China runs a dual-track regime for crude imports, splitting state-trading and non-state-trading quotas. The non-state import allowance is approved annually by the commerce authority as an import qualification granted to specific firms, under an aggregate cap.

The allowance itself cannot be transferred, sold, lent, or held on behalf of another party. Borrowing or reselling quota breaches the management order and leaves a hard mark in any IPO or compliance review. To turn an allowance into real imports, the importer must itself meet thresholds for jetties, storage, track record, and credit lines.

For traders without Chinese import qualifications, the compliant route is to locate the entity offshore: a substantive Singapore or Hong Kong SPV signs the supply contract, while the Chinese refiner declares and imports under its own allowance. Funds and cargo complete delivery and settlement under the bank's "new-type offshore international trade" framework.

Pre-trade origin screening is a separate red line. Sanctioned origins are auto-denied and stay out of the trading pool; other origins are declared truthfully by load port and routing. Only when the allowance regime, the offshore SPV, and origin screening stack together does the resale structure withstand regulatory scrutiny.