# A European buyer wants to verify a Chinese supplier of antim

_2026-11-10 14:54 · 30.3s_

SUPPLIER DUE DILIGENCE — ANTIMONY TRIOXIDE (Sb2O3, HS 2825.80)

Sector context first: since 15 Sep 2024 antimony and its oxides fall under Chinese dual-use export control (MOFCOM/GACC Announcement 2024 No. 33). Your supplier must hold a MOFCOM dual-use export licence; "we ship on a partner's licence" is a criminal-risk path. [VERIFY current list scope and any 2025 amendments before contracting.]

1. PUBLIC RECORDS TO CHECK (all free, Chinese-language)

1.1 National Enterprise Credit Information Publicity System — gsxt.gov.cn. Search the 18-digit Unified Social Credit Code. Pull: legal representative, registered vs paid-in capital, business scope (look for 生产/制造, not just 销售), shareholders, branches, administrative penalties, abnormal-operations list, serious-violation blacklist.
1.2 Credit China — creditchina.gov.cn. Cross-check penalties, tax non-compliance, customs violations.
1.3 Enforcement & judgments — zxgk.court.gov.cn and wenshu.court.gov.cn. Look for unpaid-judgment debtor status (失信被执行人) and product-liability or environmental suits.
1.4 Customs credit — credit.customs.gov.cn. Confirm the 10-digit customs registration code and AEO tier (advanced certified / general / dishonest).
1.5 Pollution permit platform — permit.mee.gov.cn, plus provincial EIA disclosure portals. A real Sb2O3 producer (roasting/volatilisation furnaces, baghouse, arsenic removal) must hold a 排污许可证. No permit = no plant.
1.6 CNIPA — trademark and patent search: does the "factory" hold any process patents or its own brand?
1.7 Commercial aggregators (Tianyancha / Qichacha / Aiqicha) for the ownership graph: shared phone/email/address with dozens of shell companies is the single most useful signal.
1.8 Satellite imagery (Google Earth / Sentinel-2 historic). Verify chimney stacks, ore yard, waste/tailings area, truck traffic. Compare with the stated plant area in m².

2. DOCUMENTS TO REQUEST

2.1 Business licence + legal rep ID; name on all documents must be character-identical.
2.2 Customs registration certificate and AEO status printout.
2.3 MOFCOM dual-use export licence (两用物项出口许可证) covering Sb2O3, plus exporter registration.
2.4 ISO 9001 / 14001 / 45001 — verify the certificate number on the issuing body's own database, not the PDF.
2.5 EU compliance pack: REACH registration status, SDS to EU 2020/878 (Sb2O3 is Carc. 2 — CLP labelling and dust-exposure controls apply), and confirmation of which SIEF/consortium the substance is registered under.
2.6 Specification sheet with real numbers: Sb2O3 assay (99.5% / 99.8%), As, Pb, Fe, whiteness, d50 particle size, LOI, moisture, packed density; plus a fresh SGS/BV/Intertek COA on your sample lot.
2.7 Process description and raw-material source: antimony ingot vs. ore concentrate, own smelting or toll-milling. Ask which province the furnaces sit in and who owns them.
2.8 Environmental permit, EIA approval, and safety-production licence where applicable.
2.9 Redacted customs declarations or bills of lading for the last 12 months (EU destinations), plus two EU buyer references you can call.
2.10 VAT general-taxpayer status and sample 增值税专用发票 — a trading shell often cannot issue a 13% special invoice for goods it does not produce.
2.11 Bank details where account holder name = business-licence name exactly; no personal or unrelated offshore account.
2.12 UBO disclosure and corporate chop/signatory authority.

3. EIGHT RED FLAGS THAT MEAN "TRADING COMPANY"

No. | Red flag | What it proves
1 | Address is an office suite or residential unit; no chimney, ore yard or baghouse on satellite | No production capability
2 | Business scope is 销售/贸易 only; registered capital RMB 1–5m with zero paid-in | Shell reseller
3 | Company under 3 years old, or repeated name/address/legal-rep changes | Identity laundering
4 | Refuses unannounced audit or live video of the furnace floor; "our plant is in another province" | Tolling/broker at best
5 | Quotes any purity you ask for; spec sheet has no As/Pb/d50 numbers | Cannot control assay
6 | Quotation entity ≠ contract entity ≠ bank account ≠ customs registrant | Fraud exposure
7 | No MOFCOM dual-use licence, or "we use a partner's licence" | Illegal export, seizure risk
8 | Pushes T/T to a personal or unrelated offshore account, refuses LC, wants >30% deposit with no pre-shipment inspection right | Payment fraud pattern

4. MINIMUM VERIFICATION SEQUENCE

4.1 gsxt + satellite + pollution permit, in that order — 30 minutes, kills most fakes.
4.2 Video audit of the furnace line with a random timestamp; then physical audit before deposit.
4.3 Contract with pre-shipment SGS inspection at the loading port, LC or escrow, and a dual-use licence number written into the contract as a condition precedent.

Unverified items above are marked [VERIFY]; treat announcement scope and licence requirements as a legal question for your EU counsel before you wire funds.

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