Mineral trading is the stage where illegal minerals blend into the legal chain, so the law places an origin-proof burden on every transaction: ore without invoices and origin documents is not merely hard to sell — it drags buyer, carrier and exporter into the same enforcement net. For a trading company, the origin file is not red tape; it is the condition for the goods to exist lawfully in its warehouse.
What an origin file for a mineral lot contains
A lawful lot must trace back to a mine holding a valid exploitation licence, shown through a purchase contract with the mine owner or a trader with lawful supply, e-invoices under Decree 123/2020/ND-CP, transport documents and volumes consistent with the mine’s licensed output. The technical point is chain consistency: a trader’s purchase volumes cannot exceed what the source mine could lawfully supply in the period. Tax and market regulators cross-check exactly this point when inspecting a buying point — and it is how illegal minerals get caught even when the invoices look complete on the surface.
Sanctions for trading minerals of unclear origin
Buying, transporting or consuming minerals without lawful origin is fined under Decree 36/2020/ND-CP, with sanctions including value-based fines, confiscation of all violating minerals and possible confiscation of transport vehicles in statutory cases. On the tax side, purchases without valid invoices earn neither deductible costs nor input VAT credit — a double loss: the goods are confiscated and the cost is disallowed at finalisation. Goods already resold before detection also trigger civil compensation disputes down the supply chain.
Exporting minerals: proving origin at the border
For exports, the origin file forms part of the customs dossier: customs and specialised inspectors may require the source mine’s exploitation licence, contracts, invoices and transport documents for the whole chain from mine to port. A shipment that cannot prove origin is held from clearance and investigated back toward the exporter. Exporters buying through several trader layers should build origin warranties and recourse rights into purchase contracts, plus a right to inspect the source mine’s file before payment.
A control system for buying companies
Professional buying companies run three control gates: supplier approval using the mine licence and output capacity before signing framework contracts; per-lot document checks, refusing goods missing invoices or exceeding the source mine’s plausible output; and lot-level traceability files kept through the post-clearance audit and tax inspection window. These gates both protect the company from sanctions and evidence good faith when a single lot in the chain turns out to be tainted by the supplier.
Frequently Asked Questions
Are invoices required when buying ore from a mine?
Yes. Mineral purchases need e-invoices under Decree 123/2020/ND-CP plus contracts and transport documents tracing back to a validly licensed mine. Buying without invoices risks confiscation of the goods, disallowance of deductible costs and loss of input VAT credit.
What is the penalty for trading minerals of unclear origin?
Buying, transporting or consuming minerals of unclear origin is fined under Decree 36/2020/ND-CP by goods value, with confiscation of all violating minerals and possible confiscation of vehicles in statutory cases — on top of adverse tax consequences at finalisation.
How is origin proven when exporting minerals?
The exporter must produce the mine-to-port document chain: the source mine’s exploitation licence, purchase contracts, invoices and transport documents in matching volumes. Customs may hold clearance for inspection where the origin file is incomplete or inconsistent.
This article has been quality-reviewed by the FLAW AI Legal Council