Bangladesh's debate over container dwell time usually begins after cargo reaches Chattogram Port. Customs assessment, physical examination, importer delays, port congestion and delivery procedures are repeatedly identified as causes. All matter. But the clearance clock starts much earlier.
Recent ASYCUDA data indicate an average interval of around 7.4 days between manifest and submission of the Bill of Entry (B/E)-more than half of a reported 13.2-day manifest-to-delivery cycle. It would be convenient to classify this entire interval as importer or C&F-agent delay. Supply chains, however, rarely work so simply.
Every downstream transaction depends upon an upstream event. A delay embedded in one procedure can propagate through the entire clearance chain.
IMPORT GENERAL MANIFEST (IGM): Bangladesh already allows advance submission of the IGM. The problem is therefore not the absence of advance filing, but whether the process gives shipping agents sufficient incentive to use it as early as possible.
Customs has already established a detailed electronic framework for cargo declaration, including voyage, bill of lading, consignee, cargo, container and weight information. The remaining question is what happens when information submitted electronically subsequently needs legitimate correction.
Shipping agents receive cargo information progressively from overseas principals, NVOCCs and freight forwarders. Industry users report that once Customs registers the manifest against a particular voyage, subsequent amendments become considerably more cumbersome. An agent needing to correct information may have to physically approach Customs, pursue a manual file and respond to explanations and queries.
The predictable response is caution. Shipping agents wait until information is as complete as possible before registration-not necessarily because they oppose advance filing, but because early registration exposes them to the risk of a difficult amendment later.
A trade-facilitation provision can, therefore, unintentionally discourage the behaviour it was intended to encourage.
MAKE EARLY FILING SAFER: Customs unquestionably needs manifest integrity for revenue protection, security and enforcement. But accuracy need not mean that every correction receives identical administrative treatment.
Bangladesh should consider a controlled electronic amendment window. Until a clearly defined cut-off-potentially before commencement of discharge-specified bona fide amendments could be made electronically, with every change timestamped and preserved in an audit trail. Material changes affecting cargo identity, description, quantity or enforcement risk could still require Customs approval.
Customs should also consider a transparent materiality framework for discrepancies.
A small difference in the recorded weight of a container should not automatically receive the same administrative treatment as a discrepancy large enough to suggest misdeclaration or affect revenue or enforcement risk. Appropriate tolerances should be determined scientifically according to commodity, shipment characteristics, historical data and risk-not individual discretion.
Such an approach would not weaken Customs control. It would make control more proportionate.
More importantly, it would change incentives. If legitimate corrections can be made electronically without falling back into a cumbersome manual process, shipping agents have far less reason to postpone advance IGM registration.
Earlier manifest availability enables earlier B/E submission. Earlier B/E submission enables earlier risk processing and assessment. Earlier assessment enables earlier payment and release.
A supply chain does not normally lose seven days at one counter. It loses minutes and hours through successive hand-offs, dependencies and waiting points until they accumulate into days.
THE REAL TEST IS HOW DIGITAL SYSTEMS HANDLE EXCEPTIONS: This reveals a broader weakness in Bangladesh's digitalisation journey. A straightforward transaction is relatively easy to digitalise. The real test of a digital system comes when information needs correction, clarification or amendment.
If detailed IGM information is captured electronically but a subsequent correction sends the shipping agent back to physical attendance and a manual file, the transaction may be digital, but the exception is not.If a B/E is submitted electronically but the C&F agent must physically pursue an Assessment Group to make it move, the workflow remains partly manual.
The same principle applies across the port ecosystem. Chattogram Port has invested in a modern Terminal Operating System (TOS), including functions relevant to a broader Port Community System environment. But where digital processes are not made the default, or users remain unfamiliar with available functions, electronic and paper workflows continue in parallel.
Bangladesh's problem is therefore not simply the absence of digital systems. It is that when a transaction becomes complicated, exceptional or discretionary, the process can fall back from digital to manual. Digital exception management should consequently become part of business process reengineering.
MEASURE EVERY EVENT, NOT MERELY TOTAL DWELL TIMEP: The WTO Trade Facilitation Agreement requires procedures allowing import documentation, including manifests, to be submitted before arrival so processing can begin earlier. It also encourages countries to measure and publish average release times using instruments such as the World Customs Organization's Time Release Study.
The WCO's updated 2025 methodology goes further by emphasising business-process mapping, segmentation and structured analysis of individual time intervals.
Bangladesh should apply that thinking throughout the cargo journey.
The digital trail should identify when advance manifest information becomes available, when the IGM is registered, when amendments occur, when the B/E becomes technically capable of submission, when it is actually submitted, when risk selection occurs, when assessment begins and ends, when queries are raised and answered, when duty is paid, when release is granted, when port formalities are completed and when the container physically exits.Some of these timestamps already exist within the electronic environment; the challenge is to connect them across the clearance chain and use them systematically to identify where waiting occurs.
Only then can Bangladesh answer a question that is frequently lost in institutional debate: who owns each hour of delay?
ARMS MUST CONTROL WHAT HAPPENS NEXT: Bangladesh Customs is already moving towards a more sophisticated risk-management architecture. NBR's Customs Strategic Plan 2024-2028 provides for strengthening risk management in ASYCUDA World, operationalising the Automated Risk Management System (ARMS) with the Bangladesh Single Window for integrated risk management involving other government agencies, and introducing centralised risk management. This is an important reform direction.
But as ARMS becomes operational across the clearance process, its real value will depend on whether system-generated risk actually determines what happens next.
A low-risk declaration should not subsequently wait in essentially the same workflow as a high-risk one. System-generated risk should determine intervention: expedited processing, documentary assessment, scanning or physical examination.
Otherwise, automated risk management risks becoming another digital layer over an unchanged manual process.
AFTER RISK SELECTION COMES THE QUEUE: There is another largely invisible interval: the time between electronic submission and an officer actually acting on a declaration. Importers, C&F agents, freight forwarders and shipping interests frequently describe physical follow-up with Customs Assessment Groups as part of the clearance process. This raises a basic workflow question: why should a declaration submitted electronically require someone to pursue it physically?
Once a B/E requiring assessment enters ASYCUDA, it should automatically join an electronic queue. The system could allocate declarations according to risk, commodity expertise and workload, using transparent first-in-first-out principles where appropriate. Assignment, first action, queries and final assessment should all carry timestamps and service standards.
This is where Faceless Assessment becomes relevant-not as a complete solution to dwell time, but as one component of a larger architecture.
India has developed a nationwide faceless-assessment structure alongside risk-based processing, separating many assessment decisions from the physical location where cargo arrives. Pakistan introduced Faceless Customs Assessment in Karachi in December 2024, electronically allocating import declarations to a Central Appraising Unit.
The lesson is not that Bangladesh should mechanically copy either country. It is that advance information, risk management, electronic queuing and faceless allocation solve different stages of the same clearance problem.
CONNECTING THE WHOLE CLEARANCE CHAIN: Bangladesh now has many of the building blocks: ASYCUDA World, BSW, the emerging ARMS architecture and CPA's TOS. The challenge is to connect them around one continuous cargo journey.
Cargo information should reach Customs well before the vessel arrives, with legitimate corrections allowed electronically. Importers should then be able to submit their declarations earlier. The system should determine the level of risk and, where assessment is necessary, automatically assign the declaration to an appropriate officer without requiring physical follow-up. Once Customs requirements are completed, payment, release and port delivery should continue digitally until the container leaves the gate.
At every stage, the system should record when the transaction arrived, who was responsible for the next action and how long that action took. Policymakers could then see precisely where hours turn into days.
The 7.4 days before B/E submission should not automatically be attributed to the importer. Nor should every subsequent delay automatically be blamed on Customs, the port, shipping agents or C&F agents. The system itself should tell us where the cargo-or its information-is waiting.
Bangladesh does not necessarily need another software platform. It needs business process reengineering around the platforms it already has.
And perhaps the most important reform principle is also the simplest: make the digital route easier than the manual one.
Only then will shipping agents file earlier, traders stop pursuing electronic declarations physically, risk management determine intervention, and port users abandon parallel paper processes.
In logistics, every event matters. Every exception matters. And every hour of waiting eventually becomes part of the dwell time. The next phase of digitalisation must therefore connect not only our systems, but every decision between the ship and the port gate.
Ahamedul Karim Chowdhury is maritime, logistics and supply chain policy analyst. Former Head of ICD Kamalapur & Pangaon ICT.
