AUTHORISED REPRESENTATIVE FOR JEWELLERY

The General Product Safety Directive basically states that all products marketed in the EU must be safe to use and forms a framework for all specific legislation established for specific products and issues. If no specific legal requirements have been set for your product and its uses, the General Product Safety Directive still applies. If there are specific requirements applicable to you, the General Product Safety Directive applies in addition, covering all other safety aspects which may not have been described specifically., You can see more about this directive on our separate page here.

This a regulation enforced by the European Chemicals Agency (ECHA). REACH formally took effect in 2007, with the purpose of regulating the concentrations of chemicals, heavy metals, and pollutants in all consumer products manufactured, imported and sold within the European Union countries.

As jewellery is usually worn on the skin, the use of hazardous chemicals is restricted, The EU has restricted a great number (over 1000) chemicals in products that are marketed in the EU. These are listed in the so-called REACH Regulation ((EC) 1907/2006). Which chemicals are of relevance for you will depend on your specific product and materials.

You should also consider Azo dyes If you use textiles or leather in your products, you products should not contain azo dyes that release any of the 22 aromatic amines which are prohibited. The EU legislation lists the aromatic amines, not the azo dyes which release them. The vast majority of azo dyes are therefore legally acceptable. Moreover, most reputable dye manufacturers only produce legally accepted dyes.

However, border rejections and market withdrawals do show that azo dyes still is an issue that causes problems on the EU market, as a number of tested products still show the prohibited aromatic amines and are consequently withdrawn from the market.

If you have any leather products, you need to address Chromium VI in Leather.

In March 2014 new legislation was adopted that restricts the chromium VI content in leather products. Chromium VI compounds can be formed in leather through the oxidation of chromium III compounds, which are added in some tanning processes.

The restriction is that the chromium VI content should not exceed 3.0 mg/kg.

Applicable to products made from wild plants and animals. If you use parts of wild plants or animals in your product (e.g., shells, coral, leather, animal parts, pearls,and wood), you need to make sure that these are not from endangered species and thus not fall under the restrictions of the Convention on International Trade in Endangered Species (CITES).

The EU has implemented the requirements in “COMMISSION REGULATION (EU) 2019/2117 of 29 November 2019 amending Council Regulation (EC) No 338/97 on the protection of species of wild fauna and f lora by regulating trade therein” and lists restricted species (including products thereof) and special procedures where applicable.

In many EU countries, a system of hallmarking and control is used to verify the precious metal content in gold, silvermore recently, platinum or palladium jewellery.

The rules on precious metals control are not harmonised in the EU. In some Member States control and hallmarking of every article by an independent body is compulsory, while others have a voluntary hallmarking system or only require prescribed marking by the manufacturer.

You should research if testing and hallmarking is necessary for your product and the country you are exporting to.Check this overview of rules on hallmarking per country

Material Analysis

In order to obtain the hallmark, semi-finished precious items must be analyzed (or assayed) by an official assay office. The duty of the assayer is to verify that the fineness of the product corresponds to the claims of the maker.

If we take gold as an example, a piece of jewellery with a fineness of 750 corresponds to 18 karats, which means that it contains 75% of gold and 25% of impurities and alloy metals. Alloy metals are added to improve hardness, decrease cost per weight, or other purposes.

Similarly, a fineness of 999 corresponds to roughly 24 karats, ie. 99.95% purity.

Thus, a hallmark represents the guarantee that the precious metal purity is equal or superior by the one indicated by the fineness number.

Hallmarking Convention

Hallmarks have a long history; as such, standards and enforcements might vary greatly among countries. In order to solve this problem, in 1972 several European countries signed the Hallmarking Convention (also known as “Convention on the Control and Marking of Articles of Precious Metals”).

Such a convention has the purpose of simplifying the trade of precious metals among the signatory states, which at the moment include Ireland, the Netherlands, Sweden, and other 17 countries.

Jewellery that conforms with the convention standards receives the Common Control Mark (CCM).

You can check the countries here

Beside the Jewellery specific regulations, importers must also familiarize themselves with the Directive 94/62/EC, an EU directive covering heavy metals contents product packaging.

Directive 94/62/EC requires that materials, printing inks, and dyes in packaging contains levels of heavy metals below certain limits. Restricted heavy metals include lead, mercury, and cadmium.

The structure of the packaging and choice of materials should be designed for collection, reuse, and recycling

The packaging may also need to prominently display compliance marks and other requisite labels.

Although not mandatory Sustainability is one of the ways for companies to differentiate themselves, and the means of offering sustainable products are numerous, ranging from recycling to choice of sustainable materials, sustainable design, improved social (working) conditions to certification and use of labels

Ther are various schemes that manufacturers can implement on a voluntary basic such as:-

• ICMM (sustainable mining),
• RJC (Responsible Jewellery Council)
• IRMA (Initiative Responsible Mining Assurance).
• Fair Trade Initiative

International Associates Limited is an Accredited Certification Body for the RJC, you can see more about the scheme on our services page here.