At least 20 countries selling goods to China last year likely had their exports shipped on to North Korea, NK Pro analysis of recent customs data from Beijing found this week.

The goods include thousands of bottles of wine from Europe, more than a million dollars’ worth of materials for manufacturing cigarettes from South Korea, and refined petroleum from the Persian Gulf, among others.

The news comes after NK Pro on Monday revealed that some of North Korea’s exports to China may have been purposely resold to a range of other countries after stopping in China’s customs warehouses and entrepôt trade zones, which hold goods before they are re-exported abroad.

One official said those findings hinted at a “serious loophole” in the global sanctions regime targeting the DPRK’s exports — and now it appears that the same pattern holds for North Korea’s imports.

According to publicly-available data from China’s General Administration of Customs (GAC), a wide range of goods — including some subject to sanctions — was exported to various Chinese provinces last year, only to be marked for re-export and then apparently sent off again in the exact same amounts to North Korea.

It is unclear if the countries are aware that their exports to China may have been sent to North Korea.

According to the GAC, North Korea imported millions of dollars’ worth of goods last year from customs warehouses and entrepôt trade “bonded areas” scattered across China’s provinces — a common practice in global trade not unique to the DPRK.

The GAC’s numbers cannot prove whether a French bottle of wine sent to a re-export zone in Liaoning Province, China, is the very same bottle of wine that set sail the next month for North Korea.

But an analysis of the trade data shows that many of the goods that left China’s customs warehouses and entrepôt trade zones for the North had first arrived at those same sites in the exact same volumes — down to the kilogram — and often in the same month, from other countries as far away as Jamaica and South Africa.

South Africa, Germany, France, and Italy sent thousands of large bottles of wine — holding a total of 74,047 liters– to the bonded area in Liaoning Province last year.

In the same period, 74,047 liters of wine — delivered in the same-sized large bottles, between two and 10 liters each — were sent from Liaoning’s bonded area to North Korea.

The United Nations bans all luxury goods from entering the DPRK, and EU law considers alcohol a luxury good — but these wine shipments do not appear in trade data as exports to North Korea; they are listed as exports to China.

Three countries — Ireland, Bulgaria, and Brazil — also sent 174 kilograms of lead crystal glassware to Liaoning’s bonded area last year, which then sent 174 kilograms of lead crystal glassware to North Korea.

Brazil’s contribution — 20 kilograms, according to the GAC — was valued at more than 91 dollars a kilogram.

In September, the United Arab Emirates (UAE) sent 31,356 liters of lubricating oil, a refined petroleum product, to the Liaoning bonded area. The following month, the Liaoning bonded area sent 31,356 liters of lubricating oil to North Korea.

United Nations sanctions limit the DPRK’s refined petroleum imports to 500,000 barrels per year, and require countries exporting refined petroleum products to the DPRK to report their shipments to the UN Security Council.

According to the UN’s recent Panel of Experts (PoE) report, which detailed North Korea’s continued sanctions-evasion efforts, only China, Russia, and Sierra Leone reported any refined petroleum exports to the DPRK last year.

But even if the UAE’s lubricating oil was destined for North Korea after stopping in Liaoning Province, it would still be listed in the customs data as a Chinese petroleum export.

South Korea sent more than one million dollars’ worth of cigarette filter tips to customs warehouses in two different provinces in China: Shandong and Guangdong.

The exact same volumes of cigarette filter tips — 22,446 kilograms in Shandong and 200,819 kilograms in Guangdong — were then sent to North Korea.

Myanmar also sent 136,918 kg of flue-cured tobacco leaves, not stemmed or stripped, to Liaoning Province’s bonded area — and Liaoning’s bonded area sent 136,918 kg of flue-cured tobacco leaves, not stemmed or stripped, to the DPRK.

NK Pro also tracked rum sent to Liaoning’s bonded area from India, Vietnam, Jamaica, and Cuba. Gin was sent there from India. Vodka was shipped to Jilin Province from Georgia.

All of the drinks were sent to North Korea in the same volumes from the same places in China.

Other items that followed the pattern included antibiotics, contraceptives, and cotton fabric.

There may yet be more: North Korea’s imports last year from China’s customs warehouses alone were worth more than $81 million, according to the GAC.

Edited by Oliver Hotham