Research Ideas and Outcomes : Policy Brief
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Policy Brief
Brick kilns, air pollution and the governance failure behind pollution-driven loss of life expectancy
expand article infoMohammad Mahfuzur Rahman, James Ojiambo Were
‡ James Madison University, Harrisonburg, United States of America
Open Access

Abstract

This policy brief examines the contribution of brick kilns to Dhaka’s severe air-pollution crisis and argues that persistent emissions reflect failures of governance, enforcement and regulatory coordination rather than a lack of technological alternatives. Drawing on recent epidemiological studies, atmospheric modelling and policy evidence from Bangladesh and across Asia, the brief analyses how seasonal brick production intensifies winter PM2.5 concentrations and contributes to major public-health and economic losses. Although Bangladesh has enacted ambitious environmental legislation, weak institutional capacity, fragmented oversight and entrenched political-economic incentives continue to undermine implementation. The brief evaluates three policy pathways: universal Zigzag 2.0 kiln conversion, substitution towards non-fired construction materials and enforcement intensification through satellite-based monitoring. It recommends a phased five-year national strategy integrating cleaner kiln technology, demand-side reform, targeted enforcement and regional airshed cooperation. Effective implementation could substantially reduce pollution exposure, improve life expectancy and strengthen long-term environmental governance in Bangladesh.

Keywords

air pollution governance, PM2.5, Bangladesh environmental policy, brick kilns

Executive Summary

Dhaka faces one of the world’s most severe air-pollution crises, with brick kilns emerging as a major seasonal source of fine particulate matter (PM2.5). Bangladesh loses an estimated 159,000 lives annually to combined ambient and household air pollution, while residents of Dhaka could gain approximately 6.9 years of life expectancy if World Health Organisation air-quality guidelines were achieved (Lima et al. 2024, Energy Policy Institute at the University of Chicago, EPIC 2025). During the winter firing season, brick kilns contribute 30-50 percent of ambient PM2.5 in Greater Dhaka (Guttikunda et al. 2013, Sarwar et al. 2025). Despite existing regulations, weak enforcement, fragmented governance and political-economic incentives allow illegal kilns to continue operating. This brief argues that the problem is fundamentally institutional rather than technological. It recommends a phased five-year strategy combining Zigzag 2.0 kiln conversion, satellite-based monitoring, stronger enforcement and expanded support for non-fired construction materials to reduce emissions and improve public health outcomes.

Introduction and Background

Dhaka, with approximately 36.6 million residents in 2025 (United Nations Department of Economic and Social Affairs 2025), is consistently ranked amongst the world’s most polluted cities. Construction-driven growth has more than tripled brick demand since 2000. In 2024, Bangladesh recorded a national annual mean PM2.5 of 78.0 µg/m³, more than fifteen times the WHO guideline of 5 µg/m³ and the second-highest country-level reading globally after Chad (IQAir 2025). Brick production is a seasonal, largely informal industry employing approximately one million workers and producing roughly 23 billion bricks annually through Fixed Chimney Kiln and Zigzag designs that combust low-grade coal and biomass for five to six months each year (Brooks et al. 2025, Mongabay 2026). The Department of Environment estimates 7,000-8,500 kilns nationwide despite the Brick Manufacturing and Brick Kiln Establishment (Control) Act, 2013 and its 2019 amendment. Air pollution shortens the average Bangladeshi’s life by 5.5 years, exceeding the burden of tobacco, malnutrition and unsafe water combined (Energy Policy Institute at the University of Chicago, EPIC 2025) and approximately 30 percent of global lower respiratory infection deaths are attributable to air pollution (State of Global Air 2024). The interim government installed in August 2024 has signalled a stronger willingness to confront the brick sector, but enforcement remains fragmented across at least fifteen ministries and roughly 75 percent of kilns shut down in 2024 reportedly resumed operations within months (The Business Standard 2025, Prothom Alo 2025).

Problem Statement

Although brick kilns are not the largest annual source of Dhaka’s PM2.5, they are the most addressable industrial source. The 2024-2030 National Air Quality Management Plan attributes 13 percent of the GDA-originating share of population-weighted PM2.5 to brick kilns, with households (28 percent) and power plants (24 percent) contributing larger annual shares (Government of Bangladesh, Ministry of Environment, Forest and Climate Change 2024). During the November-March firing season, reduced winter dispersion lifts brick-kiln contributions to 30-50 percent of ambient PM2.5 (Guttikunda et al. 2013) and recent CMAQ-based modelling estimates monthly-mean PM2.5 contributions of 31-46 µg/m³ during winter, with a 50 percent reduction in kiln emissions projected to lower ambient PM2.5 by 14-20 µg/m³ (Sarwar et al. 2025). Table 1 below shows the Source Apportionment of Population-Weighted PM2.5 in the Greater Dhaka Area.

Table 1.

Source Apportionment of Population-Weighted PM2.5 in the Greater Dhaka Area.

Emission Source

Annual Share (%)

Pollution Profile

Household combustion (cooking, biomass)

28

Year-round; concentrated in poor areas

Power plants

24

Year-round; SO₂ and NOₓ dominant

Brick kilns

13

Seasonal: 30-50% of winter PM2.5

Road transport (incl. road dust and exhaust)

12

Year-round; near major roads

Open burning of waste

11

Year-round; localised hotspots

Other (industries, construction, transboundary)

12

Mixed; transboundary ≈ 18-21%

Note. Single-source figures from the National Air Quality Management Plan 2024–2030 (Government of Bangladesh, Ministry of Environment, Forest and Climate Change 2024); percentages reflect shares of GDA-originating PM2.5, which itself constitutes approximately 56 percent of total ambient PM2.5 in Greater Dhaka.

The health consequences are severe. The World Bank Country Environmental Analysis attributes 159,000 premature deaths annually to combined ambient and household air pollution in 2019, with economic losses of 8.32 percent of GDP, or USD 32 billion (Lima et al. 2024). Brooks et al. (2023) provide direct epidemiological evidence: PM2.5 concentrations are 72.3 µg/m³ (95% CI: 10.2, 134.3) higher two kilometres downwind of an active kiln and adults over 40 living downwind have approximately 2.2 times the odds of chronic obstructive pulmonary disease symptoms (95% CI: 1.2, 4.3). A systematic review of 104 studies confirms consistent adverse respiratory effects on workers and nearby communities (Nicolaou et al. 2024). Sherris et al. (2021) demonstrate that child pneumonia incidence rises when ambient PM2.5 contains a higher proportion of brick-kiln source markers. Lee et al. (2021) show that 77 percent of detected kilns operate illegally within one kilometre of a school; Department of Environment data indicate that only about 40 percent of officially registered kilns hold a valid Environmental Clearance Certificate (Mongabay 2026). Table 2 below shows the Estimated Life-Expectancy Loss from Particulate Pollution by district in Bangladesh.

Table 2.

Estimated Life-Expectancy Loss from Particulate Pollution by District.

District

Years of Life Lost (relative to WHO 5 µg/m³)

Gazipur

7.1

Dhaka

6.9

Narayanganj

6.6

Chattogram

6.2

Khulna

5-6

Sylhet

3.5

Note. Population-weighted estimates from the AQLI 2025 Annual Update Bangladesh Fact Sheet, derived from 2023 PM2.5 (Energy Policy Institute at the University of Chicago, EPIC 2025). All districts use the AQLI 2025 update; Khulna falls within the 5-6 year range AQLI reports for Cumilla, Tangail, Khulna and Mymensingh.

Current Policy Framework

Bangladesh’s regulatory architecture for brick manufacturing is amongst the most ambitious in South Asia on paper, but amongst the weakest in implementation. The Bangladesh Environment Conservation Act, 1995 and the Air Pollution (Control) Rules, 2022, establish national air-quality standards aligned with WHO Interim Target 1. The Brick Manufacturing and Brick Kiln Establishment (Control) Act, 2013, amended in 2019, banned new Fixed Chimney Kilns, prohibited siting within one kilometre of residential or agricultural areas, required environmental clearance and mandated a phased shift to non-fired materials in government works (Alam and Barman 2019). The National Air Quality Management Plan 2024-2030 sets a target reduction of 30 µg/m³ in the Greater Dhaka Area by 2030 (Government of Bangladesh, Ministry of Environment, Forest and Climate Change 2024).

Four institutional weaknesses repeatedly undermine outcomes. First, governance is fragmented across at least fifteen ministries and the Department of Environment’s Air Quality Wing operates with limited staffing, district coverage and demolition equipment (The Business Standard 2025). Second, enforcement is highly cyclical: mobile court drives between January and July 2025 took action against 699 brick kilns, demolishing 483 chimneys and issuing closure orders against 216 others, yet roughly 75 percent of kilns shut during the 2024 winter resumed operation within months (The Business Standard 2025, Prothom Alo 2025). Third, the political economy entrenches non-compliance: industry contributions to local Resource Funds give district administrations a fiscal stake in kiln continuity and bribery of inspectors has been documented (Prothom Alo 2025). Fourth, demand-side reform has stalled: the 2025 deadline for full government adoption of non-fired blocks was missed, with only the Ministry of Housing and Public Works in compliance; a 15 percent value-added tax disadvantages alternatives; and concrete-block manufacturing meets less than 10 percent of construction demand (Mongabay 2026).

Comparative Insights from Asia

Targeted technology and demand-side reform reduce brick-kiln emissions when paired with credible enforcement. India’s 2017 Central Pollution Control Board directive and the 2020 National Green Tribunal ruling made induced-draft Zigzag conversion mandatory across northern India, with over 1,000 kilns in Uttar Pradesh converted by 2020 (Down To Earth 2021). Nepal’s post-2015 Gorkha earthquake reconstruction period accelerated the transition from traditional brick kilns to cleaner Zigzag kiln technology, contributing to substantial reductions in suspended particulate matter emissions in compliant kilns (Eil et al. 2020, Timilsina et al. 2024). Vietnam’s 2010 Decision 567 launched a national programme to develop non-fired materials (Government of Vietnam, Prime Minister. 2010) and China prohibited solid clay bricks in 170 cities by the early 2000s, saving roughly 60,000 hectares of arable land within two years (Daily 2004). Durable reductions require integrated technology adoption, demand substitution and credible enforcement.

Policy Options

Three principal options have been advanced. They are not mutually exclusive; the recommended strategy combines them.

First Option: Universal Zigzag 2.0 Conversion

Accelerating conversion of remaining Fixed Chimney Kilns and rolling out Zigzag 2.0 process improvements. A randomised controlled trial across 276 zigzag kilns in Khulna Division found that operational improvements (better fuel feeding, brick stacking and insulation) were adopted by 65 percent of treatment kilns, reducing CO₂ (carbon dioxide) and PM2.5 emissions by 171 and 0.45 metric tonnes per kiln per year, respectively (approximately 20 percent reductions amongst adopting kilns) and energy use by 10.5 percent. Social benefits exceed costs by approximately 65 to 1 when CO₂ reductions are valued at the social cost of carbon of USD 185 per metric tonne (Brooks et al. 2025). Benefits: speed, low cost, scalability through the International Centre for Disease Research, Bangladesh (icddr,b). Risks: continued reliance on fired clay; limited gains where kilns are sited near vulnerable populations.

Second Option: Demand Substitution Towards Non-Fired Blocks

Re-orientating construction demand towards concrete, hollow, autoclaved aerated concrete and compressed stabilised earth blocks. The 2019 amendment already mandates this in government works and Bangladesh Bank’s green-finance scheme offers subsidised loans for block manufacturers (Alam and Barman 2019). Full substitution would eliminate kiln emissions and topsoil loss. Risks: capital intensity, the missed 2025 deadline and the existing VAT (Mongabay 2026).

Third Option: Enforcement Intensification with Satellite Monitoring

Strengthening regulatory enforcement using satellite imagery and deep-learning detection. Lee et al. (2021) demonstrated that scalable algorithms can geo-locate every operating kiln in South Asia at low cost. Benefits: immediate visibility and credible deterrence. Risks: political resistance from industry associations and persistent recidivism (Prothom Alo 2025). Table 3 below shows the Comparative Assessment of Policy Options. As the underlying problem combines technological lock-in, weak governance and structurally distorted demand, no single option is sufficient. The recommendation below sequences them.

Table 3.

Comparative Assessment of Policy Options.

Policy Option

Primary Benefit

Time Horizon

Main Risk

Universal Zigzag 2.0 conversion

≈ 20% PM2.5/CO₂ per adopting kiln; BCR ≈ 65:1

1-3 years

Continued fired-clay reliance

Demand substitution to non-fired blocks

Permanent emissions and topsoil-loss elimination

3-7 years

Capital intensity, tax disincentives

Enforcement intensification with satellites

Credible deterrence; visibility of illegal kilns

1-5 years

Political resistance; capacity gaps

Note. Synthesis from Alam and Barman 2019, Lee et al. 2021, Lima et al. 2024, Brooks et al. 2025, The World Bank 2025, Sarwar et al. 2025.

Recommended Action: A Phased Five-Year Strategy

This brief recommends a phased five-year National Brick-Sector Air Quality Strategy anchored within the National Air Quality Management Plan 2024-2030, led by the Ministry of Environment, Forest and Climate Change, in coordination with the Cabinet Committee on Air Quality. The immediate phase (FY2026-2027) focuses on rapid emission reduction. The Department of Environment, with icddr,b and the Stanford brick research programme, should scale Zigzag 2.0 training to all approximately 7,000 traditional kilns by the end of 2027 (Brooks et al. 2025), commission a national satellite-based kiln registry using Lee et al. (2021) methodology within twelve months and redirect mobile court enforcement towards the highest-emitting and school-proximate kilns. The medium-term phase (FY2028-2029) accelerates demand substitution: eliminate the 15 percent VAT on non-fired blocks; enforce a 50 percent non-fired block public-procurement target; and triple Bangladesh Bank’s green-finance refinancing capacity. The World Bank Bangladesh Clean Air Project (USD 290 million, approved June 2025) provides the principal financing platform (The World Bank 2025). The long-term phase (to 2030) finalises the structural transition: ban Fixed Chimney Kilns with credible enforcement; relocate or close kilns within one kilometre of schools and hospitals; and join the regional Indo-Gangetic Plain airshed initiative.

Implementation Strategy

The Ministry of Environment should establish a Brick-Sector Air Quality Coordination Committee chaired at the Adviser or Cabinet Secretary level, comprising the Department of Environment, Ministry of Industries, Ministry of Housing and Public Works, Bangladesh Bank, the Bangladesh Brick Manufacturing Owners Association, civil-society organisations and donors. The committee should report quarterly on kiln conversion, demolition and ambient PM2.5. Resource mobilisation can build on the World Bank’s USD 290 million Bangladesh Clean Air Project, plus complementary financing from the Asian Development Bank and Asian Infrastructure Investment Bank. Disbursement-linked indicators should tie tranches to verifiable PM2.5 reductions, district conversion rates and procurement compliance, with an annual Air Quality Implementation Review tabled before the National Parliament.

Expected Outcomes

Modelling by the Energy Policy Institute at the University of Chicago, EPIC (2025), implies that meeting the national PM2.5 standard of 35 µg/m³ in Dhaka would restore approximately 4.1 years of life expectancy per resident, while meeting the WHO guideline would restore 6.9 years. Sarwar et al. (2025) project that halving brick-kiln emissions alone could lower wintertime ambient PM2.5 by 14-20 µg/m³. The World Bank (2025) projects that full implementation of the National Air Quality Management Plan could halve air-pollution-related premature deaths by 2030. Recovery from current air-pollution damage would generate billions in avoided medical expenditure and lift agricultural productivity through reduced topsoil loss (Lima et al. 2024). The Brooks et al. (2025) Zigzag 2.0 evaluation reports a benefit-to-cost ratio of approximately 65 to 1 at the social cost of carbon of USD 185 per metric tonne. Equity gains accrue disproportionately to women, children and the poor.

Limitations

This study relies primarily on secondary data and policy analysis rather than primary fieldwork or stakeholder interviews. Consequently, the perspectives of kiln workers, local communities and small-scale producers are not directly represented. In addition, source-apportionment estimates and mortality calculations vary across datasets and modelling approaches. The analysis also emphasises institutional and environmental dimensions, with more limited attention to the broader socioeconomic trade-offs associated with stricter regulation and the transition towards non-fired construction materials. Finally, Bangladesh’s evolving political context may affect the feasibility and pace of policy implementation.

Conclusion

Air pollution from brickfields in Dhaka is not a technical problem awaiting a solution; it is a governance and political-economy problem with proven, low-cost technical solutions that have not yet been scaled. Recent evidence from the Zigzag 2.0 trial, satellite-based kiln detection, atmospheric modelling and direct epidemiological studies provides a stronger evidence base than at any prior point. The interim government’s reform window, the Bangladesh Clean Air Project and the National Air Quality Management Plan 2024-2030 collectively offer Bangladesh its best opportunity in two decades. The cost of further delay will be measured in lives.

Conflicts of interest

The authors have declared that no competing interests exist.

References

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