Bangladesh has seen a rise in imports under the category covering lead chromate, while gaps in trade monitoring and regulation are making it difficult to determine the actual volume of the toxic chemical entering the country.
A lack of a separate Harmonised System (HS) code for lead chromate has complicated its identification at customs, raising concerns over the monitoring and control of imports of the substance, which poses significant risks to public health and the environment.
Against this backdrop, the Environment and Social Development Organization (ESDO) has called for stronger import monitoring, market surveillance, product identification and enforcement measures to control the trade of lead chromate in Bangladesh.
The call was made at a roundtable discussion held at the Department of Environment (DoE) in Dhaka on Tuesday, organised by ESDO in collaboration with the DoE and the International Pollutants Elimination Network (IPEN), marking International Lead Poisoning Prevention Week (ILPPW) 2026.
The discussion was held under the theme “From Detection to Prevention”.
At the event, Dr Foijun Nahar, policy and advocacy associate at ESDO, presented a report titled “Report on Trade of Lead Chromates: Bangladesh”, prepared in collaboration with IPEN.
According to the report, there is no evidence of domestic production of lead chromate in Bangladesh. The chemical pigment used in paints and other products is therefore believed to enter the country through imports.
However, Bangladesh does not have a separate HS code for lead chromate. It is traded under HS code 320620, which covers pigments and preparations based on chromium compounds, including lead-free pigments. As a result, trade statistics cannot establish the exact volume of lead chromate imported into the country.
Data from UN Comtrade show that Bangladesh's imports under HS code 320620 increased by 51.1% between 2022 and 2025. Imports rose from 427,481kg, worth $1.69 million, in 2022 to approximately 645,800kg, valued at $2.29 million, in 2025.
The report also found that India accounted for 89.9% to 93% of Bangladesh's imports under this category by weight each year between 2022 and 2025. China was the second-largest supplier, accounting for 5.7% to 9%, while imports from South Korea and other countries were comparatively low.
The study identified the paint industry as the likely primary user of imported lead chromate. No significant domestic producers involved in colouring plastics were identified. Smaller paint manufacturers generally purchase pigments through chemical traders, making it difficult to trace the supply chain and determine the extent of lead chromate use.
The report noted that Bangladesh has taken some regulatory measures to control lead content in decorative paints through the Bangladesh Standards and Testing Institution (BSTI).
Under standards BDS 1423:2018, BDS 1827:2018 and BDS 1833:2018, the maximum permissible limit for total lead in decorative paints has been set at 90 parts per million (ppm). BSTI has also drafted a similar standard setting the same limit for industrial paints, which is awaiting gazette notification.
Lead chromate is not yet listed under the Prior Informed Consent (PIC) procedure of the Rotterdam Convention, although plans are underway for its listing. Ratification of the convention would allow Bangladesh to use the PIC procedure to regulate imports of lead chromate.
The report recommended introducing a separate customs classification for lead chromate, improving product identification capacity, strengthening import and market surveillance, and enhancing coordination among relevant government agencies.
Speaking as the chief guest, Dr Md Lutfor Rahman, director general of the Department of Environment (DoE), said: “The lead poisoning situation is deepening every day, and we must face it head-on. Student-led research must be incentivised through government funding. We must also remember that lead is chemically associated with multiple other toxic elements, hence becoming a multidimensional problem.”
Special guest Dr Md Saidur Rahman, additional secretary of the Ministry of Environment, Forest and Climate Change (MoEFCC), said: “We need a detailed economic analysis of the industry related to lead chromate. If we want to protect our economic interests, a research-driven approach to our current situation will reduce the possible loss and damage that may occur as we shift towards lead-free products. Problem identification must be technological, as should the solutions.”
Guest of Honour Mohammed Solaiman Haider, additional director general (CC) of the Department of Environment, said: “We must first understand the extent of the crisis and the associated health hazards. In our country, the open market is mostly unregulated, and that is why it is important to bring the market under government radar, which itself is a huge challenge.”
Professor Dr Nasrin Sultana, director of the National Institute of Preventive and Social Medicine (NIPSOM), said: “The entire system must be brought under market surveillance and subjected to detailed monitoring. We must pay particular attention to how women and children are exposed to these harmful substances, not only through the food chain, but also through ingestion, inhalation and dermal contact.”
Dr Md Shahriar Hossain, founder and secretary general of ESDO, said: “There is no safe or permissible level of lead exposure. We must explore measures such as green taxation to encourage industries to move towards safer alternatives. Our 2025 study revealed an encouraging finding: 90% of paint manufacturers were already compliant with the lead limit. This demonstrates that compliance is achievable, and the remaining 10% can make the transition too.”
ESDO Executive Director Siddika Sultana said: “Bangladesh already has a National Strategy and Multi-year Action Plan for a Lead-Free Bangladesh. What we need now is effective implementation. Lead chromate is just one of the sources of lead exposure, and addressing it must be part of a broader, comprehensive effort to eliminate lead pollution.”
Dr Abdullah Al Mamun, deputy director (Waste and Chemicals Management) at the Department of Environment, said extended producer responsibility (EPR) needs to be made mandatory to ensure a better accountability mechanism.
He also stressed the need for further assessment of the volume of lead chromate imported into Bangladesh and improvements in testing facilities at universities to strengthen research and understanding of the issue.
Dr Md Mohammad Mostafizur Rahman of Jahangirnagar University said: “We cannot hide the risk that lead poses to public health. There is no, and has never been, any biological necessity that would justify the addition of lead to various products.”
Dr ASM Obaidullah Mahmud, chief R&D officer (R&D, QA, Process Engineering) at Berger Paints Bangladesh Ltd, said: “Bangladesh is moving towards a lead-free paint industry, and strengthening research and development (R&D) will help facilitate a smoother and more effective transition.”
Concluding the discussion, Razinara Begum, director (Waste and Chemicals Management) at the Department of Environment and moderator of the roundtable, said: “Chemical rules are being drafted; here, lead needs a spotlight. The ratification process for the Rotterdam Convention is ongoing; therefore, its clauses will become legally binding for us. Lead-acid battery rules are also being formalised, and the Ministry of Agriculture is working with highly hazardous pesticides. But first, we need to ensure the occupational health and safety of lead-exposed workers who work without protective gear. Awareness campaigns need to target at-risk workers.”
Through the roundtable, ESDO and its partners aim to strengthen controls on lead chromate trade in Bangladesh by improving customs classification, product identification, import monitoring, market surveillance and enforcement.
The initiative is also expected to strengthen coordination among the Department of Environment, BSTI, the National Board of Revenue (NBR), Bangladesh Customs and other relevant authorities, while encouraging the adoption of safer alternatives to lead chromate.