What origin proof is required to import doré gold into the EU?

Rule lines

commodity code

7108 12 00 — other unwrought forms of non-monetary gold. Both doré and refined bullion bars sit on this line; the Combined Nomenclature does not split them by purity.

third-country duty

0% (Free). Every CN 7108 line, including 7108 12 00, carries a conventional duty rate of free, for every country of origin.

preferential origin

Buys nothing on duty here. A preferential rate cannot go below the third-country rate, and the third-country rate is already 0%.

non-preferential origin

Must still be declared on every EU import declaration, under article 60 of the Union Customs Code. This field does not exist for duty; it exists for sanctions, statistics and trade-remedy screening.

due diligence

Regulation (EU) 2017/821, Annex I, Part A: doré (below 995‰, not yet refined) is coded ex 7108 and treated as a mineral. Article 4 to 7 obligations apply past 100 kg a year.

Russia ban

Council Regulation (EU) No 833/2014, article 3o, in force since 22 July 2022. Gold originating in Russia and exported from Russia after that date is banned on entry, direct or indirect.

Every line above was verified on 2026-09-07. Sanctions lists and due-diligence thresholds move; the date is part of the rule.

Why a duty-free line still needs an origin proof

Every subheading of CN 7108 carries a 0% third-country duty. A preferential origin proof cannot beat that rate, so it buys nothing on the duty owed.

Non-preferential origin is a different field, and it is not optional. Article 60 of the Union Customs Code requires it on every release for free circulation, for sanctions and statistics.

A dossier that leads with an EUR.1 certificate and skips the non-preferential declaration has answered the wrong question.

The due-diligence split doré falls into

Regulation (EU) 2017/821, Annex I, treats doré gold — below 995‰, not yet through refining — as a mineral, coded ex 7108. Refined gold at 995‰ or above is treated as a metal, on the same CN code.

That split matters past 100 kilograms a year. A mineral-category importer faces the article 4 to 7 obligations directly, including an independent third-party audit, with no exemption route.

Refined-gold importers can be exempted from that audit if every smelter or refiner in the chain already carries its own audit. A doré pack cannot lean on that exemption.

The Russia-gold ban sits at the border, not in the tariff

Since 22 July 2022, article 3o of Council Regulation (EU) No 833/2014 bans importing gold that originates in Russia. The ban covers gold exported from Russia after that date, direct or indirect.

Processed gold is covered too. If Russian-origin gold was exported before the ban date and later processed elsewhere, the importer must be able to prove that earlier export date.

This is where a doré pack is actually held: not on the duty line, which is 0% regardless, but on origin evidence for the sanctions and due-diligence checks above.

What this page did not check

• 01Whether the 10-digit TARIC layer splits doré from refined bullion within 7108 12 00 for any purpose beyond the conflict-minerals Annex I entries. The live TARIC consultation database could not be reached on this date.
• 02The 0% duty rate was not confirmed against the primary EUR-Lex Combined Nomenclature annex or against Access2Markets directly. It is sourced from a national customs authority's published mirror of the CN table.
• 03Any EU dual-use export or import licensing regime specific to gold doré, beyond the Russia-gold ban. No licence requirement is stated here beyond that ban.
• 04EU sanctions regimes on gold from countries other than Russia. This was not researched for this page.

Sources

• Finnish Customs (Tulli), Combined Nomenclature 2025, Section XIV, Chapter 71

  Goods description and duty column for CN 7108, quoted below, read 2026-09-07

• Regulation (EU) 2017/821, Annex I

  Conflict-minerals due diligence — the doré/refined split by purity and refining stage, read 2026-09-07

• European Commission — non-preferential rules of origin

  Article 60 UCC declaration requirement, read 2026-09-07

• European Commission, DG FISMA — import, purchase and transfer of listed goods (Russia sanctions FAQ)

  Gold import ban under article 3o of Regulation (EU) No 833/2014, read 2026-09-07