Russian Federation [Licensed export (miner, refiner or bank)] → Hong Kong (China SAR) → China (mainland) (refine) · Deposit, trade and withdrawal on the Shanghai Gold Exchange

Extract gold ore or placer sands within the licensed plot

执行方

Subsoil user (gold mining company)

所需

Subsoil-use licence (electronic); Special-registration register entry (FPP)

形态

Ore (in situ / run-of-mine) → Concentrate / black sand

• Law 'On Subsoil', art. 11

Process on site (gravity, leaching, smelting) into dore bars or placer (shlikh) gold; the metal must then go to refining

执行方

Subsoil user (gold mining company)

出具

Batch number / GIIS UIN of the dore lot

形态

Concentrate / black sand → Doré bar - unstamped

Processing technology is industry practice; the law only requires "necessary processing" before refining.

• Federal Law 41-FZ, art. 20(1)

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

执行方

Subsoil user (gold mining company)

出具

Refining (tolling) agreement miner-refiner

• Government Decree 972, Procedure para 3, para 3

Record the lot in GIIS DMDK and issue an electronic accompanying document (ESD) with the lot's UIN for dispatch to the refiner

执行方

Subsoil user (gold mining company)

所需

Batch number / GIIS UIN of the dore lot; Refining (tolling) agreement miner-refiner

出具

ESD for dispatch of dore/placer gold to the refiner

[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

Transport dore to the refinery by air, sea, inland water, rail or a specialised equipped road vehicle under armed escort

执行方

Secure carrier of valuables

所需

ESD for dispatch of dore/placer gold to the refiner

• Federal Law 41-FZ, art. 29(3)

Screen buyer and destination: Russian-origin gold exported after the sanctions dates cannot be imported into the EU, UK, US, Switzerland or Japan, and Russian bars made from 7 Mar 2022 are not LBMA Good Delivery; sales go to non-sanctioning markets

执行方

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

Sign the export contract and issue the commercial invoice

执行方

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

出具

Export contract with foreign buyer; Commercial invoice

Apply to Minpromtorg for an export licence (one-off for a contract, or a general licence under Decree 1126 or 867); Minfin approves the application in GIIS DMDK within 10 working days (Order 10n from 1 Sep 2026), except credit organisations' applications for refined gold, silver, platinum and palladium bars since 8 May 2026

执行方

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

所需

Export contract with foreign buyer; Special-registration register entry (FPP)

出具

Minfin conclusion (permissive document) approving an export-licence application (Order 10n from 1 Sep 2026); EAEU export licence issued by Minpromtorg (one-off or general)

Licence validity and issue time from EEC Council Decision 125 Rules paras 9 and 13: a one-off licence is valid up to 1 year from its start (may be limited to the contract term); a general licence up to 1 year; the licensing authority decides within 15 working days of receiving the documents unless the Commission decision introducing the measure sets another term. [unconfirmed] Decision 125's own in-force date depends on the Protocol of 25.05.2023 (see ru.law-eec-125).

• Presidential Decree 1137, Regulation paras 4 and 22; Minfin Order 10n, paras 4, 22

File the application letter for FPP state control through GIIS DMDK with: the export licence copy (table-1 goods), the contract, the specification, the invoice, the calculation of the value of the precious metals (within 5% of world prices), special-registration record or bank licence, proof of lawful ownership, the precious-metal content document, technical documentation, the subsoil licence (mining subjects) and the document on the State Fund's refusal to buy (mining and producing subjects)

执行方

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

所需

EAEU export licence issued by Minpromtorg (one-off or general); Export contract with foreign buyer; Commercial invoice; Document on the authorised bodies' refusal (non-exercise) to purchase; Passport for standard bar / certificate for measured bar of refined precious metal (FPP Order 154n; replaced by a single certificate under Order 144n from 1 Mar 2027)

出具

Application (zayavka / letter-application) for FPP state control on export or import, filed in GIIS DMDK; Calculation of the value of precious metals in the consignment

[transcription] EEC Board Decision 30 read in the ConsultantPlus copy published by the FPP; the FPP list reproduces the same paragraph.

• EEC Board Decision 30, Annex 14, Annex 2 (Rules) para 4(b); Minfin Order 11n (valuation), Rules para 4(b)

State control of the whole consignment within 5 working days: check against documents, origin, compliance with transaction rules, valuation, optional sampling; issue the act of state control (3 copies; the first for customs) or a refusal

执行方

Federal Assay Chamber

所需

Application (zayavka / letter-application) for FPP state control on export or import, filed in GIIS DMDK

出具

Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber

• EEC Board Decision 30, Annex 14, Annex 2 (Rules) paras 3, 8, 10; 41-FZ art. 26², Rules para 10

Lodge the export declaration at a specialised customs post, presenting the export licence and the act of state control

执行方

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

所需

EAEU export licence issued by Minpromtorg (one-off or general); Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber; Commercial invoice

出具

Export goods declaration (accepted and released by customs); Certificate of origin (general form) for non-EAEU destinations

[not-read] The customs rules on the declaration itself were not read.

• EEC Board Decision 30, Annex 14 paras 4-5; Presidential Decree 1137 para 19¹, Regulation paras 4-5

Carry the sealed consignment to the airport and hand to the airline (valuable cargo)

执行方

Secure carrier of valuables

所需

Export goods declaration (accepted and released by customs)

出具

Packing list; Air waybill

The armed-escort rule (41-FZ art. 29(3)) covers transport to the airport; no rule on the hand-over to the airline was read.

• Federal Law 41-FZ, art. 29(3)

Onboard the supplier: KYC and source-of-supply review. Hong Kong law makes CDD mandatory for a Category B registrant only for specified cash transactions (AMLO s.5A(5A)); for bank-paid purchases the pack is the importer's own risk choice, with LBMA/OECD guidance applying where the buyer or refiner is bound by it

执行方

Registered bullion dealer / trader (DPMS registrant)

所需

DPMS Category A registration certificate; Commercial invoice

出具

Supplier KYC pack held by the Hong Kong importer; Customer due diligence file (Category B, specified cash transaction); Supplier's commercial invoice

[inferred] No Hong Kong rule found that requires origin documents for imported gold; the KYC pack is commercial practice outside cash transactions. The legal scope of CDD is read in the Ordinance.

• AMLO s. 5A and Sch. 2 (only for specified cash transactions), s. 5A(5A)-(5B)

  “An AML/CTF requirement that applies to a DNFBP who is a Category B PMS registrant only applies when, by way of business, the registrant carries out, in Hong Kong with a customer, a specified cash transaction that is not an excluded transaction”

Fly the consignment into HKIA and deliver it to the importer's vault. If it is transhipment cargo (consigned on a through bill of lading or through air waybill to a place outside Hong Kong) or transit cargo, no Hong Kong declaration is required and the gold never enters the Hong Kong market

执行方

Secure logistics carrier / forwarder

所需

Supplier's commercial invoice; Air waybill; Export customs declaration accepted by the dispatching country's customs

出具

Inbound air waybill

• Import and Export (Registration) Regulations (Cap. 60E), reg. 3(a)-(b); Cap. 60 s. 2 (transhipment cargo, article in transit)

Receive the bars, weigh them and check serials against the bar list; credit the importer's allocated account

执行方

Precious-metals vault operator

所需

Inbound air waybill

出具

Weight and quality verification record; Bar list (serials, weights, fineness); Allocated account weight list

[inferred] Vault intake practice is not documented in an official source; the clearing press release confirms designated vaults record deposits.

Lodge the import declaration within 14 days after the day of importation using the specified system (Trade Single Window, or during the transition a government-appointed service provider). Gold bars of fineness 995.0 or above (HKHS 7108 1210, 7108 2010) go on Form 1B with no declaration charge; other gold pays the charge. No customs duty or VAT; gold is not an exempted article

执行方

Registered bullion dealer / trader (DPMS registrant)

所需

Inbound air waybill; Supplier's commercial invoice

出具

Hong Kong import declaration (Cap. 60E, lodged electronically within 14 days)

• Import and Export (Registration) Regulations (Cap. 60E), regs 3, 4(1)-(2), 7, 8(1), (1AA), (4), 18

If the gold is paid for with physical currency or BNIs above HK$120,000 carried across the boundary, declare the cash (not the gold) to C&ED: advance CDS declaration for cargo, red channel for arriving travellers

执行方

Registered bullion dealer / trader (DPMS registrant)

出具

CBNI advance electronic declaration (CDS) for cash moved as cargo

• Cap. 629, ss. 2, 4, 9, 11; Sch. 4

Mainland buyer (holder of a PBOC gold import qualification) obtains a PBOC Gold and Gold Products Import/Export Permit for the consignment: one shipment, one permit, used within 40 working days

执行方

Mainland importer holding a PBOC gold import qualification

出具

PBOC Gold and Gold Products Import/Export Permit (中国人民银行黄金及黄金制品进出口准许证)

• PBOC/GACC gold import-export measures, Arts. 3, 8, 17

Agree the sale with the Mainland importer and release bars (typically 999.9 kilobars or bank-refined bars) to the cross-boundary carrier

执行方

Registered bullion dealer / trader (DPMS registrant)

所需

PBOC Gold and Gold Products Import/Export Permit (中国人民银行黄金及黄金制品进出口准许证); Allocated account weight list

出具

Hong Kong exporter's commercial invoice; Packing list; Outbound air waybill / cross-boundary transport document

[unconfirmed] Bar form preferred by the Mainland market not confirmed from an opened source.

Lodge the Hong Kong export declaration within 14 days; C&SD records the flow as an export to the Mainland

执行方

Registered bullion dealer / trader (DPMS registrant)

所需

Hong Kong exporter's commercial invoice

出具

Hong Kong export / re-export declaration (Cap. 60E, lodged within 14 days)

C&SD FAQ Q1: Hong Kong is a separate customs territory, so a declaration is required for goods exported to the Mainland.

• Import and Export (Registration) Regulations (Cap. 60E), reg. 5(1)-(2)

Clear Mainland customs by presenting the PBOC permit, then register the gold on the State Council-approved gold spot exchange and complete its first trade there

执行方

Mainland importer holding a PBOC gold import qualification

所需

PBOC Gold and Gold Products Import/Export Permit (中国人民银行黄金及黄金制品进出口准许证); Hong Kong export / re-export declaration (Cap. 60E, lodged within 14 days); Export customs declaration accepted by the dispatching country's customs

This step happens under Mainland law and belongs to the China module; kept here to show the hand-off.

• PBOC/GACC gold import-export measures, Arts. 6, 17

Hold the PBoC gold import/export qualification (bank that is an SGE financial member or market maker, or qualified mining group or refiner)

执行方

Bank holding PBoC gold import/export qualification (SGE financial member or market maker)

• Gold and Gold Products Import/Export Measures, Arts. 7, 8, 10

Apply to the PBoC for a permit for the batch: application form, import contract and (on repeat applications) nothing further unless details changed

执行方

Bank holding PBoC gold import/export qualification (SGE financial member or market maker)

出具

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)

• Gold and Gold Products Import/Export Measures, Art. 10

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

执行方

People's Bank of China (permit issuer and reserve holder)

所需

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)

出具

PBoC permit (import batch)

• Gold and Gold Products Import/Export Measures, Arts. 3, 14-17

Pay the foreign seller through the bank under foreign-exchange rules

执行方

Bank holding PBoC gold import/export qualification (SGE financial member or market maker)

所需

Gold import/export contract (required with the permit application)

出具

Import payment through an FX-authorised bank

[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

Declare the gold to Customs (HS 7108) presenting the PBoC permit; import-stage VAT is exempt for gold (incl. standard gold) and gold ore

执行方

Bank holding PBoC gold import/export qualification (SGE financial member or market maker)

所需

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

出具

Customs import declaration (进口货物报关单), HS 7108

[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

Register the imported gold on SGE and complete its first trade there (duty to balance domestic physical supply)

执行方

Bank holding PBoC gold import/export qualification (SGE financial member or market maker)

所需

Customs import declaration (进口货物报关单), HS 7108

出具

SGE registration and first-trade record of imported gold; SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)

• Gold and Gold Products Import/Export Measures, Art. 6

Report execution of the permit to the PBoC

执行方

Bank holding PBoC gold import/export qualification (SGE financial member or market maker)

所需

PBoC permit (import batch)

出具

Report to PBoC on use of the import/export permit

• Gold and Gold Products Import/Export Measures, Art. 19

Receive and assay doré or raw gold under the refining or purchase agreement

执行方

SGE-accredited refiner (standard gold ingot / bar refiner)

所需

Refining Agreement (fee schedule, assay/settlement formula); VAT-exempt sales invoice for non-standard gold or gold ore (producer sale)

Chinese refiner intake practice not documented in sources read.

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

执行方

SGE-accredited refiner (standard gold ingot / bar refiner)

形态

Doré bar - unstamped → 999.9 kilobar

• SGE Detailed Delivery Rules; SGE Refiner Measures 2025, Delivery Rules Art. 11 and Annex 1; Refiner Measures arts. 2, 26-27

Issue the certificate of quality and packing list (bar list) for the bars

执行方

SGE-accredited refiner (standard gold ingot / bar refiner)

出具

Refiner's certificate of quality and packing list for SGE standard bars; Bar list (serials, weights, fineness)

• SGE Detailed Delivery Rules, Art. 30

Open an FT account at a margin custodian bank and trade International Board contracts (iAu99.99, iAu99.5) in offshore RMB

执行方

SGE international member or international client (SGEI, Shanghai FTZ)

出具

Free Trade (FT) account statement in offshore RMB (SGEI)

• SGE Member Management Measures (2026); SGEI Business Management Measures, Member Measures Arts. 3-4; SGEI Measures arts. 4, 20-21

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

执行方

SGE international member or international client (SGEI, Shanghai FTZ)

所需

Air waybill; Refiner's certificate for the bars it produced (serials, fineness, weights, year)

出具

IB vault entry papers; SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)

[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

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

执行方

SGE designated vault / International Board certified vault operator

[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

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

执行方

SGE international member or international client (SGEI, Shanghai FTZ)

出具

SGE Application for Load-Out and Application of Take-delivery

• 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

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

执行方

SGE comprehensive member (producer, processor, jeweller or trader)

所需

Refiner's certificate of quality and packing list for SGE standard bars; Bar list (serials, weights, fineness)

出具

SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)

• SGE Detailed Delivery Rules; Vault Measures, Delivery Rules Arts. 11, 29-31; Vault Measures Art. 4

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

执行方

SGE comprehensive member (producer, processor, jeweller or trader)

所需

SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)

出具

SGE trade and clearing record

• MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 point 1; SAT No. 23 point 1

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

执行方

SGE institutional client (e.g. jewellery manufacturer) trading through a member

所需

SGE trade and clearing record

出具

SGE Application for Load-Out and Application of Take-delivery

• SGE Detailed Delivery Rules, Arts. 37, 43, 45

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

执行方

Shanghai Gold Exchange (and SGEI)

所需

SGE Application for Load-Out and Application of Take-delivery

出具

SGE VAT special invoice labelled 会员单位投资性黄金 (member withdrawal for investment use)

• 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)

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)

执行方

SGE comprehensive member (producer, processor, jeweller or trader)

所需

SGE VAT special invoice labelled 会员单位投资性黄金 (member withdrawal for investment use)

出具

Member's input-VAT deduction on the SGE special invoice (VAT return schedule 2, after use confirmation)

• SAT Announcement 2025 No. 23; MOF/SAT Announcement 2025 No. 11, SAT No. 23 point 2(3)-(4); 2025 No. 11 point 1(1)

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

执行方

Shanghai Gold Exchange (and SGEI)

所需

SGE Application for Load-Out and Application of Take-delivery

出具

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)

• MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 point 1(2)-(3); SAT No. 23 points 3-4

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

执行方

SGE comprehensive member (producer, processor, jeweller or trader)

出具

Application to change declared use (investment / non-investment), once within 6 months

• MOF/SAT Announcement 2025 No. 11, Point 8

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

执行方

SGE institutional client (e.g. jewellery manufacturer) trading through a member

[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

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)

执行方

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

出具

Receipt of export proceeds

[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