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Importing gold into the European Union: Regulation 2017/821, VAT on investment gold and customs
Regulation (EU) 2017/821 places its duties on the Union importer that declares gold for free circulation above 100 kg a year, not on a seller abroad. Investment gold of at least 995 thousandths is exempt from VAT across the EU; doré is not investment gold. The third-country customs duty on unwrought gold is 0%. This is a summary of official texts read on 2 November 2026, not legal advice. Rules change and member states differ, so confirm each point with an adviser or customs broker in the importing state.
Who the regulation binds
Regulation (EU) 2017/821 lays down supply-chain due-diligence obligations for Union importers of tin, tantalum, tungsten and gold. A Union importer is the person declaring the minerals or metals for release for free circulation, or the person on whose behalf that declaration is made. The Regulation does not apply to an importer whose annual import volume of a mineral or metal is below the Annex I threshold, and it does not apply to recycled metals except for the disclosure in Article 7(4). The importer duties in Articles 4 to 7 have applied since 1 January 2021.
The Annex I thresholds for gold, as amended by Delegated Regulation 2020/1588, are:
| Annex I line | CN code | Volume threshold (kg a year) |
|---|---|---|
| Gold ores and concentrates (Part A, minerals) | ex 2616 90 00 | 4 000 000 |
| Gold, unwrought or in semi-manufactured forms, or in powder, with a gold concentration lower than 99.5% that has not passed the refining stage (Part A, minerals) | ex 7108 | 100 |
| Gold, unwrought or in semi-manufactured forms, or in powder form, with a gold concentration of 99.5% or higher that has passed the refining stage (Part B, metals) | ex 7108 | 100 |
The Regulation addresses the Union importer. It does not bind an exporter in Uganda, and it names no exporting country. The Commission's own explanation is that it applies to EU importers of these minerals and metals "no matter where they originate". A Ugandan seller meets the Regulation through the importer's questions and contract terms, not directly. Each member state designates a competent authority, which carries out ex-post checks, including on-the-spot inspections at the importer's premises, and issues a notice of remedial action where it finds an infringement.
The importer's duties step by step
| Step | What the Regulation requires of the importer | What they will ask a Ugandan seller for |
|---|---|---|
| Article 4, management system | A supply-chain policy consistent with Annex II of the OECD Due Diligence Guidance, communicated to suppliers and the public; senior-management responsibility; records kept at least five years; the policy incorporated into supplier contracts; a grievance mechanism | Acceptance of the policy in the contract; a named contact; consent to records being kept |
| Article 4(f), chain of custody for minerals | Description and trade name; supplier name and address; country of origin; quantities and dates of extraction; and, for conflict-affected and high-risk areas, the mine of origin, where the gold was consolidated, traded and processed, and the taxes, fees and royalties paid | Mine and licence identity, purchase records, the export permit, evidence of fees paid, and an unbroken set of custody documents |
| Article 4(g), chain of custody for metals | The names and addresses of the smelters and refiners in the chain, and their third-party audit reports or evidence of a recognised scheme; failing that, the countries of origin of the minerals | The refiner's identity, its audit reports and the origin of its feed |
| Article 5, risk management | Identify and assess risks against the policy; report to senior management; respond by continuing trade with mitigation, suspending trade, or disengaging after failed mitigation; consult suppliers and stakeholders on the plan | Answers to red-flag questions, access for site visits, and acceptance that trade may be suspended |
| Article 6, third-party audit | An independent audit of the importer's due diligence; importers of metals are exempt where all their smelters and refiners are on the Commission's list under Article 9 | Documents that will be seen by the importer's auditor |
| Article 7, disclosure | Audit reports to the competent authority; information to downstream purchasers; an annual public report on due diligence | Agreement that supply details may be summarised publicly |
For the documents a Ugandan lot should carry, see what each export document should prove, gold chain of custody and the ICGLR certificate. For checking the seller itself, see how to check a Ugandan gold supplier.
Minerals or metals: where Ugandan gold falls
The Regulation treats gold below 99.5% that has not passed the refining stage as a mineral, and gold of 99.5% or higher that has passed it as a metal. Doré therefore sits in Part A, where the importer's chain-of-custody record runs to the mine and the importer's own system is audited. A refined bar sits in Part B, where the importer records the refiner and relies on the refiner's audit, and may be exempt from its own audit if every refiner in its chain is on the Commission's list of global responsible smelters and refiners. We did not read that list, so we do not say whether any Ugandan refiner appears on it. See gold doré and refined gold bars.
VAT: investment gold versus doré
| Point | What the Directive says | Limit |
|---|---|---|
| Investment gold | Gold in the form of a bar or wafer of weights accepted by the bullion markets, of a purity equal to or greater than 995 thousandths (Article 344(1)) | Member states may exclude bars or wafers of 1 g or less (Article 344(2)) |
| Exemption | Member states shall exempt from VAT the supply, the intra-Community acquisition and the importation of investment gold (Article 346) | Producers and transformers of investment gold may opt to tax supplies to another taxable person (Article 348) |
| Records | Traders in investment gold keep accounts of all substantial transactions and documents identifying their customers for at least five years (Article 356) | Member states may impose stricter record rules |
| Doré and gold below 995 | Outside the Article 344 definition on its face, so import VAT applies at the importing state's rate | We did not confirm any member state's rate or any national relief for gold destined for refining |
Customs duty
The EU's TARIC database, at a reference date of 2 November 2026, shows the third-country duty for code 7108 12 00 (gold, non-monetary, other unwrought forms) as 0%, applicable since 1 January 2005. The same page carries a footnote reminding importers that they must comply with the due-diligence obligations of Regulation 2017/821 and keep documentation demonstrating compliance, including third-party audit results. It also shows origin-based prohibitions on gold from Russia and, from 15 July 2026, from Sudan. No entry names Uganda.
The CAHRA question for Ugandan gold
The Regulation defines conflict-affected and high-risk areas as areas in a state of armed conflict or fragile post-conflict, and areas witnessing weak or non-existent governance and security and widespread and systematic violations of international law, including human rights abuses. The Commission commissions external experts to keep an indicative, non-exhaustive and regularly updated list of such areas, and the Regulation states that importers sourcing from areas not on the list keep their due-diligence duties. The list is published by RAND Europe on a site funded by the Commission.
We did not read whether Uganda is on the list: the site places the list behind a terms page we did not accept, and we do not state its content either way. Even if Uganda were absent, an importer applying Article 5 would weigh the United Nations finding: Uganda recorded about 62 tonnes of gold exports in 2025, and UN experts assessed that the rise was largely attributable to gold originating in the Congo. Gold declared as Ugandan therefore raises a transit-country question under the importer's own risk assessment. See Uganda's production and export figures.
The Ugandan side of the shipment
Under Uganda's Act, each consignment needs an export permit. The copy of Uganda's 2024 export regulations we reviewed states a minimum of 99.9% gold for exports (S.I. 30 of 2024, regulation 3). We have not confirmed that it is currently in force, and we found no exemption for doré. This is a regulatory requirement, not a product specification, and a buyer's acceptance of any material is a separate matter. Qualified Ugandan legal advice is still needed on how it applies today. See how gold is lawfully exported from Uganda and how to check a Ugandan gold supplier.
What we could not confirm
- Whether Uganda appears on the current indicative CAHRA list
- The content of the Commission's list of global responsible smelters and refiners under Article 9, and whether any Ugandan refiner is on it
- The competent authority in any given member state, and each state's rules on infringement
- Member-state VAT rates on gold that is not investment gold, and any national relief for gold imported for refining
- How a particular doré consignment would be classified between heading 7108 and heading 2616 at import
- National anti-money-laundering cash limits and dealer registration rules, which sit outside the texts read
Where Uganda Gold Report stands
Uganda Gold Report is developing documented gold-sourcing routes and welcomes enquiries from qualified international buyers. Product availability, specifications, seller authority and export eligibility are subject to independent verification and applicable regulatory approvals. We do not supply the European Union, and we have no buyers, refiners or partners there; we hold no stock and no Ugandan licence. If you are a buyer with a genuine requirement, send us your specification and delivery point. We reply with what can and cannot be quoted at this stage.
Questions buyers ask
Does the EU Conflict Minerals Regulation apply to a seller in Uganda?
Not directly. Regulation (EU) 2017/821 binds the Union importer that declares gold for free circulation above the Annex I threshold of 100 kg a year. A Ugandan seller meets it through the importer's contract terms and its requests for origin, licence, permit and custody documents.
What is the volume threshold for gold under Regulation 2017/821?
Annex I sets 100 kg a year for unwrought gold under heading 7108, both below 99.5% unrefined (a mineral) and at 99.5% or higher refined (a metal), and 4 000 000 kg for gold ores and concentrates under 2616 90 00. An importer below the threshold for a line is outside the Regulation for that line.
Is imported gold subject to VAT in the EU?
Investment gold, meaning bars or wafers of weights accepted by the bullion markets and a purity of at least 995 thousandths, is exempt from VAT on importation under Article 346 of Directive 2006/112/EC. Doré and gold below 995 fall outside that definition, so import VAT applies at the importing state's rate, which we did not confirm.
What customs duty applies to gold entering the EU?
TARIC shows a third-country duty of 0% on code 7108 12 00, other unwrought gold, at a reference date of 2 November 2026. The same page notes the Regulation 2017/821 due-diligence obligation and origin-based prohibitions on gold from Russia and Sudan; no entry names Uganda.
Is Uganda a conflict-affected and high-risk area under the Regulation?
We did not read the indicative list, which sits behind a terms page, so we do not say either way. The Regulation itself says importers sourcing from unlisted areas keep their due-diligence duties, and the UN finding that Uganda's 2025 exports were largely attributable to Congolese gold is what an importer's risk assessment will weigh.
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Send the gold form, fineness, quantity, delivery point and the documents you require. We reply by email with what can and cannot be quoted at this stage, and on what basis.
Sources for the figures and rules on this page
Evidence for this page
Each statement is labelled by the strength of its evidence and dated. How we label evidence.
| Statement | Evidence | Source | Checked |
|---|---|---|---|
| Article 1(2) and (3): the Regulation lays down due-diligence obligations of Union importers of minerals or metals containing or consisting of tin, tantalum, tungsten or gold, and does not apply where the importer's annual import volume of each mineral or metal is below the Annex I threshold. Article 1(6): with the exception of Article 7(4), it does not apply to recycled metals. Article 2(f): conflict-affected and high-risk areas are "areas in a state of armed conflict or fragile post-conflict as well as areas witnessing weak or non-existent governance and security, such as failed states, and widespread and systematic violations of international law, including human rights abuses". Article 2(l): a Union importer is a person declaring minerals or metals for release for free circulation, or on whose behalf such declaration is made. Annex I as amended by Delegated Regulation (EU) 2020/1588: gold ores and concentrates, ex 2616 90 00, 4 000 000 kg; gold with a concentration lower than 99,5 % that has not passed the refining stage, ex 7108, 100 kg (Part A); gold of 99,5 % or higher that has passed the refining stage, ex 7108, 100 kg (Part B). | Official | Regulation (EU) 2017/821, consolidated text of 19 November 2020, EUR-Lex; read in the browser pane | |
| Article 4: supply-chain policy consistent with Annex II of the OECD Due Diligence Guidance, communicated to suppliers and the public; senior-management responsibility and records for a minimum of five years; policy incorporated into supplier contracts; grievance mechanism; chain of custody for minerals recording description, supplier name and address, country of origin, quantities and dates of extraction, and for conflict-affected and high-risk areas the mine of origin, locations of consolidation, trading and processing, and taxes, fees and royalties paid; for metals, the names and addresses of smelters and refiners and their audit reports or scheme evidence. Article 5: identify and assess risks; report to senior management; continue trade with mitigation, suspend, or disengage; consult suppliers and stakeholders. Article 6: independent third-party audit; importers of metals exempt where sourcing exclusively from smelters and refiners listed under Article 9. Article 7: audit reports to competent authorities; information to downstream purchasers; annual public report. | Official | Regulation (EU) 2017/821, Articles 4 to 7, consolidated text of 19 November 2020 | |
| Article 9: the Commission adopts implementing acts establishing the list of names and addresses of global responsible smelters and refiners and makes it publicly available. Article 10: each member state designates one or more competent authorities; the Commission publishes the list. Article 11: competent authorities carry out ex-post checks, which should include on-the-spot inspections at the importer's premises. Article 14(2): the Commission calls on external expertise for "an indicative, non-exhaustive, regularly updated list of conflict-affected and high-risk areas"; importers sourcing from areas not on the list "shall also maintain their responsibility to comply". Article 16: member states lay down rules on infringements; competent authorities issue a notice of remedial action. Article 20(3): Articles 4 to 7 apply from 1 January 2021. | Official | Regulation (EU) 2017/821, Articles 9, 10, 11, 14, 16 and 20, consolidated text of 19 November 2020 | |
| The Commission's explanation: the Regulation applies directly to companies that import tin, tungsten, tantalum and gold into the EU "no matter where they originate"; the requirements for EU importers apply from 1 January 2021; the list of conflict-affected and high-risk areas is indicative and non-exhaustive, so companies must comply when operating in unlisted areas; the Regulation applies directly to between 600 and 1,000 EU importers; a 1 December 2025 award notice concerns the CAHRA list. | Official | European Commission, Directorate-General for Trade, Conflict Minerals Regulation: the regulation explained; read in the browser pane | |
| The CAHRA website "presents an indicative, non-exhaustive, and regularly updated list of conflict-affected and high-risk areas" under Regulation 2017/821, developed with EU funding and maintained by RAND Europe; "importers sourcing from areas which are not mentioned on the list presented on this website remain responsible for complying". The list itself sits behind a terms-acceptance page that we did not accept, so its content was not read. | Official | cahraslist.net, landing page; read in the browser pane | |
| Article 344(1)(1): investment gold means "gold, in the form of a bar or a wafer of weights accepted by the bullion markets, of a purity equal to or greater than 995 thousandths"; Article 344(2): member states may exclude small bars or wafers of 1 g or less. Article 346: member states shall exempt from VAT the supply, the intra-Community acquisition and the importation of investment gold. Article 348: producers and transformers may opt for taxation of supplies to another taxable person. Article 356: traders keep accounts of all substantial transactions and customer-identification documents for at least five years. | Official | Council Directive 2006/112/EC on the common system of value added tax, Title XII, Chapter 5, consolidated text of 1 January 2025, EUR-Lex; read in the browser pane | |
| TARIC, goods nomenclature code 7108120000, reference date 02-11-2026, last update 30-10-2026: "Third country duty (01-01-2005 - ): 0 %" (R2261/98). Footnote TN092: Union importers shall comply with the due-diligence obligations of Regulation (EU) 2017/821 and keep documentation demonstrating compliance, including third-party audit results. Import controls shown for Russia (gold exported from Russia after 22 July 2022, R0833/14) and Sudan (gold exported from Sudan after 15 July 2026, R2147/23). No entry names Uganda. | Official | European Commission, Taxation and Customs Union, TARIC measure information; read in the browser pane | |
| Uganda recorded gold exports of about 62 tonnes in 2025; the UN experts assessed the rise as largely attributable to gold originating in the Congo. | Official | UN Group of Experts on the DRC, final report, June 2026 (S/2026/466), para. 212; local text copy re-read 2 Nov 2026 | |
| Regulation 3 states: "A person shall not export gold out of Uganda unless the gold is at a minimum purity level of 99.9% Au." Made 9 May 2024; Statutory Instruments Supplement No. 15 of 24 May 2024. Current force not confirmed. | Official | Mining and Minerals (Export of Refined Gold) Regulations 2024, S.I. 30 of 2024, regulation 3; scanned copy on the mining directorate (DGSM) website, read 31 Oct 2026 |