GFN ÔÇô BEIJING
The Ministry of Commerce of the PeopleÔÇÖs Republic of China (MOFCOM) has issued Announcement 2025-No. 68, imposing stringent conditions on the export of three critical minor metals ÔÇö tungsten, antimony and silver ÔÇö for the period 2026-2027. The move reflects ChinaÔÇÖs intensifying resource-security agenda and tighter export controls over strategic materials.
The announcement, published on October 26, 2025, defines the application conditions and procedures for Chinese state-trading enterprises to export tungsten, antimony and silver during the 2026-2027 period. The move is framed as part of resource-and-environment protection efforts and export administration under the Trade Law and the Import & Export Goods Regulation.
Focus on Silver
The section on silver (þÖ¢ÚôÂ) outlines rigorous eligibility criteria for both production and trading firms:
- For production enterprises: they must be legal persons, hold export qualification, and have actual silver export performance every year from 2022-2024 (or since gaining qualification). For new applicants, the 2024 year-end domestic production threshold is at least 80 tonnes (40 t in western regions).
- For circulation/trading enterprises: they must also be legal persons, meet annual export performance for 2022-2024, hold ISO9000 certification, abide by tax/customs/forex laws, and have no unresolved illegal violations.
Procedural steps
Applicants must submit documents to their provincial commerce authorities, who compile regional lists and submit to MOFCOM by November 12, 2025. After MOFCOMÔÇÖs review and 7-day public disclosure of approved firms, final qualification and list release follow. Documentation requirements include: commitment letters, business licenses, customs codes, quality & environment certifications, social insurance payment proof, and production/export proof (for silver: 2024 production proof).
GoldFix Interpretation
This regulatory tightening signals that China is filtering the pool of firms eligible to export these strategic minor metals. The threshold of 80 t production for silver firms (less in western regions) effectively limits export access to larger, integrated producers. Combined with firm-specific certification and compliance records, the policy erects higher barriers to entry.
For silver, which plays a dual role in both industrial uses (photovoltaics, electronics, battery and conductive applications) and precious-metal stores, this measure appears designed to retain more upstream control over a critical input and to moderate export flows in favor of domestic strategic priorities.
Implications
- Export supply of Chinese silver may become more concentrated among a smaller number of qualified firms, potentially tightening global access and raising the global price risk premium.
- End-users in industrial supply chains (PV, electronics) reliant on Chinese silver could face greater sourcing risk or higher costs.
- ChinaÔÇÖs move underscores its broader shift toward resource nationalism and strategic export control ÔÇö a theme increasingly central to geopolitical risk in raw-material markets.
- For silver as a commodity, the policy may contribute to an upstream ÔÇ£squeezeÔÇØ if production continues but export access is filtered, possibly underpinning higher silver prices or increased premium for non-Chinese sources.
Bottom Line:
With Announcement 2025-No. 68 the Ministry of Commerce has set forth an export-licensing regime that tightens access for silver exports from China, favoring larger, compliant producers and restricting smaller entrants. This aligns with BeijingÔÇÖs resource-security strategy and may have material repercussions for global silver supply, industrial users and precious-metal market dynamics.
