Importing Sodium Cyanide from China
My first experience with exporting sodium cyanide from China dates back to 2007- 2008. A chemical distributor suddenly found itself without any sodium cyanide allocations from Dupont and engaged 300CC Asia Pacific Ltd to source cyanide from China. Apparently, United States legislators were concerned about an American company sending large quantities of sodium cyanide to an African dictator’s country.
There was a global shortage of sodium cyanide at the time and it was almost impossible to get, mainly due to the high prices of gold after the global financial crisis. New projects were being opened and current ones increased production to take advantage of the gold price. Gold mines in Zimbabwe depended on this distributor and had to scramble to get allocations. Other extenuating factors included the supplier taking advantage of the shortage and squeezing out every last dollar he could get from importers. Five (5) months later we finally made our first delivery.
Since that time, 300CC Asia Pacific Ltd/Kemcore has exported more than 10,000 tons of Sodium Cyanide from China.
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How to Import Sodium Cyanide from China
In 2001, China exported only 5284 tons of sodium cyanide. By 2009 exports began to catch up with imports and in 2013, China exported volumes of up to 77,054 tons of sodium cyanide, with a declared value of $ 248.55 million.
The process for exporting sodium cyanide from a producer country can seem complicated. Several years before the global financial crisis in October 2002, China developed procedures and policies regarding biological and chemical export control -- a licensing system for the export of dual–use agents, related equipment, and technologies and also a registration system for exporters. This means that any Chinese company involved in the biological and chemical production or trade cannot export without the permission from the central Chinese government.
China’s Export Control Law states that related equipment and technologies supplied by China shall not be used for purposes other than the declared end-use, or be retransferred to a third party other than the declared end-user.
The Export Control Law also provides strict procedures for export examination and approval and punishments for violations of the regulations. Besides protecting China’s national security interest, this law was also satisfies other international commitments.
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The term “dual-use items and technologies” means items and technologies that can be used both for civilian and military purposes. MOFCOM, jointly with GAC, maintains a catalogue or control list of Dual-use Items and Technologies that are subject to Import and Export License Administration. This list includes chemicals such as Sodium cyanide, TBP, HCL, etc
The export procedure for Sodium Cyanide is thus based on the regulation guidelines of ““dual-use items and technologies”.
Sodium Cyanide Supply chain:
Since Cyanide is one of the most profitable reagents/chemical in the mining supplies business, there are many sales layers involved which often renders the above ineffective.
Kemcore ensures that the importer has the required permits, and assumes that the local government strictly enforces the cyanide handling laws.
Exempt Countries
India, for example, doesn't need importers provide any import/export documents. Other countries including South Africa, USA, Canada, Peru, certificateColombia are not required to provide an "import license" for China.
How to obtain an export license for Sodium Cyanide
After securing a supplier, you will be requested to provide (two) 2 documents in original or hard copy format. These documents are:
- Import license: In the case of Sodium Cyanide, for countries like Zimbabwe, this document is issued by the ministry of mines. Importers would also have had to meet local regulations that govern the handling and sales of sodium cyanide.
- End UserCertificate: This is a declaration document to the “National Chemical Weapons Implementation Office” that is issued by the “importer”, - this document is issued by the mining company itself, or the chemical distributor.
The End User must declare that the cyanide is used only for the purposes declared in the certificate. It must also declare that it will not transfer the cyanide to any third parties unless permission is granted by the Chinese government.
The Sodium Cyanide Export Process
- Submit original documents to Kemcore/ supplier.
- Apply for Export Quota from CWC -- “National Chemical Weapons Implementation Office”
- Then submit CWC quota for an export license with MOFCOM.
- Apply for an environmental license with Ministry of Environment Protection.
- Apply for transport license from the local police station (for every shipment).
- Begin the export procedure.
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Accepting Institutions
Once the supplier receives hard copies of the “Import License” & “End Use & End User Certificate,” an application is then sent to MOFCOM.
- After the Export license has been issued, the exporter then files an application for “Environmental Management of Export of Toxic Chemicals. “
- Application materials or documents required from the importer: Import license, End User, and End-user certificate
- Application process and approval: 30- 45 days
- Once the export license is approved the export of Cyanide can start.
- The exporter also needs to apply for an “escort permit” from the local police department. All cyanide shipments delivered to port use a convoy system with an armed police escort. This includes support vehicles containing spill kits, medical staff, mechanic and safety officers or what is deemed as a complete emergency response team. Before the “Tianjin blast” exporters could warehouse the cyanide at the port. With the new laws, this is no longer possible. Every cyanide shipment is loaded immediately onto the vessel.
Changes in the export procedure after Tianjin port explosion
After the Tianjin port incident in August 2015, where ”700 tons” of cyanide were found in the blast area, all exports of cyanide were suspended for close to 2 months.
All export licenses had to be re-issued as the export port changed from Tianjin to Qingdao port. The move also had several implications as most end users ran out of Cyanide. Qingdao port is also much further from the 2 export factories in China- a 700km journey. This has increased the local transport cost from RMB1000 to RMB3000/ton. Another challenge is that cyanide can’t be stored at the port.
This explosion has had several repercussions. Firstly if a vessel is delayed or postponed the sodium cyanide load has to be sent back to the factory. Secondly, if a shipment is detained for "further inspection" and misses the vessel, the cargo is sent back to the factory. This adds a layer of cost to the supplier.
Document Exemptions
Certain countries are exempt from providing export documents. For example, an "End User/End-Use" declaration form from "importers" in South Africa, USA etc. is sufficient for the export license application. However, the documents should be notarised by a public notary.
In South Africa, the importer is also required to register with the Non-Proliferation Council. The export of cyanide from SA is under control of the Non-Proliferation of Weapons of Mass Destruction Act, 1993 (Act No. 87 of 1993) and its supporting notices.
For other countries including, Tanzania, Sudan, Iran etc., not only must they provide an "Import license" and "End Use/End User" certificate, these documents must also be notarized by the local Chinese embassy.
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