To strengthen the management of critical minerals, starting in 2026, China’s silver export officially enters the era of “single batch, single approval“. All exporting enterprises must first obtain qualification, then secure permits, significantly raising the entry barrier and tightening the process. How should enterprises respond? Please refer to this comprehensive analysis.
I. Core Regulatory Changes: From “Filing” to “Approval”
Previously, qualified enterprises could export silver after completing a filing process. Now, they must pass “two hurdles“:
1. Enterprise Entry Hurdle: First, apply for the “Silver Export Qualification“. Only after approval can an enterprise be included in the Ministry of Commerce’s (MOFCOM) filing list.
2. Export Approval Hurdle: Before each export, an Export License must be applied for individually for each contract, i.e., “single contract, single review“.
The regulations are based on MOFCOM Announcements No. 68 and No. 69 of 2025, which took effect on January 1, 2026.
II. Who Can Get the “Entry Ticket”? Qualification Thresholds at a Glance
| Dimension of Impact | Specific Content | Affected Parties |
| Tightened Entry Criteria | Producers (New Applicants): Require annual silver production exceeding 80 tons in 2024 (relaxed to over 40 tons in Western regions). Existing Qualified Enterprises: Must have actual export performance in each year from 2022 to 2024. | SMEs, new market entrants |
| Comprehensive Compliance | Requires enterprises to pass system certifications like ISO9000 (Quality) and ISO14000 (Environment), and strictly comply with safety production, social security, tax, foreign exchange regulations. | All applying enterprises |
| Limited Number of Exporters | The number of enterprises granted export qualification for the 2026-2027 period has been set at 44. | Overall industry landscape |
| International Supply Chain Volatility | As a major global supplier, China’s control measures may impact international silver supply, potentially intensifying price fluctuations. | Downstream international customers |
III. Applying for Qualification: What Should Enterprises Do?
1. Step 1: Self-Assessment for Compliance
Verify if production volume, export records, and system certificates are complete and ensure there are no compliance violations.
2. Step 2: Prepare Application Materials
Business license, Customs code, system certifications, production volume proof, tax payment certificates, etc.
3. Step 3: Submit the Application
Submit to the provincial-level commerce department (central SOEs report directly to MOFCOM), which will then submit collectively.
4. Step 4: Monitor the Public List
MOFCOM will publish a preliminary review list (7-day public notice period). The final filing list will be publicly released.
✅ Key Reminder:All regulatory details are subject to ”MOFCOM Announcements No. 68 and No. 69 of 2025″.
IV. What is “Single Contract, Single Review”? How to Operate?
Obtaining qualification is just the first step; “single contract, single review” is required before each export:
● What it is: Each export contract corresponds to one Export License. No export is allowed without the license.
● Where to apply: Apply online through MOFCOM’s “Foreign Trade Operator Filing and Registration Application” system.
● Required Materials:
(1) Proof of enterprise export qualification
(2) Export License Application Form
(3) Original or copy of the foreign trade contract
(4) Importer information (sometimes required)
● What is reviewed: Besides the authenticity of materials, aspects like price, quantity, and end-user will be assessed to ensure alignment with national policy.
⚠️ Warning: If false declarations, contract forgery, etc., are discovered, not only will the single license be revoked, but the export qualification may also be permanently cancelled.
V. Enterprise Action Checklist: A Three-Step Approach for Smooth Compliance
| Phase | Action Items | Key Points & Objectives |
| Qualification Self-Assessment Phase | 1. Check compliance with production capacity and performance requirements per Announcement No. 68. 2. Verify all system certifications (ISO9000/14000) are complete and valid. 3. Review records for tax, social security, environmental compliance, ensuring no violations. | Confirm eligibility to apply for the “entry ticket”. |
| Application Preparation Phase | 1. Contact provincial commerce authorities for the latest application guidelines. 2. Systematically prepare all required supporting documents as per the announcements. | Ensure the application materials pass review on the first submission, avoiding back-and-forth. |
| Post-Qualification Phase | 1. Organize training for trade and customs teams on the export license application system and process. 2. Establish internal contract review and license application verification mechanisms. 3. Closely monitor industry trends and potential policy adjustments. | Ensure every “single contract, single review” is compliant and efficient, mitigating risks. |
VI. Policy Background: Why the Tightening Now?
● Domestic Level: China has been continuously strengthening export controls on critical metals like tungsten, antimony, and silver in recent years to safeguard resource security and industrial health.
● International Level: In November 2025, the US added silver to its Critical Minerals List, highlighting its strategic importance and intensifying global resource competition.
Summary Reminders
Starting in 2026, silver export is no longer a simple process. Enterprises must:
1.First, obtain qualification – Strict entry control.
2.Then, secure permits – Approval required for each shipment.
It is recommended that relevant enterprises immediately initiate self-assessment and application processes to adapt to the new regulations early and avoid business disruption. Compliance is key to sustainable operation.。
Appendix: Full Process Diagram for Export Qualification Application and “Single Contract, Single Review”
Post time: Jan-12-2026