SNSUC holds exactly one legal identity in crude trading: an offshore supplier and reseller. The Ministry of Commerce sets hard gates on import allowance — qualifying use performance or crude-use eligibility in the prior two years, no less than 50,000 tonnes of jetty rights, no less than 200,000 cubic metres of tankage, bank credit of at least 20 million US dollars, plus customs registration and a string of other licences. SNSUC cannot meet the jetty, tankage and track-record items in the short run, so by design it does not act as the China-side import filing entity.

The operating structure: a Singapore or Hong Kong SPV with real office, staff and decision-making signs the supply contract, title transfers offshore, and the Chinese refiner files the import and consumes its own quota as the actual importer. SAFE's due-diligence process has accepted this path, processed under new-type offshore trade for receipts and payments, giving both the bank and the refiner a clear compliance anchor.

One caveat: import allowance itself cannot be transferred, sold or held on behalf of another party. If a refiner cannot use its full quota in a year, it must return the unused portion to the Ministry by 1 September, and entities with no usage track record in the prior two years get no allocation the next year. SNSUC only handles supply and title arrangement; quota use and return stay with the refiner, which is precisely what keeps SNSUC clear of the import-entity red line.