Koos Jansen
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Koos Jansen
Posted on 23 Jan 2014 by

Open Letter To CPM Group

To CPM Group,

On January 15, 2013 CPM Group released a Market Alert addressing the facts and fantasies being spread throughout the mainstream media and the financial blogosphere regarding Chinese central bank gold purchases. An endeavor much appreciated by me as I’m highly concerned with credible figures. In the article various subjects about the Chinese gold market are discussed, not on all do I wish to comment, but there was one I feel obliged to respond to. At one point CPM stated:

One of the commentators added gold deliveries via the Shanghai Gold Exchange to gross supply figures, apparently unaware that the gold involved in these deliveries gets re-delivered repeatedly via the exchange over time. Adding this gold to supply is confusing new supply with market turnover. 

Because I have been the most active reporter on SGE deliveries (or actually withdrawals) chances are this “one commentator is me. Hence my desire to share my point of view on this matter. I have written extensively on this in the past (which you can read hereherehere and here) but would like to present the rules as disclosed by the SGE and the implications from it on Chinese demand for physical gold once again.

Physical delivery on futures exchanges relates to the amount of gold in the vaults of the exchange that changes ownership after settlement between long and short contracts, a process that in theory can be repeated to infinity and therefore a completely inaccurate indicator for physical supply and demand. The Shanghai Gold Exchange, however, does not only publish data on physical delivery, they also publish data on the amount of physical gold that is being withdrawn from the SGE vaults. There has been confusion about the difference between SGE deliveries and withdrawals because the SGE has been naming withdrawals as deliveries inconsistently. The numbers I’ve published on this website always related to the withdrawals from the SGE vaults (these numbers are only released by the SGE on their Chinese website).

The crucial SGE rule that makes the withdrawal numbers significant is this: once SGE bars are withdrawn from the vaults they are not allowed to be re-depositedThis rule can be found in the SGE rule book (#23), and, for example, is disclosed on several ICBC webpages regarding gold products.

(2) According to the Shanghai Gold Exchange rules, physical gold taken out of the warehouse cannot be taken into the gold warehouse designated by the Shanghai Gold Exchange again.

To be absolutely positive please call the SGE (phone number; 0086 2133189588), they speak fluent English and will confirm this rule.

The rule implies these withdrawals can’t be re-delivered. The purpose of the rule is that SGE bars are granted to be of the highest quality, no one can counterfeit an SGE bar and bring it in the vaults. The same rule applies on the Borsa Istanbul:

Once gold bars have been released from the Istanbul Gold Exchange vaults, they cannot be re-admitted to the Exchange vaults. They must be melted again and assayed and tested by an Istanbul Gold Exchange approved authority. Such re-melted gold is admitted in the Istanbul Gold Exchange again essentially as new gold bars and can then be traded.

We can compare this type of policy with the LBMA Chain of Integrity. Bullion Management Group, which is an LBMA associate, states on its website:

If the documentation and the background checks passed scrutiny, then all bars coming from outside the Chain of Integrity are re-assayed and re-cast to Good Delivery standards.

The SGE rule, combined with the Chinese laws that require all imported and mined gold to be sold through the SGE, implies that the withdrawals are equal to total Chinese gold demand. The following quote is from the Chinese media, translated by Soh Tiong Hum:

China’s explosion in demand for physical gold in 2013 left a deep impression on international investors. The Shanghai Gold Exchange withdrawals for the year up till 27 December 2013 exceeded 2180 tons. Considering the exchange’s position as a hub for domestic gold circulation, in conjunction with a system that forbids withdrawn gold from re-entering inventory, to a large extent the withdrawals number can be treated as the best benchmark for physical gold demand in the Chinese market. Not to mention that the entire 2013 global mined gold production does not exceed 2700 tons. China’s massive demand has to a large extent remade the world’s gold circulation system. Newly mined and stocked gold is moving through trade links in London – Switzerland – Hong Kong – into China in a large scale orientation towards the East. The impact of China’s demand on international gold price will inevitably increase.

I sincerely hope this information will clear up some of the misconceptions of the Chinese gold market.

Kind regards,

Koos Jansen
E-mail Koos Jansen on:

  • Joshua Roberts

    can i redeposit withdrawn SGE bars if i smelt them first?
    let’s ask Germany 🙂 [of course i am just being facetious]
    great work as usual guys!

  • USGrant

    Typo, allowed instead of “aloud” in the 5th paragraph. Much thanks for your work.

    • In Gold We Trust

      Thanks for that! Corrected. I will now delete your comment (because the typo is gone)

  • Billy Bankers

    Superb open letter, Koos! Great morning read for me and a really useful contribution to the gold market. Keep up the great work!

    • In Gold We Trust

      Thanks Will. Lets see if the mainstream media will ever discuss this massive amount of gold being withdrawn from the SGE vaults.

      • Guest

        I’d suggest the MSM will be at least a year or so away from reporting this. If and when (God willing!) the gold and silver bull markets resume, this might be one of the convenient facts they ‘discover’ to explain the new bullish price trends… albeit years after the event!

  • http://twitter.com/#!/alexdgn alexdg

    Another great post! Keep up the good work!

    You always keeping it down to fundamentals and quote the facts and numbers.

  • wazsah

    I notice in all their critique you linked to above – and what I could find at their www site – CPM are not offering their version of how Chinese gold buying has varied over the years.

  • Gutekunst

    Koos, you have to understand the attitude of an employee at such organisations like CPM. If an employee picks up something out of the “Goldbug blogosphere” regardless if it is true or not, he looses credibility or worse his job. If they do not respond to your letter, you can see it as a confirmation. You can compare it to a fund manager at a big bank, he will always follow the consenus in order not to loose his job, so do not expect to much from organisations like CPM. Only a hedge fund manager would be flexible enough to change his opinion..

    At least your work is getting traction, several German newspaper report on the flow of Gold from the west to the east. Although they do not know, where the numbers developed, your work is the only reliable source based on facts. All others estimate the Chinese numbers, If e.g. GFMS would confirm your number they would have to admit that their Chinese numbers were wrong in the past, which would mean they would loose business, because they sell their numbers to institutional clients.

    I am observing that they gradually adjust their numbers. The only reason I can imagine is your work.on net imports, SGE deliveries and exports from Switzerland to China. These numbers clearly demonstrate that the consensus numbers on Chinese gold demand from GFMS etc. are wrong, a fact they like to hide in order to keep their business. Throughout last year they negated the Chinese demand, upgrading their numbers a little bit. Since two months i am observing a change of attitude on reports in newspapers. Before that the Chinese demand was “goldbug propaganda”

    I would wish that there would be more persons like you working with hard facts. 90% of the blogs in the “goldbug community” are doing harm to gold investors. By spreading false information they keep out institutional investors. Your blog and the blog of Bron Suchecki are one of the fews working with facts and not with propaganda about the cartel etc. So keep on going with your work.

  • Jeff Christian

    25 January 2014

    Dear Koos,

    Thanks for the e-mail.

    First, let me assure you that I was
    not referring to you. I generally have found your material pretty good and

    Second, I was referring to the known
    fraudsters with poor ethical compasses, who willingly and knowingly lie and
    distort data about gold and silver in order to dupe investors into buying and
    holding, and never protecting their gold and silver investments from downward
    price moves that inevitably happen in free markets. I think we all know who I
    am referring to.

    These people engaged in a blatant and conscious round of distortion late last year, adding the gold
    imports into China to estimates of demand within China, and then adding SGE
    deliveries to that sum, to inflation what they claimed was the ‘accurate’
    estimate of demand for gold in China. Thus, they triple counting imports, and
    double counted domestic production. Those egregious lies are the basis of my

    Third, let me point out that I try to be very careful with my word choice. Words matter. A comma cost a million dollars in a Canadian contract dispute a few years ago. Throwing words around
    carelessly, like making up statistics, is unethical and unwise. I point this
    out because what CPM Group (we are a team of analysts, and not just me) wrote
    in our Market Alert was that “the gold involved in these deliveries
    gets re-delivered repeatedly via the exchange over time.” You
    quoted us correctly. Note that we did not write that the same bars are
    delivered repeatedly over time. However, for a few bucks you can melt and
    recast bars, assaying them to make sure they are of proper purity. It happens
    all the time around the world – not just in Istanbul and Shanghai, but around
    the world.

    Ostensibly, legally, all of the gold bought and sold on a wholesale level in China passes through the SGE. So, if a wholesaler sells a retailer, jewelry manufacturer, or sell-side investment firm gold via the SGE, it shows up as a sale. Some of that metal is withdrawn. I do not have
    the actual figure in front of me on a frigid Saturday morning at my home, but
    we monitor this data and have it in our data base, as you do.

    All of the gold imported is supposed to pass through SGE. To add the gold imports to SGE
    withdrawals, or deliveries, is to double count this metal. If you then add in
    the metal that is sold to fabricators, you triple the counting. For
    domestically refined metal, you are double counting. China is the largest
    mining and refining country in the world for gold, of course. There are
    additional pitfalls in over-counting demand, due to the fact that multiple
    companies will buy and semi-fabricate the same ounce between the time it is
    refined and either used or bought as an investment product.

    Of the metal withdrawn, some comes back sooner and some comes back later. Some never comes back. If I am an electronics firm, my process scrap to product ratio is around 70% – 80%, meaning that of the gold I take physical delivery of and withdraw to use to make my electronic components, around 75% of it will come back to the refiners for reprocessing. If I am a
    jeweler, the scrap generation will be anywhere from 25% to 80%, depending on
    the type of jewelry I am making and the processes I am using. If I am an
    investor, well, in China as in the rest of the world, smart investors sometimes
    sell their metal back to their dealers. There is a constant flow of gold in the
    market, as there is in markets around the world. Withdrawals do not equal use,
    for a number of reasons.

    I hope this addresses your questions. I apologize if you thought I was referring to you. I
    was not.

    Jeffrey M. Christian
    Managing Director
    CPM Group

    • In Gold We Trust

      Dear Jeffrey,

      First of all I would like to thank you for taking the time to respond to my open letter.

      Second, according to the PBOC, who is a co-writer of the yearly China Gold Market Report, total withdrawals equal total demand and total supply.

      Their formula: SGE withdrawals = total supply = mine + import + scrap = total demand

      In 2013 total withdrawals accounted for 2197 tons, this had to be supplied by mine, import and scrap supply. Mine supply was 430 tons. What is your take on the ratio between scrap and import supply for the remaining 1767 tons?

      Chinese demand (withdrawals) exploded after the price drop in April 2013. It’s clear the Chinese are big buyers because of these low prices. I can just not imagine the Chinese, well known for their long term savings strategy regarding physical gold, buy at bottom prices and sell it the same year for the same low prices. Therefore I think scrap supply (just the part that is being refined into new SGE bars) for 2013 is roughly 200-300 tons.

      Best regards,

      Koos Jansen

      • Jeff Christian

        I am not familiar with the report to which you refer. I am familiar with the work of PBOC and others within China. We work with most major gold market participants there. I would refer you and your readers to China Gold Associations’ recent statements regarding the levels of gold demand in China — around 35 MM oz in 2013, in line with our estimates. CGA and CPM Group recently signed two international cooperative agreements, so it’s not surprising our data coincides with their statistics on that account. In reality, however, the reason we signed the agreements and work with them is that their read on the Chinese gold market is better, is based on the activities of their members, which comprise all major gold market participants in China, and conforms with what importers, banks, jewelers, manufacturers, wholesalers, and retailers within China tell us. In other words, there is a consensus view within the Chinese market to which we adhere, which is quite distinct from the numbers bandied about outside of China. We would rather believe that Chinese market participants know what they are doing than to believe that people far removed from the day to day trading and business in the Chinese gold market, relying on estimates derived from indirect data, have a better take on what the Chinese companies with which we deal say they are doing.

        There was a problem in the early 1990s with Indian data. The Indian market was expanding rapidly, after relaxation of gold and silver import prohibitions that had been put in place in the 1960s. All the Indian market participants were clustered around given estimates of demand for gold and silver in India. Our ersatz competitors refused to believe everyone in the Indian market, saying, literally, ‘We’re British. We know better than the Indians what is going on in their markets.’ The Indians were right, of course. We like to learn from our mistakes, as well as those of others.

        • In Gold We Trust

          Dear Jeffrey,

          The report I was referring to is the China Gold Market Report 2011:


          In these yearly reports it’s stated that Chinese gold demand equals SGE withdrawals. This is not my interpretation, this is a fact according to the writers of these reports. The reports are written in conjunction by the PBOC, the SGE, the SHFE and the CGA.

          I have written a comprehensive analysis that indisputably exposes this fact that Chinese gold demand equals SGE withdrawals. You can read it here:


          The other sources I used for my analysis were the SGE Annual
          Reports and CGA Gold Yearbooks (if you like I can sent you
          all the reports that are not available online). In my writings all my sources
          are attached, mentioned, accurately translated, linked to and I added easy to read screen dumps of the most significant numbers from the reports. Please read my analysis.

          I would still like to hear your answer on my question from my previous comment, in which I asked:

          “In 2013 total SGE withdrawals accounted for 2197 tons, this had to be supplied by mine, import and scrap supply. Mine supply was 430 tons. What is your take on the ratio between scrap and import supply for the remaining 1767 tons?”

          Best regards,

          Koos Jansen

          • Gutekunst

            If the Chinese Central Bank purchases gold I assume it would not appear in the numbers of CGA, that could be a source of the discrepancy.

          • Jeff Christian


            I want to explain why I did not immediately respond to your last question, about Chinese supply from mines and scrap. I was not avoiding you, but went to Chinese sources to
            verify some data, try to get additional data, and ask some questions. I wanted
            to make my responses as accurate as possible.

            Additionally, our
            discussion here comes at an inopportune time, for several reasons. This is the
            time of year when CPM Group and other groups such as industry associations and
            participants in China and around the world pull together their ‘final estimates’
            of supply and demand for the previous year, for use in our annual Gold Yearbook
            and other uses. Also, the markets have been very unsettled lately in many
            countries, demanding attention. Seasonally, we have been in the run-up to the
            Lunar New Year: This is a time when gold dealers are busy selling gold, and not
            really wanting to be distracted by questions about how much metal they bought,
            sold, and traded last year. Now, Lunar New Year has arrived, and all such talk
            is off for a little more than a week. Finally, there are major shifts, and
            minor shifts, in the Chinese gold market, and gold market regulation, underway.

            The quick answer to
            your question is this: In 2013 CPM Group’s estimates, at this time pending
            final locking in over the next three weeks, is that mine production was 430 mt,
            secondary supply was 34 mt, and net imports were 1411 mt. That totals 1,875 mt.
            The difference between that figure at the 2,197 mt you quote may represent, in
            part, the round-trips of metal that is used in the manufacturing process,
            recast and recycled through the market that I described last weekend. In
            reality, there are a lot of other things going on.

            A few separate

            You may have read
            that the China Gold Association has signed two international Agreements with
            CPM Group. We will work as its international advisors on the gold market
            internationally, for one thing, and CGA will translate and publish CPM Group’s
            Gold Yearbook in Chinese in China.

            The PBOC has never
            cobbled together numbers on the gold market or co-authored gold reports with
            SGE. This work has been done by the CGA and others; the PBOC and SGE are users
            of such data.

            The relationship between SGE withdrawals and estimated gold demand in China has
            never been that one equals the other. SGE and others may say that to you or
            others, but let’s just chalk that up to meaning lost in translation. For
            example, in 2008 SGE withdrawals were 41% greater than estimated total demand for
            fabrication and investment demand in China. In 2009 SGE withdrawals exceeded
            estimated demand by 39%. Over the years the ‘over-age’ of SGE withdrawals to
            estimated demand has ranged from 14% to 41%. People may say that one equals the
            other, but they simply do not.

            I am sure you have
            read various things that you reported, such as the PBOC co-authoring gold
            reports and that SGE withdrawals equal supply equal demand. I could bore you
            witless with examples of similarly cavalier use of language and statements from
            around the world’s precious metals market. I won’t. Many things simply are not as they seem to
            be, nor as they are said to be. I hope my discussion of the circulation of
            gold, even if in recast bars, has helped you understand a bit more of the
            multi-layered complexity of the flows of gold in individual national markets.
            Even those comments were immensely superficial.

            Hope all of this

            Jeff Christian
            29 January 2014

          • In Gold We Trust

            Hi Jeffrey,

            1) So according to you total SGE withdrawals for 2013 (2197mt) were supplied by:

            430 mt mine
            34 mt secondary
            1411 mt net import
            322 mt scrap

            Total supply = 2197 mt. I’m happy we can agree on this part.

            Now our disagreement:

            If this gold is supplied to the SGE, and then sold through the SGE, and then withdrawn from the vaults (fact! and this gold can’t be sold twice over the SGE). How come this doesn’t equal demand. How come any gold buyer on the SGE that extracts gold from the vaults doesn’t demand gold? He surely paid for it and took possession. Where else is this gold going?

            2) The PBOC does co-author the yearly China Gold Market
            Reports. I added a picture from the China Gold Market Report 2011 were we can see the authors of the report on page 3. Everyone can see this report here.


            The PBOC still has a huge stake in the Chines gold market, the SGE is controlled by the PBOC and not so long ago the PBOC WAS the Chinese gold market.

            3) You state Chinese demand doesn’t equal SGE withdrawals
            because numbers get lost in translation. However, again, if you read (all links are provided)


            you will find that total demand disclosed by the China Gold Market Reports written in ENGLISH exactly matches SGE withdrawals disclosed in SGE Annual Reports written in ENGLISH (from 2007 – 2011, after 2011 they stopped publishing reports).

            In the above linked article I also mention a few other
            quotes from these reports that imply the Chinese use the equation:

            mine + import + scrap = total supply = SGE withdrawals =
            total demand

            Simply saying “The relationship between SGE withdrawals and
            estimated gold demand in China has never been that one equals the other. The SGE and others may say that to you or others, but let’s just chalk that up to meaning lost in translation.” Does not convince me.

            Yes, every year SGE withdrawals exceed CPM’s “estimated total demand for fabrication and investment demand in China”. That’s my whole point. Why did these Chinese gold institutions (SGE, CGA, SHFE, PBOC) report on much more demand than your company did?

            Quote from the China Gold Market Report 2011:

            “Deregulation of the gold control to open the gold market to
            the public in 2002 led to the constant rise in Chinas gold demand, which unprecedentedly exceeded 1,000 tons in 2011..”

            While CPM states fabrication and investment demand was 684
            tons in 2011. Page 15


            The big difference between CPM/WGC/GFMS total Chinese demand
            and total Chinese demand disclosed in the China Gold Market Reports is caused by investment category 6 “Net Investment”.

            I hope you can explain to me what kind of “investment” this relates to. According to the SGE it relates to gold being withdrawn by individual SGE account holders.


            Koos Jansen

          • Jeff Christian


            First, our basic numbers do not agree. We have secondary at 34 mt. Secondary supply is refined from scrap. You have added a line for 322 mt of scrap on top of the physical supply we and everyone else actually involved in the Chinese gold market identify, presumably in order to make the physical supply equal SGE withdrawals. We do not have that.

            The difference between our, and everyone else, estimates of physical supply and yours is that you are adding this number in, presumably as a dummy variable.

            Furthermore, you seem to have missed some very important points I made earlier. The gold withdrawn from the SGE vaults may be returned. The bars may not. There is a constant steady flow and reflow of metal amount physical market participants: refiners, semi-fabricators, fabricators, jewelers, investors, wholesalers, retailers, scrap processors, and others. The metal is taken delivery of. It is used. The process scrap is refined, recast, and returned to dealers or banks, who resell the new bars to new buyers. It is different bars, but the same gold.

            Your error is tantamount to sales, well, this shirt manufacturer sold a shirt to the wholesale distributor, who sold it to a retailer, who sold it to a consumer, so four shirts were bought. No, one shirt was bought.

            I have things I need to do other than this, so I cannot belabor this or other parts. Regarding your references to the PBOC personnel and others listed as ‘authors and proofreaders, see if you can find a book I read in college calls Tsars, Mandarins, and Commissars, written in the 1960s, or any other book on the political control structures of the Soviet Union and Chinese communist socieities, or any other book that might explain the difference between an author, an editor, and a ‘proofreader’ in a centrally planned and controlled economy.’

            Sorry, but I have to move on from this discussion.


          • In Gold We Trust

            Hi Jeffrey,

            1) Even the CGA/SGE is estimating scrap by subtracting import and mine (and stock carry-over) from SGE withdrawals.

            From the China Gold Market Report on 2008 data, page 69


            ”Physical gold withdrawals from the Shanghai Gold Exchange (SGE) topped 543.19 tons in the year, including gold imports of 81.44 tons by commercial banks, stock carry-over of 31.661 tons from 2007 and 282.007 tons of gold produced in the year. In theory, the gap of 148.082 tons was filled by recycled gold.”

            2) The gold withdrawn from the SGE vaults can only return if its remelted and thus is scrap/recycled supply.

            3) I know gold changes hands many times and not all transactions are measured as demand. The question is, at what level do you measure demand?

            If I buy a 100 gram gold bar on the SGE and sell it to my brother, who sells it to a refinery, who sells it to a jeweler, who fabricates a necklace and sells it to a Chinese auntie, the Chinese (according to the reports released up until 2011) will only measure my purchase at the SGE as demand. Your company will probably measure the purchase from the auntie as demand.

            To demonstrate once more Chinese demand equals SGE withdrawals I added two pictures. (just to repeat it’s not my theory)

            – 1 shows 2010 total demand, from China Gold Market Report 2010, page 26


            – 2 shows 2010 SGE withdrawals from the SGE Annual Report 2010, page 28


            Both 837 tons (and this matches every year). Concluding these reports I have been studying measure demand at ”wholesale level”, where others measure demand at ”retail level”.

            But we can repeat our arguments to infinity, we will (most likely) never agree. In any case, thank you very much for taking the time to respond.


            Koos Jansen

            PS One last quote from the Chinese media:


            “Considering the exchange’s position as a hub for domestic gold
            circulation, in conjunction with a system that forbids withdrawn gold
            from re-entering inventory, to a large extent the withdrawals number can
            be treated as the best benchmark for physical gold demand in the
            Chinese market.”

        • mohamed

          jeff christian

          i need ur help plz i have gold am just find a best costerma and i will sell u the best price i have 10kg

  • Jeff Christian



    After I wrote my response to you I went and refreshed your blog to make sure it was posted. I noted the comments from Gutekunst disparaging CPM Group. I would like to suggest to him and others that they refrain from opining on things they are clearly totally ignorant of. He is correct to congratulate you on your reliance on facts and data. Unfortunately, he does not practice what he preaches. It’s people like him that give ‘the goldbug blogoshpere’ and other blogs a reputation for stupid commentary from the uninformed.

    Jeff Christian

    • Gutekunst


      as far as I know CPM Group is not a charity organisation and wants to sell its products. Koos Jansen does not depend on customers, only on donations, but anyway, thanks a lot for answering to Koos Jansens letter and appreciating his work detailing possible flaws in the Chinese numbers.

      • Jeff Christian

        Apology accepted. I do not know who you are, but you clearly do not know anything about CPM Group, who we are, what we do, how we earn our money, our background and history, and what we know about gold and other commodities. So let’s make this a growing experience. Visit our website, http://www.cpmgroup.com. Read some of the free commentary. Read the letters about derivatives market regulations and hedging from the late 1990s and 2002 there. Maybe buy our 2013 Gold Yearbook, which will give you an incredibly deep and broad insight into aspects of the gold market that you may not be aware of. You can buy my 2006 book, Commodities Rising, which gives more background on us, and on commodities markets. Try to be more informed in future commentaries, about CPM Group, gold, and everything else in the universe. And, again, thanks for the apology. Compared to many on the internet, you’re a real gentleman, or gentle person. I appreciate that in these uncivil days.

  • geoffrey

    Lack of Demand, not Manipulation, Behind Gold Price Drop, Says CPM’s Jeffrey Christian

    The Gold Report: This year has been difficult for gold investors. The price went from a high of almost $1,800/ounce ($1,800/oz) to where it is now, in the mid-$1,200/oz range. You have written extensively about the supply and demand forces of precious metals. What is behind the drop in the gold price?

    Jeffrey Christian: The single most important factor has been a massive decline in the investment demand for gold. In 2013 investors have bought about 30 million ounces (30 Moz) gold on a net basis globally. That’s down from about 39 Moz in 2012 and 31 Moz in 2011, but it is still at a very high level compared to historic investment demand. The net purchases are down 24% because some investors are selling gold.


    Massive decline in demand ?? !

    No manipulation ?? !

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