Fee Breakdown: Recipe Approval Stage vs Final Registration Stage

1. Key takeaways

Government fees in Bangladesh are paid at two separate points in the process. The first payment, BDT 5,000 plus 15% VAT, a total of 5,750, is made when the recipe approval application is filed. The second, BDT 50,000 plus 15% VAT, a total of 57,500, is made when the registration application is filed after the recipe approval letter has been issued. The two together come to BDT 63,250, and the final stage is ten times the recipe stage. The official schedule contains only these two items, and there is no line for a BDT 500 pay order.

• Payment one is 5,750 and payment two is 57,500; neither can be deferred to the other stage.
• The split is approximately 9% at the recipe stage and 91% at the registration and inspection stage.
• The interval between the two filings is 3 to 4 months, which is a practical estimate rather than a published period.
• If an application is returned, the government fee is normally not refunded, and a resubmission requires a second payment.
• VAT is calculated on each base fee separately, so the two payments never share one tax base.
• The second payment is triggered by the recipe approval letter, which makes that letter a financial milestone as well as a regulatory one.

2. Legal basis

The schedule is structured by stage rather than by total, which is why the fee has to be read as two entries instead of one. Each stage has its own base amount, its own VAT line and its own payment point. The table below sets out the sequence and the amount payable at each step.

The sequencing has a documentary consequence that is easy to miss. The first payment buys an assessment of the recipe, not an assessment of the product as a whole, and the second payment buys the registration and inspection work. A manufacturer that treats the first payment as a deposit against the second will misread both the cash flow and the review depth. The schedule treats them as two transactions because they are two decisions, taken at two different moments, on two different questions.

3. Expert insights

Insight one: the two steps are in a ratio of one to ten, not an even split. The recipe stage accounts for 9% of the total at 5,750, and the registration and inspection stage accounts for 91% at 57,500. That ratio runs in the opposite direction to the depth of review, because the first step examines the requirements and the second examines the substance. For financial planning the implication is that the main funding pressure arrives late in the project, and early-stage cash flow pressure is systematically underestimated. A budget approved on the assumption of an even split will be short at exactly the point where the file cannot proceed without payment.

Insight two: each payment carries its own VAT, and the tax base cannot be merged. The schedule reads as BDT 5,000 per product plus 15% VAT on that fee, and BDT 50,000 per product plus 15% VAT on that fee, with each payment made on its own TR Challan; the registration and inspection payment uses code ১-২৭১৫-০০০০-১৮৬৩. Two errors recur in Chinese-language quotations. The first is to omit VAT altogether. The second is to add the two base fees together and apply 15% once, which produces the same percentage but the wrong instrument, since the two payments are separate transactions with separate challans. Either error surfaces as a top-up demand at the counter.

Insight three: the 3 to 4 months between the steps is both a funding opportunity and a funding risk. The opportunity is that the full amount does not have to be committed at once, so a manufacturer can stage its outlay across a quarter. The risk is that if the first filing is returned, the government fee is normally not refunded, and the second submission requires a fresh payment. That combination is the financial reason for a rigorous completeness check before the first filing: one return costs double the fee plus a quarter. The fee is not the largest cost in that scenario; the lost quarter usually is.

Insight four: the recipe approval letter is a payment trigger, so its date belongs in the project plan. Because the second payment falls due when the registration is filed after the recipe approval letter, the date of that letter sets the date of the largest cash outflow in the project. A plan that tracks the letter only as a regulatory milestone will be surprised by the invoice that follows it. Treating the letter as a joint regulatory and financial event allows the treasury calendar and the submission calendar to be built from the same date.

4. Practical recommendations

GRZAN ties fee payment to process milestones in a single schedule: the first payment date is the filing date, and the final payment date is within five working days of the recipe approval letter being issued. We also ask clients to hold a budget for a second payment in the event of a return. The reason is not that returns are likely; it is that when one happens, a client without a reserve tends to lose another quarter before resubmitting, which turns three months into six.

• Provision the first payment at BDT 5,000 plus 15% VAT, and record the 5,750 total rather than the base fee.
• Provision the final payment at BDT 50,000 plus 15% VAT, and place it in the quarter in which the recipe approval letter is expected.
• Compute VAT twice, once for each payment, and keep the two challans as separate documents in the finance file.
• Bind each payment date to a filing or approval milestone rather than to a calendar month.
• Hold a reserve equal to the final payment, so that a return does not force a delay while funds are approved.
• Plan the cash flow around a 3 to 4 month interval between the two filings, and treat any shorter interval as an upside rather than as the base case.

5. Verification checklist

• □ The first payment is provisioned at BDT 5,000 plus 15% VAT (5,750)
• □ The final payment is provisioned at BDT 50,000 plus 15% VAT (57,500)
• □ The two VAT amounts are calculated separately, with no consolidated tax base
• □ Each payment date is bound to a filing or approval milestone
• □ A reserve for a second payment on return has been provided
• □ The cash flow plan reflects the 3 to 4 month interval between the two steps

Regulatory information verified as of 6 November 2026, against the original DGDA fee schedule.

How GRZAN can help. GRZAN provides medical device and IVD registration, quality system, authorised representative and local testing support across South Asia, including Bangladesh. Our team prepares dossiers to DGDA expectations, manages submissions and deficiency responses, and supports post-market vigilance obligations. Business enquiries: info@grzanglobal.com