The market often conflates the import allowance with the right to import crude. The allowance is the quota number allocated by the Ministry of Commerce; the right to import is a separate gate. To obtain crude-import qualification a firm must first prove intake capacity: a coastal wharf of at least 50,000 tonnes, crude tankage of no less than 200,000 cubic metres, and a track record of imports or usage over the recent two years.

These three are physical gates, not administrative quotas. A refiner without a matched wharf cannot even discharge the cargo; insufficient tankage forces costly third-party storage or short-haul buying, raising both capital occupation and loss. The two-year track-record clause alone ejects the quota-as-shell players - the Ministry stops allocating allowance to firms with no performance the following year.

The implication for SNSUC is clear: we do not pursue importer-of-record status (nor can we meet the wharf, tankage and track-record tests near term). Instead, an offshore SPV acts as the supplier, and a qualified domestic refiner clears customs and consumes its own quota. Splitting the compliance entity from the supply entity simply sidesteps the three gates.

In practice, watch two variables: the quota-execution rate of qualified refiners (it caps how much we can supply) and the seasonal tightness of wharves and tanks (it sets discharge rhythm and demurrage). Both move the real landed cost of a transshipment deal more than the daily Brent tick.