The Ministry of Commerce of the People's Republic of China (MOFCOM) has issued Announcement 2025-No. 68, imposing stringent conditions on the export of three critical minor metals - tungsten, antimony and silver - for the period 2026-2027. The move reflects China's intensifying resource-security agenda and tighter export controls over strategic materials.

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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 (白银) 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.

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Procedural steps

Applicants must submit documents to their provincial commerce authorities, who compile regional lists and submit to MOFCOM by November 12, 2025. After MOFCOM's 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).

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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.

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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.

  • China's move underscores its broader shift toward resource nationalism and strategic export control - a theme increasingly central to geopolitical risk in raw-material markets.

  • For silver as a commodity, the policy may contribute to an upstream "squeeze" if production continues but export access is filtered, possibly underpinning higher silver prices or increased premium for non-Chinese sources.

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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 Beijing's resource-security strategy and may have material repercussions for global silver supply, industrial users and precious-metal market dynamics.

About the Author

Vincent Lanci is a commodity trader, Professor of MBA Finance (adj.) , and publisher of the GoldFix newsletter.

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