The 2026 non-state crude import allowance totals 257 million tonnes, but allocation carries a hard performance test: companies with no utilization record over the prior two years get no allowance the following year. Quotas flow back to the pool if holders cannot actually lift the barrels, so the barrier to becoming an import principal is capacity to use, not capital.

The allowance is an administrative grant to a named entity, not a tradable commodity. Transfer, lending and nominee holding are all prohibited, with violations handled under the Regulations on the Administration of Goods Import and Export and the Measures for the Administration of Automatic Import Licensing of Goods. For a trading house preparing an IPO, flipping quotas is a line that cannot be crossed — it would contaminate the compliance file.

SNSUC's structure was built to avoid that line entirely. The company sits as an offshore supplier and intermediary, contracting through a substantive Singapore or Hong Kong SPV, while the Chinese refiner clears customs and draws on its own quota. We sell title and delivered services, not the import-principal licence, which also keeps us clear of the terminal, storage and track-record thresholds that are hard to meet short term.