Can This Cargo Actually Move?

Raw ore export banned — this route does not exist.

Indonesia has banned raw nickel ore exports since January 2020 with no relaxation since, to force smelting capacity onshore. The effect shows in the data: Indonesia does not appear at all among China’s nickel ore origins — 61% now comes from the Philippines. If a counterparty offers Indonesian nickel ore for China, that claim is itself the red flag. What can leave is processed material — NPI, matte, MHP — not ore.

Bauxite export banned; Guinea took over the volume.

Bauxite exports have been banned since June 2023, on the same logic as nickel: domestic refineries can absorb the tonnage that used to be exported. China now sources 79% of its bauxite from Guinea and 16% from Australia; Indonesia has vanished from the list.

Export volumes capped from April 2026 — and 79% of China’s bauxite rides on this one country.

Export volume caps take effect from April 2026, cutting an unconstrained run-rate of roughly 200 Mt to about 150 Mt a year, allocated by quota against three-year production plans, to support prices and protect smaller producers — while Guinea builds its own alumina capacity (five refineries planned, 7.2 Mt of alumina combined). This is not an admissibility problem but a volume-and-price one: long-term contracts need the cap written into the pricing terms rather than extrapolated from historical prices.

Export quota regime — whether they hold quota matters more than whether they hold material.

The blanket 2025 export ban has been replaced by quotas: 96,600 t for each of 2026 and 2027, of which 87,000 t is allocated pro rata to producers and 9,600 t is held at the discretion of the regulator, ARECOMS, to reward investment in local processing. ARECOMS has said quotas may be cut further if the market stays unbalanced. With 75% of China’s cobalt coming from the DRC, this quota is effectively global supply. The due-diligence question is not "how much material do you have" but "whose quota is this shipment moving under" — without quota, material that exists still cannot leave.

Tin concentrate flows (33% of China’s imports), but origin compliance in the eastern provinces is a hard requirement.

Tin concentrate sits outside the cobalt quota regime and the DRC is China’s largest source (33%). The risk here is not the export licence but origin: material from the eastern conflict provinces needs traceability (ITSCI or equivalent), and downstream smelters and end customers enforce this harder than customs does. Cargo without origin documents clears customs and then gets rejected by the buyer.

Copper concentrate falls under the same downstreaming policy, but the deadline has slipped repeatedly — re-check before quoting.

Copper concentrate was folded into the same downstreaming policy as bauxite, but the effective date has been pushed back repeatedly because domestic smelting capacity lagged. Unlike nickel and bauxite this is not a stable ban but a repeatedly deferred deadline — treat this row as a prompt to check the current notice, not as the answer.

Raw-ore exports banned since 2022, with a 30% local value-addition law advancing — ask how far the material has been processed.

Nigeria has banned exports of unprocessed ore since 2022, and mining licences now require a local processing plan; further legislation mandating at least 30% local value addition before any raw material is exported is advancing, with criminal and financial penalties for breaches. 17% of China’s tin concentrate comes from Nigeria, which shows processed material does leave — what cannot leave is pit-to-port raw ore. For Nigerian offers, establish how far the material has been processed and what export paperwork exists: "I have ore" and "I have concentrate I can legally export" are different claims here.

From 21 May 2027, EU scrap can only go to non-OECD destinations on an EU-approved list — China included.

The recast EU Waste Shipment Regulation (Regulation (EU) 2024/1157, in force 20 May 2024) phases in: most provisions from 21 May 2026, and the export rules from 21 May 2027. From that date, exporting green-listed waste (including copper and aluminium scrap) to non-OECD countries is permitted only where the destination country appears on an EU list — it must apply and demonstrate environmentally sound management — and exporters must commission independent audits. China is not an OECD member and falls under this rule. Practically: EU origins such as Spain (8% of scrap copper) and Belgium (5% of scrap aluminium) operate under a different regime after May 2027, so any contract spanning that date needs the point written in.

China’s No.2 scrap-copper and No.1 scrap-aluminium origin — but also a transit hub, with an expanding e-waste ban list.

Thailand supplies 26% of China’s scrap copper and 31% of its scrap aluminium — both top of the list — yet domestic arisings cannot support that volume: much of it is European and American material routed through, plus secondary smelting capacity that relocated from Malaysia. Thailand’s prohibited e-waste list grew from 428 categories in September 2020 to 463 items by June 2025, and the market expects imports may be restricted to domestic end-users to squeeze out intermediary traders. As with Malaysia: establish whether "Thai material" originates in Thailand or merely passes through.

Wa State halted mining in August 2023; output has been restarting since late 2025 — recovering, not recovered.

Myanmar supplies 22% of China’s tin concentrate, almost all from the Man Maw area in Wa State. The 1 August 2023 suspension cut supply off; shipments recovered to about 1,300 t of contained tin per month in Nov–Dec 2025 (against roughly 630 t/month in May–Oct), and in February 2026 the Wa authorities formalised dewatering cost-sharing across 11 mine portals, with further recovery from March. The uncertainty here is not policy but mine dewatering and local administration — confirm actual current shipments rather than treating nameplate capacity as available supply.

The transit route is tightening: COA plus SIRIM purity limits to get in, and a blanket e-waste import ban.

Malaysia accounts for 7% of China’s scrap copper imports, but it functions largely as a transit and pre-processing hub rather than a source of scrap. All scrap imports now need a Certificate of Approval with slow inspections; aluminium scrap faces SIRIM purity thresholds (since 2021); and after roughly MYR 7 bn of illegal scrap imports were seized in 2025, e-waste is banned outright — with cargo sitting at Port Klang for close to two years in some cases. For offers claiming material "in Malaysia", establish whether it was generated locally or is passing through: for transit cargo the choke point is Malaysian entry, not Chinese.

Open. The much-repeated "Philippines is banning nickel ore exports" never became law — the ban clause was struck out.

The Senate did pass a version of the bill in February 2025 banning unprocessed nickel ore exports by 2030, mirroring Indonesia — but that clause was subsequently removed from the mining bill, with the domestic industry association (PNIA) opposing it as premature. 61% of China’s nickel ore comes from the Philippines and the route is currently open. This status is a verified finding rather than an untested assumption — but it is also the row most likely to flip, so re-check it periodically.

Import declarations for recycled copper raw material must be accompanied by a quality certificate stating the supplier name, material name, total metal weight, contained copper weight, and the national standard it is declared against — all five, or the certificate does not count. The notice also refers to a pre-shipment inspection certificate, but that requirement is not yet in force: it cannot be demanded as a legal obligation today, though it can be written into the contract as a commercial term.

MEE and five other ministries, Announcement No. 23 of 2024; SN/T 5416-2022 (Inspection protocol for imported recycled copper raw material)

This is fixed at the moment of loading and cannot be fixed on arrival. The notice states that different categories of recycled copper and aluminium raw material may not be mixed in one load, a single customs declaration may not cover more than one category, and different categories of bulk material may not be commingled — separately packaged material may travel together but must be kept segregated. In practice: a container holding both recycled copper raw material and recycled copper alloy raw material (different customs codes) is simply wrong, so this must be agreed with the seller before loading, not renegotiated on arrival.

MEE and five other ministries, Announcement No. 23 of 2024 (in force 15 Nov 2024, superseding No. 43 of 2020)

Before shipment, a qualified overseas laboratory must test for radioactivity against GB 20664 (natural radioactivity limits for non-ferrous metal mineral products), with a bilingual Chinese/English report attached. This is a pre-shipment step, not something to be remedied on arrival — by the time an exceedance is found at the port, the cargo is already in China.

GB 20664-2006; China Customs field inspection requirements

First a sensory (visual) inspection; if that cannot establish compliance with the schedule, testing follows the customs technical specifications or the national standards (GB/T 38470 recycled brass, 38471 recycled copper, 38472 recycled cast aluminium alloy, 40382, 40386); and where customs suspects the material is solid waste, it may commission a specialist body to determine its classification and act on that determination. The third step is the worst case — a solid-waste classification means the whole shipment goes back, not that extra duty is charged. Which is why the first step is not a formality: appearance, contamination, oil and loading method decide whether a cargo escalates that far.

MEE and five other ministries, Announcement No. 23 of 2024, Articles 3 and 4

Under the customs radiation monitoring procedure, a cargo fails if its gamma dose equivalent rate exceeds ten times the local environmental background. Note that this is a relative threshold, not an absolute one — the benchmark is background at the port of discharge, so in principle the same cargo could be judged differently at different ports. Field inspection simultaneously checks for excess inclusions and for prohibited or foreign matter, with anomalies sampled and sent to a laboratory.

GACC Radiation Monitoring Procedure; GB 20664

This is the most expensive trap in arrival disputes. Since GACC Announcement 159 of 2019, weight determination for bulk commodity imports changed from being performed by customs on every consignment to being performed on the importer’s application. Likewise, a customs quality certificate requires selecting the one-off complete declaration mode and ticking the quality certificate option at declaration. Both third-party records must therefore be actively requested. Without them, a short weight or an under-grade cargo leaves the buyer holding only the seller’s documents and its own assay — neither of which is a neutral third party. Weighing method: weighbridge for containerised cargo; weighbridge or draft survey for bulk.

GACC Announcement No. 159 of 2019

A gap between the load-port assay and the discharge-port assay is normal, not exceptional. Contracts usually handle it one of three ways: load-port assay governs (favours the seller); discharge-port assay governs (favours the buyer); or the two are averaged, with a third-party umpire assay if the difference exceeds an agreed splitting limit. The third is the standard construction in bulk mineral trade and the only one that does not systematically favour one side. A buyer who insists on "we will sort it out when it lands" or "the usual practice" is often perfectly genuine — but what they are preserving is the right to renegotiate on arrival. This is industry practice, not law: unless it is in the contract, either side can decline to be bound by it.

The usual split: the seller pays for pre-shipment inspection (they are proving the cargo is as described), the buyer pays for the arrival check (they are verifying it), and whichever party’s figure deviates more pays for the umpire assay. No specific prices are quoted here on purpose: inspection fees vary by commodity, port, lot size and agency, and change faster than the rules do — a hard number would be wrong within months. For a quote, ask SGS, CCIC or BV at the time rather than citing a figure that has been sitting in a file for six months. For scale, pre-shipment inspection is small against the value of a shipment: skipping it to save that cost is the worst trade on this whole chain.

Disputes over concentrate usually land on grade and moisture and are settled in money. Recycled copper and aluminium raw material is different: a solid-waste classification sends the entire shipment back rather than discounting it. The leverage is therefore all in pre-shipment control of the cargo’s condition (no mixed loading, no oil or foreign matter, categorised against the national standard), not in negotiating price on arrival. The first half of this item is practice; the consequence of reclassification is law — see the arrival item above.