, ADs should satisfy themselves completely about the clarity of the conditions in the export orders/LCs, the standing and credit of foreign buyers and the ability of the enterprises for timely execution of export orders.
(2) Type C enterprises shall be allowed to obtain foreign exchange from ADs to settle obligations for importing capital machinery by the conversion of equivalent amount of equity and/or authorized loan received in local currency. Similarly, Type B enterprises may be allowed to convert their local equity/authorized loan received in local currency into foreign exchange to settle obligations for importing capital machinery if equity/authorized foreign loan received from abroad falls short to meet such obligations.
Source: Bangladesh Bank, FEPD-1 Circular No. 30, 13 August 2026, Part L, paragraph 3 (page 34). The original circular is the authority.
So far: import trade in the specialized zones follows each zone's own regulations, and zone factories are Type A, B or C depending on who owns them. Intra-zone, inter-zone and non-zone purchases need no IMP form and are reported in monthly schedules quoting the export-leg EXP forms, while DPA enterprises in EZs may pay imports and other permissible expenses from their Taka accounts. Otherwise, zone imports are paid only from the unit's own foreign exchange earnings or borrowings abroad in its FC accounts, never from the AD's own foreign exchange, except that Type C (and, when foreign money falls short, Type B) enterprises may convert local equity or authorised loan into foreign exchange for capital machinery.
Next: Lesson 30, Zone imports and export money: matching and retention.
Check yourself
30 questions, in 3 sets of up to 10. Nobody sees your answers but you.
Set 1 of 3
L-1 says import trade in specialized zones is guided by the respective regulations. (L-1)
L-1 names EPZ, PEPZ, EZ and HTP. (L-1)
L-1(c): Type C enterprises are 100% owned by Bangladeshi entrepreneurs resident in Bangladesh. (L-1)
L-1(b): Type B is a joint venture between foreign and Bangladesh entrepreneurs resident in Bangladesh. (L-1)
True. L-1(a) includes enterprises owned by Bangladeshi nationals ordinarily resident abroad in Type A. (L-1)
L-1 sorts zone enterprises by ownership and where the owners live. (L-1)
L-1(b): a joint venture between foreign and resident Bangladeshi entrepreneurs is Type B. (L-1)
L-2(1) says IMP Form procedures do not apply to intra/inter-zone transactions and imports from Bangladesh (non-zone area). (L-2)
L-2(1): they are reported in relevant monthly schedules with reference to the export-leg EXP forms. (L-2)
L-2(2) cites NBR order no. 288/2017/Customs/529 dated December 21, 2017. (L-2)
Set 2 of 3
L-2(2): the order amended the Customs (Economic Zones) Procedures, 2017. (L-2)
L-2(2) allows DPA enterprises to settle these liabilities from funds in their Taka accounts. (L-2)
L-2(2): the waiver covers transactions between DPA enterprises of EZs and the Tariff Area. (L-2)
False. L-2(2) says DPA enterprises may use it irrespective of their ownership status. (L-2)
True. L-2(2) says that restriction is not applicable for EZ enterprises operating in the DPA. (L-2)
L-2(1): intra-zone transactions need no IMP form and are reported in monthly schedules with reference to the export-leg EXP forms. (L-2)
L-2(1): imports from Bangladesh (non-zone area) need no IMP form and are reported in monthly schedules quoting the export-leg EXP forms. (L-2)
L-2(2) lets DPA enterprises in EZs, irrespective of ownership, settle import liabilities from their Taka accounts. (L-2)
L-3(1): payments may be made only out of the unit's foreign exchange earnings or borrowings abroad credited in FC accounts. (L-3)
False. L-3(1) says no funds from the AD's own foreign exchange resources can be used for this purpose. (L-3)
Set 3 of 3
L-3(1) lists clarity of conditions, the buyers' standing and credit, and the enterprise's ability to execute on time. (L-3)
L-3(1) asks the AD to be satisfied about the standing and credit of foreign buyers. (L-3)
L-3(2) allows Type C enterprises to convert equivalent local-currency equity and/or authorised loan. (L-3)
L-3(2): Type B may convert if equity/authorised foreign loan from abroad falls short. (L-3)
False. L-3(2) names only Type C and Type B enterprises. (L-3)
L-3(1) bars the AD's own foreign exchange resources for these import payments. (L-3)
L-3(1) says the AD should satisfy itself completely about the clarity of the conditions in the export order or LC. (L-3)
L-3(2): Type C enterprises shall be allowed to obtain foreign exchange by converting equivalent local-currency equity and/or authorised loan. (L-3)
L-3(2): Type B may convert local equity/authorised loan when equity/authorised foreign loan from abroad falls short. (L-3)
L-3(1) includes the enterprise's ability for timely execution of export orders among the AD's checks. (L-3)
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