Russian Federation [Raw-material export with Minfin inexpediency conclusion] → China (mainland) (refine) · Deposit, trade and withdrawal on the Shanghai Gold Exchange

Public law and official guidance, published as research. Not legal, tax or financial advice.

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Russia (Doré bar - unstamped → Concentrate / black sand) ⟶ China (Concentrate / black sand → 999.9 kilobar)

Leg 1: Russia

Where the goods start

Doré bar - unstamped → Concentrate / black sand

1
Extract gold ore or placer sands within the licensed plot
Who
Subsoil user (gold mining company)
Needs
Subsoil-use licence (electronic); Special-registration register entry (FPP)
Form
Ore (in situ / run-of-mine) → Concentrate / black sand
Primary law
- Law 'On Subsoil', art. 11
2
Process on site (gravity, leaching, smelting) into dore bars or placer (shlikh) gold; the metal must then go to refining
Who
Subsoil user (gold mining company)
Issues
Batch number / GIIS UIN of the dore lot
Form
Concentrate / black sand → Doré bar - unstamped
Primary law
Processing technology is industry practice; the law only requires "necessary processing" before refining.
- Federal Law 41-FZ, art. 20(1)
3
Sign a refining agreement with a listed refiner; it must set the delivery schedule and volumes, limits of harmful substances, the inventory of each lot, commission acceptance with control sampling, timing and specifications of the output, return-waste norms, the recipients of refined metal, the owner's delivery obligations to the State Fund or regional funds, liability and dispute settlement
Who
Subsoil user (gold mining company)
Issues
Refining (tolling) agreement miner-refiner
Primary law
- Government Decree 972, Procedure para 3, para 3
4
Record the lot in GIIS DMDK and issue an electronic accompanying document (ESD) with the lot's UIN for dispatch to the refiner
Who
Subsoil user (gold mining company)
Needs
Batch number / GIIS UIN of the dore lot; Refining (tolling) agreement miner-refiner
Issues
ESD for dispatch of dore/placer gold to the refiner
Official guidance
[not-read] The GIIS DMDK Rules (Decree 270) were not read in full; the ESD fields for dore were not seen.
- Government Decree 270 of 26.02.2021
5
Transport dore to the refinery by air, sea, inland water, rail or a specialised equipped road vehicle under armed escort
Who
Secure carrier of valuables
Needs
ESD for dispatch of dore/placer gold to the refiner
Primary law
- Federal Law 41-FZ, art. 29(3)
6
Obtain the Minfin conclusion on the (in)expediency of industrial extraction in Russia: file through GIIS DMDK the sampling act, an accredited-laboratory test protocol on precious and associated metals, and a justification with the value of recoverable metals and processing and transport costs; Minfin decides within 10 working days
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Issues
Minfin conclusion on the inexpediency of industrial extraction of precious metals from raw materials in Russia; Test protocol on precious-metal content
Primary law
- Minfin Order 10n, Annex 2; Presidential Decree 1137 para 23, Annex 2 paras 3, 5
7
Obtain the export licence and FPP control (for ores and concentrates HS 2616 the FPP checks documents only, not the goods)
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Needs
Minfin conclusion on the inexpediency of industrial extraction of precious metals from raw materials in Russia; Test protocol on precious-metal content
Issues
EAEU export licence issued by Minpromtorg (one-off or general); Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber
Primary law
- EEC Board Decision 30, Annex 14, Annex 2 (Rules) para 10; Presidential Decree 1137 para 23(a), Rules para 10
8
Clear customs; between 1 Oct 2023 and 31 Dec 2024 the exchange-rate-linked export duty (0-7%) applied to precious-metal ores and concentrates (HS 2616)
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Needs
Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber; EAEU export licence issued by Minpromtorg (one-off or general)
Issues
Export goods declaration (accepted and released by customs)
Primary law
[unconfirmed] No duty on HS 2616 after 31 Dec 2024 was found.
- Government Decree 1538, para 1 and para 12, para 1

Taxes and fees

Exchange-rate-linked export duty on gold
0% (average USD/RUB below 80), 4% (80-85), 4.5% (85-90), 5.5% (90-95), 7% (95 and above) of the customs value
Primary lawAmount not confirmed
- Government Decree 1538 of 21.09.2023, para 1; Decree 532 of 25.04.2024, para 1
Export duty on gold-bearing concentrates
Same exchange-rate-linked bands (0-7%) as Decree 1538 para 1 - group 26 (except 2609 00 000 0) is in the list, which covers precious-metal ores and concentrates (HS 2616) Precious-metal ores and concentrates (HS 2616) exported outside the EAEU
Primary lawAmount not confirmed
- Government Decree 1538 of 21.09.2023, para 1, para 1
Mineral extraction tax (NDPI) on gold
6.0% (art. 342(2)(5): "концентратов и других полупродуктов, содержащих в себе один или несколько драгоценных металлов"), times the rent coefficient KRENTA = 1 for these minerals (art. 342⁸(3)(2)) and the territory coefficient Ktd (art. 342(2²)) Gold-bearing semi-products at the end of the extraction operations (dore/ligature gold, placer and native gold, concentrates)
Primary lawAmount not confirmed
- Tax Code Part Two, ch. 26, arts. 337(2)(13), 340(5), 342(2)(5), 342⁸(3)(2)
NDPI surcharge on gold (2024)
RUB 78,000 per kg of gold contained in the extracted semi-product (КДРМ = VДРМ x 78 000) Tax periods beginning 1 June - 31 December 2024; gold in semi-products under art. 337(2)(13) extracted on licensed plots
Primary lawAmount not confirmed
- Federal Law 96-FZ of 22.04.2024, art. 1(7), adding Tax Code art. 343(21), art. 343(21) (2024 wording)
NDPI surcharge on gold from 2025
КДРМ = 0.1 x (ЦЗ / 1000 - 61 000) x VДРМ x Р: 10% of the excess of the month's average world gold price in USD per kg (ЦЗ is USD per tonne, art. 342¹⁰(1)) over USD 61,000 per kg, times the kg of gold contained, times the month's average USD/RUB rate
Primary lawAmount not confirmed
- Tax Code art. 343(21) as restated by Federal Law 176-FZ of 12.07.2024, art. 343(21)

Controls

FPP state control of every import from and export to non-EAEU states of goods in tables 1 and 3 of section 2.10 (41-FZ art. 26²; Decree 1137 para 19(b)): the whole batch is presented (for ores and concentrates, HS 2616, the documents only) and controlled within 5 working days; checks of the batch a…
Primary law
- EEC Board Decision 30, Annex 14, Annex 2 (Rules) paras 3, 4, 7, 8, 10; Presidential Decree 1137 paras 19, 19¹, Rules paras 3, 10
From 1 May 2026 export from Russia of refined gold in bars with a total weight over 100 g by individuals, legal entities and entrepreneurs is prohibited, except (a) to EAEU member states through the international airports Moscow (Vnukovo), Moscow (Domodedovo), Moscow (Sheremetyevo) and Vladivostok (…
Total weight over 100 g
Primary lawAmount not confirmed
- Presidential Decree 193 of 25.03.2026; Government Decree 450 of 23.04.2026, para 2, para 4
Purchase and sale of precious metals (and jewellery and scrap) of RUB 1,000,000 or more is subject to mandatory control and reported to Rosfinmonitoring by the seller within 3 working days; individuals buying jewellery up to RUB 60,000 (RUB 400,000 with a personalised e-payment means) are not identi…
RUB 1,000,000
Primary lawAmount not confirmed
- Law 115-FZ, art. 6(1)(4) sixth paragraph; art. 7(1.4-2)
Only listed refiners, Goznak and credit organisations may sell refined (investment) bars to individuals, and retailers only bars received on commission or agency from them; buy-back dealers and pawnshops may pass bars bought from individuals only to refiners. Deals between individuals in precious me…
Primary law
- Government Decree 604 of 15.05.2024 (Rules paras 3-4, 8); 41-FZ art. 22(6), Rules para 4
No gold-specific cash-payment limit was found. The RUB 1,000,000 mandatory-control threshold applies whatever the means of payment.
Unverified
Export to non-EAEU states of goods in tables 1 and 2 of section 2.10 of the EAEU Single List (table 1 includes refined gold in bars, plates, powder and granules, unique and non-refinable nuggets, other unwrought gold incl. dore, scrap, ores and concentrates) requires a licence issued by Minpromtorg …
Primary law
- Presidential Decree 1137 (Regulation paras 4, 22, 23); EEC Board Decision 30, Annex 14 para 5; Minfin Order 10n, paras 4, 22, 23
Residents must receive export proceeds on their accounts in authorised banks (173-FZ art. 19(1)(1)). Under art. 19(8) this does not apply to contracts priced or payable in foreign currency, except for goods listed there; the list includes HS 7101-7103 and 7112 but not 7108 (gold). Where art. 19 appl…
Primary law
- Federal Law 173-FZ art. 19; Presidential Decrees 79 (para 2) and 430, art. 19(1), (8)
Traceability: participants must record precious-metal operations in GIIS DMDK, with UINs and electronic accompanying documents between participants; refiners report receipt and shipment of metal in any form.
Primary law
- 41-FZ art. 12², art. 20(2); Government Decree 270 of 26.02.2021, art. 12²
Refined metal in standard form must, before it enters circulation, be offered by a purchase proposal to the State Fund institution under Minfin and to the authority of the mining region (where a regional fund exists) - for the next year by 31 December, with an additional proposal within 10 working d…
Primary law
- Federal Law 41-FZ, art. 2(5), art. 20(4)-(5)
LBMA suspended six Russian refiners on 7 Mar 2022; their bars produced from that date are not Good Delivery; Russian bars already in loco London/Swiss before then remain Good Delivery, with clearing banks attesting conformity.
Standard
Mined and produced precious metals (except nuggets) must, after the necessary processing, go for refining to organisations on the Government list (41-FZ art. 20(1)); only listed organisations may refine (art. 4(4)); the refining agreement's mandatory terms and the refiner's reporting duties are set …
Primary law
- Federal Law 41-FZ, art. 20(1)
Switzerland: purchase, import, transit and transport into and through Switzerland of gold under Annex 26 (includes HS 7108) originating in Russia and exported from Russia after 4 August 2022 are prohibited (Art. 14d(1)); the same applies to such gold processed in a third country (Art. 14d(2)) and, s…
Primary law
- Swiss Ukraine Ordinance SR 946.231.176.72 (Stand 21.09.2026), Art. 14d
EU: it is prohibited to purchase, import or transfer, directly or indirectly, gold listed in Annex XXVI (HS 7108; 7112 91 gold waste and scrap; ex 7118 90 gold coins) that originates in Russia and was exported from Russia into the Union or to any third country after 22 July 2022 (art. 3o(1)); the sa…
Primary law
- Regulation (EU) 833/2014 as amended by 2022/1269, art. 3o
Japan: import of precious metals originating in Russia and shipped from Russia on or after 1 August 2022 requires the Minister of Finance's permission under FEFTA art. 19(2) (MOF Notice No 443 of 2006 as amended 25 July 2022, item 4); the government announced it on 5 July 2022 as an import ban.
Primary law
- MOF Notice No 443 of 2006 as amended 25 Jul 2022, item 4
UK: import of gold originating in Russia and exported from Russia on or after 21 July 2022 is prohibited (reg 46Z11, Chapter 4J inserted by SI 2022/850, in force 21 Jul 2022), with prohibitions on acquisition with intent to import, supply and delivery, technical assistance, financial services and br…
Primary law
- Russia (Sanctions) (EU Exit) Regulations 2019, regs 46Z11-46Z16, 46Z16A-46Z16C
US: import of gold of Russian Federation origin is prohibited from 28 Jun 2022, except gold located outside Russia before that date (OFAC determination under E.O. 14068 s. 1(a)(i)(A), amended version of 22 Dec 2023). U.S. persons may not deal with the Central Bank, the National Wealth Fund or the Mi…
Primary law
- E.O. 14068 and the OFAC determination; E.O. 14024 as amended by E.O. 14114, E.O. 14068 s. 1(a)(i)(A); E.O. 14024 s. 11
  “the importation into the United States of … products of Russian Federation origin”
Temporary ban from 1 June to 30 November 2026 on export from Russia of precious-metal waste and scrap (HS 7112) and electrical and electronic waste used mainly to recover precious metals (8549 21 000 0, 8549 29 000 0), with exceptions for samples of up to 500 g per batch exported by listed refiners …
Primary law
- Government Decree 558 of 16.05.2026, para 1
Legal entities, entrepreneurs and artist-jewellers operating with precious metals must be on the FPP special register kept in GIIS DMDK; those that should be registered and are not may not carry out operations (41-FZ art. 13¹(2)). Registration within 30 calendar days of state registration (Rules pa…
Primary law
- 41-FZ art. 13¹; Government Decree 1052 (Rules paras 2, 5), art. 13¹
Precious metals and products from them are transported by air, sea, inland water, rail or specialised equipped road vehicles under armed escort; raw materials with less than 1% gold (or 5% silver), jewellery, investment metals (within a weight limit set by the Government) and some other items may mo…
Primary law
- Federal Law 41-FZ, art. 29(3)

Leg 2: China

Where the goods arrive

Concentrate / black sand → 999.9 kilobar

9
Hold the PBoC gold import/export qualification (bank that is an SGE financial member or market maker, or qualified mining group or refiner)
Who
Bank holding PBoC gold import/export qualification (SGE financial member or market maker)
Primary law
- Gold and Gold Products Import/Export Measures, Arts. 7, 8, 10
10
Apply to the PBoC for a permit for the batch: application form, import contract and (on repeat applications) nothing further unless details changed
Who
Bank holding PBoC gold import/export qualification (SGE financial member or market maker)
Issues
Gold and Gold Products Import/Export Application Form (《黄金及黄金制品进出口申请表》) with contract; Gold import/export contract (required with the permit application)
Primary law
- Gold and Gold Products Import/Export Measures, Art. 10
11
Examine (verification by two or more staff where needed) and decide within 20 working days; issue the permit, one per batch, usable within 40 working days
Who
People's Bank of China (permit issuer and reserve holder)
Needs
Gold and Gold Products Import/Export Application Form (《黄金及黄金制品进出口申请表》) with contract; Gold import/export contract (required with the permit application)
Issues
PBoC permit (import batch)
Primary law
- Gold and Gold Products Import/Export Measures, Arts. 3, 14-17
12
Pay the foreign seller through the bank under foreign-exchange rules
Who
Bank holding PBoC gold import/export qualification (SGE financial member or market maker)
Needs
Gold import/export contract (required with the permit application)
Issues
Import payment through an FX-authorised bank
Primary law
[not-read] SAFE detailed goods-trade FX rules (current-account guidelines) not held; the FX Regulations require a genuine transaction basis checked by the bank.
- Gold and Gold Products Import/Export Measures; FX Regulations, Measures art. 23; FX Regulations arts. 12, 14
13
Declare the gold to Customs (HS 7108) presenting the PBoC permit; import-stage VAT is exempt for gold (incl. standard gold) and gold ore
Who
Bank holding PBoC gold import/export qualification (SGE financial member or market maker)
Needs
PBoC permit (import batch); Export customs declaration accepted by the dispatching country's customs; Air waybill; Refiner's certificate for the bars it produced (serials, fineness, weights, year); Commercial invoice
Issues
Customs import declaration (进口货物报关单), HS 7108
Primary law
[unconfirmed] Import duty rate for 7108 not held (cn.gap-tariff). [unconfirmed] Continuation of the import-stage VAT exemption after 1 Jan 2026 (cn.gap-import-vat-2026; MOF/GAC/SAT 2026 No. 17 read only in summary [summary]).
- Gold and Gold Products Import/Export Measures; Customs Law; Caishui [2002] 142, Measures arts. 3, 17; Customs Law art. 24; Caishui 142 point 1
14
Register the imported gold on SGE and complete its first trade there (duty to balance domestic physical supply)
Who
Bank holding PBoC gold import/export qualification (SGE financial member or market maker)
Needs
Customs import declaration (进口货物报关单), HS 7108
Issues
SGE registration and first-trade record of imported gold; SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)
Primary law
- Gold and Gold Products Import/Export Measures, Art. 6
15
Report execution of the permit to the PBoC
Who
Bank holding PBoC gold import/export qualification (SGE financial member or market maker)
Needs
PBoC permit (import batch)
Issues
Report to PBoC on use of the import/export permit
Primary law
- Gold and Gold Products Import/Export Measures, Art. 19
16
Receive and assay doré or raw gold under the refining or purchase agreement
Who
SGE-accredited refiner (standard gold ingot / bar refiner)
Needs
Refining Agreement (fee schedule, assay/settlement formula); VAT-exempt sales invoice for non-standard gold or gold ore (producer sale)
Unverified
Chinese refiner intake practice not documented in sources read.
17
Refine into SGE standard ingots or bars (Au99.99 1 kg; Au99.95 3 kg; Au99.5 12.5 kg; Au100g/Au50g at 999.9) under the refiner's SGE accreditation
Who
SGE-accredited refiner (standard gold ingot / bar refiner)
Form
Doré bar - unstamped → 999.9 kilobar
Official guidance
- SGE Detailed Delivery Rules; SGE Refiner Measures 2025, Delivery Rules Art. 11 and Annex 1; Refiner Measures arts. 2, 26-27
18
Issue the certificate of quality and packing list (bar list) for the bars
Who
SGE-accredited refiner (standard gold ingot / bar refiner)
Issues
Refiner's certificate of quality and packing list for SGE standard bars; Bar list (serials, weights, fineness)
Official guidance
- SGE Detailed Delivery Rules, Art. 30
19
Open an FT account at a margin custodian bank and trade International Board contracts (iAu99.99, iAu99.5) in offshore RMB
Who
SGE international member or international client (SGEI, Shanghai FTZ)
Issues
Free Trade (FT) account statement in offshore RMB (SGEI)
Official guidance
- SGE Member Management Measures (2026); SGEI Business Management Measures, Member Measures Arts. 3-4; SGEI Measures arts. 4, 20-21
20
Bring bars from abroad into an International Board vault (Customs-supervised, bonded) without a PBoC permit (exempt channel), through the vault's designated carrier and customs broker, giving SGE the invoice (incl. origin), packing list, bar list and non-wood packaging declaration; load-in needs SGE authorisation and bars from SGE-accredited or recognised international suppliers
Who
SGE international member or international client (SGEI, Shanghai FTZ)
Needs
Air waybill; Refiner's certificate for the bars it produced (serials, fineness, weights, year)
Issues
IB vault entry papers; SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)
Primary law
[not-read] Customs' own entry formalities for the bonded zone (declaration form, supervision code) not held; the SGE guidelines say the vault's appointed customs broker files them.
- Gold and Gold Products Import/Export Measures; SGE IB Vault Guidelines; SGE Vault Measures; Delivery Rules, Measures art. 20(2); Guidelines arts. 4-9; Vault Measures arts. 4, 12; Delivery Rules Art. 27 and Annex 2
21
Hold the bars in an International Board vault (3 bonded vaults: trading vaults in Shanghai (2) and Shenzhen (1); safekeeping vault in Shanghai). SGE's January 2026 fee schedule lists IB storage rates, while the IB page says storage and in/out fees are currently waived
Who
SGE designated vault / International Board certified vault operator
Official guidance
[conflict] cn.div-conflict-ib-fees: fee schedule rates versus the waiver stated on the IB page.
- SGE Vault Measures; SGE fee schedule (Jan 2026), Vault Measures Art. 3
22
Withdraw for re-export abroad (exempt channel: invoice and SGE withdrawal papers; carrier appointed by the vault) or for entry into the domestic market (only by a member or client holding the gold import/export qualification, with the PBoC permit copy 1 and a customs import declaration); the destination is reported to SGE and Customs
Who
SGE international member or international client (SGEI, Shanghai FTZ)
Issues
SGE Application for Load-Out and Application of Take-delivery
Primary law
- Gold and Gold Products Import/Export Measures; SGE IB Vault Guidelines; Delivery Rules; Vault Measures, Measures arts. 4, 20; Guidelines arts. 10-12, 17-19; Delivery Rules Art. 42; Vault Measures Arts. 17-18
23
Deposit bars at an SGE designated vault through a registered designated deposit person, with the Load-In application (3 copies), quality certificate and packing list; the vault checks gross weight (tolerance ±0.1 g for ingots, ±0.05 g for bars) and accepts only bars from SGE-accredited refiners or suppliers accredited by an SGE-recognised international market
Who
SGE comprehensive member (producer, processor, jeweller or trader)
Needs
Refiner's certificate of quality and packing list for SGE standard bars; Bar list (serials, weights, fineness)
Issues
SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)
Official guidance
- SGE Detailed Delivery Rules; Vault Measures, Delivery Rules Arts. 11, 29-31; Vault Measures Art. 4
24
Sell standard gold on SGE; the seller's sale is VAT-exempt (it invoices the exchange with an ordinary invoice against the exchange's settlement invoice); while no physical delivery out of the vault takes place, the exchange's sale is also exempt and the buyer receives a settlement invoice (结算发票) only
Who
SGE comprehensive member (producer, processor, jeweller or trader)
Needs
SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)
Issues
SGE trade and clearing record
Primary law
- MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 point 1; SAT No. 23 point 1
25
Buyer (member or client) applies through the member platform to take delivery and presents the Load-Out application, take-delivery application and withdrawer's ID at the vault
Who
SGE institutional client (e.g. jewellery manufacturer) trading through a member
Needs
SGE trade and clearing record
Issues
SGE Application for Load-Out and Application of Take-delivery
Official guidance
- SGE Detailed Delivery Rules, Arts. 37, 43, 45
26
On delivery out of the vault to a member that declared investment use on the delivery-out slip, the exchange's sale is subject to VAT levied and immediately refunded to the exchange (urban construction tax and education surcharges exempt) and SGE issues the member a VAT special invoice labelled 会员单位投资性黄金
Who
Shanghai Gold Exchange (and SGEI)
Needs
SGE Application for Load-Out and Application of Take-delivery
Issues
SGE VAT special invoice labelled 会员单位投资性黄金 (member withdrawal for investment use)
Primary law
- MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 points 1(1), 5, 7; SAT No. 23 point 2(1)-(2)
27
Deduct the input VAT shown on the SGE special invoice after use confirmation on the tax platform; onward sales of the gold, or of investment gold products made from it, are invoiced with ordinary invoices only (no special invoices, except legal gold coins)
Who
SGE comprehensive member (producer, processor, jeweller or trader)
Needs
SGE VAT special invoice labelled 会员单位投资性黄金 (member withdrawal for investment use)
Issues
Member's input-VAT deduction on the SGE special invoice (VAT return schedule 2, after use confirmation)
Primary law
- SAT Announcement 2025 No. 23; MOF/SAT Announcement 2025 No. 11, SAT No. 23 point 2(3)-(4); 2025 No. 11 point 1(1)
28
On delivery out of the vault for non-investment use (declared on the delivery slip), or to a client, the exchange's sale is exempt and SGE issues an ordinary invoice labelled 会员单位非投资性黄金 or 客户标准黄金; a general-taxpayer buyer computes input VAT at 6% of the invoice amount
Who
Shanghai Gold Exchange (and SGEI)
Needs
SGE Application for Load-Out and Application of Take-delivery
Issues
SGE VAT ordinary invoice labelled 会员单位非投资性黄金 or 客户标准黄金 (non-investment use or client withdrawal)
Primary law
- MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 point 1(2)-(3); SAT No. 23 points 3-4
29
Report the change of use to the exchange before it happens and apply, once, within 6 months, to change the declared use; red-letter invoice reversal and re-issue
Who
SGE comprehensive member (producer, processor, jeweller or trader)
Issues
Application to change declared use (investment / non-investment), once within 6 months
Primary law
- MOF/SAT Announcement 2025 No. 11, Point 8
30
Sell onward (bars or jewellery) charging VAT at 13%; gold jewellery also bears consumption tax of 5% at retail, on the sales value excluding VAT
Who
SGE institutional client (e.g. jewellery manufacturer) trading through a member
Primary law
[unconfirmed] Later changes to the consumption-tax rate table not checked.
- VAT Law; Consumption Tax Regulations; Caishui [1994] 95, VAT Law art. 10(1); Consumption Tax rate table item 4.1; Caishui [1994] 95 points 1-2, 7

Taxes and fees

Consumption tax on gold jewellery
5% Gold jewellery at retail
Primary lawAmount not confirmed
- Consumption Tax Regulations; Caishui [1994] 95, Rate table item 4.1; Caishui [1994] 95 points 1-4, 7
Export of gold-containing goods: VAT-exempt without refund
VAT-exempt (no export refund; input VAT not refunded) Goods containing gold or platinum listed in annex 8, incl. HS 71081100, 71081200, 71081300 and 71082000; diamonds and diamond jewellery
Primary law
- MOF/SAT Announcement 2026 No. 11, Art. 6(1)1(4)
No export VAT rebate on gold
No rebate on gold; for gold jewellery only the processing value added is rebated
Primary law
- Caishui [2002] 142 point 3, replaced by Guoshuifa [2005] 125, Point 3
Import customs duty on unwrought gold (HS 7108)
Unverified
Import-stage VAT on gold and gold ore
Exempt Imported gold (incl. standard gold) and gold ore
Primary lawAmount not confirmed
- Caishui [2002] 142, Point 1
VAT on standard gold sold off-exchange
13% (standard VAT rate on goods) Standard gold not sold through SGE or SHFE
Primary lawAmount not confirmed
- MOF/SAT Announcement 2025 No. 11 point 2; VAT Law, 2025 No. 11 point 2; VAT Law art. 10(1)
Earlier VAT regime for SGE members' sales of standard gold (Caishui [2002] 142 point 2)
No physical delivery: exempt; physical delivery: the tax authority issued a special invoice at the actual price and VAT was levied and immediately refunded, with urban construction tax and education surcharges exempt (for sales through the exchange with its settlement voucher)
Primary law
- Caishui [2002] 142, Point 2
VAT on standard gold withdrawn by a member for investment use
VAT levied and immediately refunded to the exchange (即征即退), urban construction tax and education surcharges exempt; the exchange issues the member a special invoice (label 会员单位投资性黄金) whose VAT the member deducts; the member's onward sales carry ordinary invoices only Member withdrawals for direct sale or processing into 99.5%+ bars, ingots or legal gold coins
Primary law
- MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 points 1(1), 5; SAT No. 23 point 2
VAT on SGE / SHFE trades of standard gold without physical delivery
Exempt: the seller's sale to the exchange, and the exchange's sale while no physical delivery takes place; the buyer receives a settlement invoice (结算发票) Standard gold (AU99.99/99.95/99.9/99.5; 50 g, 100 g, 1 kg, 3 kg, 12.5 kg) traded on the exchange
Primary lawAmount not confirmed
- MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 point 1; SAT No. 23 point 1
VAT on standard gold withdrawn for non-investment use or by a client
Exempt at the exchange (ordinary invoice); general-taxpayer buyer deducts input VAT at 6%; onward sales taxed normally with special invoices Jewellery, industrial and other non-investment uses; all client withdrawals
Primary lawAmount not confirmed
- MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 point 1(2)-(3); SAT No. 23 points 3-4
VAT on producers' sales of non-standard gold and gold ore
Exempt Sales of gold other than standard gold, and gold ore (incl. associated gold), by gold producers and dealers
Primary lawAmount not confirmed
- Caishui [2002] 142, Point 1
VAT on gold producers' and dealers' sales of non-standard gold and gold ore (2026-2027)
Exempt Sales of gold other than standard gold (AU9999, AU9995, AU999, AU995 in 50 g, 100 g, 1 kg, 3 kg, 12.5 kg) and of gold ore (incl. associated gold) by gold producers and dealers
Primary lawAmount not confirmed
- MOF/SAT Announcement 2026 No. 10, 二(二)24

Controls

No permit is needed for processing trade, for movements between special customs supervision areas/bonded sites and abroad or between such areas, or for repair, return and temporary import/export; Customs supervises them.
Primary law
- Gold and Gold Products Import/Export Measures, Art. 20
Special preventive measures: for persons on the counter-terrorism list, the Foreign Ministry notices implementing UN Security Council targeted financial sanctions, and the PBoC high-risk list, institutions must immediately stop services and restrict transfers of funds and assets and report to the PB…
Primary law
- AML Law 2024; PBoC PM AML Measures; Anti-Foreign Sanctions Law, AML Law art. 40; Measures art. 27; AFSL arts. 11-12
Mining without a mining right: ordered to stop; confiscation of tools, equipment and the minerals taken; fine of 3 to 5 times the market value of the minerals illegally extracted, or RMB 100,000 to 1,000,000 where nothing was extracted or the value is under RMB 100,000; suspension if the activity co…
Primary law
- Mineral Resources Law 2024, Art. 64
Dealers in precious-metal spot trading are specific non-financial institutions (AML Law art. 64(3)). Under the PBoC Measures (in force 1 Aug 2025) they must run AML controls, assess risk at least every 3 years, carry out CDD incl. beneficial owners on cash of RMB 100,000 or more, report large cash t…
Cash of RMB 100,000 single or daily cumulative (Measures arts. 2, 15, 24)
Primary lawAmount not confirmed
- AML Law 2024; PBoC PM AML Measures; Import/Export Measures, AML Law arts. 34, 64; Measures arts. 2, 13-16, 24-26, 38; Import/Export Measures art. 22
SGE deposit and delivery accept only standard ingots/bars from SGE-accredited refiners, or from suppliers accredited by an SGE-recognised international market. The Delivery Rules (Annex 2) and the overseas criteria name LBMA Good Delivery refiners; overseas refiners can also be accredited directly (…
Official guidance
- SGE Detailed Delivery Rules; SGE Vault Measures; SGE Refiner Measures and Overseas Criteria, Delivery Rules Art. 11 and Annex 2; Vault Measures Art. 4; Overseas Criteria arts. 6, 19
Exports of unwrought gold are subject to the same PBoC qualification and per-batch permit; the export is VAT-exempt without refund (MOF/SAT 2026 No. 11 art. 6 and annex 8).
Primary law
- Gold and Gold Products Import/Export Measures, Arts. 3, 8
Foreign-exchange receipts and payments arising from gold imports and exports follow SAFE rules (Measures art. 23): current-account payments are unrestricted but need a genuine, lawful transaction basis checked by the bank and are made against valid documents (FX Regulations arts. 5, 12, 14); receipt…
Primary law
- Gold and Gold Products Import/Export Measures; FX Regulations, Measures art. 23; FX Regulations arts. 5, 9, 12, 14
Import and export of gold and gold products in the PBoC catalogue need a PBoC permit presented to Customs: one permit per batch, used within 40 working days, only for entities holding the PBoC qualification; the PBoC may restrict quantities for macro-economic reasons (art. 3). No other channel is la…
Every batch
Primary law
- Gold and Gold Products Import/Export Measures; Customs Law, Measures arts. 3, 4, 8, 17, 21; Customs Law art. 24
Gold carried into China by travellers is not limited in quantity but must be declared to Customs; gold may be carried out only against a PBoC certificate or up to the quantity declared on entry (Gold and Silver Regulations arts. 25-26). The Import/Export Measures (art. 4) leave rules for individuals…
Primary law
- Gold and Silver Regulations (rev. 2011); Import/Export Measures, Regulations arts. 25-26; Measures art. 4
Qualified importers/exporters must help balance domestic physical supply; imported gold must be registered and first traded on the State Council-approved gold spot exchange (SGE).
Primary law
- Gold and Gold Products Import/Export Measures, Art. 6
Import and export of national gold reserves are handled only by the PBoC; gold coins (incl. commemorative) only by an institution the PBoC designates (Measures art. 5). Gold coins are minted and issued only by the PBoC (Gold and Silver Regulations art. 21).
Primary law
- Gold and Gold Products Import/Export Measures, Art. 5

Leg 3: Russia

Back in the origin country: the proceeds of the export

31
Receive payment through an authorised bank; the statutory repatriation duty (173-FZ art. 19(1)(1)) applies to rouble-priced contracts but not, under art. 19(8), to FX-priced gold contracts; foreign currency credited under the contract is subject to mandatory sale in the share set by the Government Commission (Decree 79 para 2)
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Issues
Receipt of export proceeds
Primary law
[inferred] Exemption of FX-priced gold contracts read from the absence of 7108 in the art. 19(8) list. [unconfirmed] The current mandatory-sale share is not in a legal act found. Western bank channels are largely closed by sanctions (OFAC FAQ 1029).
- Federal Law 173-FZ art. 19; Presidential Decrees 79 and 430, art. 19

Crossings between countries

Russia → China Researched
Papers that cross: Minfin conclusion on the inexpediency of industrial extraction of precious metals from raw materials in Russia; Test protocol on precious-metal content; EAEU export licence issued by Minpromtorg (one-off or general); Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber

Paperwork gaps

cn.st-24 expects Air waybill; the earlier legs don't model this paper
cn.st-24 expects Refiner's certificate for the bars it produced (serials, fineness, weights, year); the earlier legs don't model this paper
cn.st-24 expects Commercial invoice; the earlier legs don't model this paper
cn.st-28 expects Air waybill; the earlier legs don't model this paper