Jewellery Regulations in the European Union: A Complete Guide

Jewellery manufactured or imported for sale in the EU is subject to various regulations and directives. These cover substance restrictions, labelling, hallmarking, and other aspects. Further, jewellery packaging is also subject to regulatory requirements.

In this guide, we take a closer look at EU hallmarking rules, grading systems, REACH, GPSR, and other compliance requirements for jewellery sold in the EU.

EU Jewellery Hallmarking Requirements

Hallmarking is required in many EU countries to certify the content of gold, silver, platinum, and palladium in jewellery and other products.

In general, to obtain hallmarking, your product must be analysed by an official Assay Office. The officer must certify that the fineness of the product corresponds to your claims (e.g., a fineness of 750, which corresponds to 18 karats).

The application of the Mutual Recognition Regulation to articles of precious metals

The main goal of this document is to clarify the application of the Mutual Recognition Regulation (EC) 764/2008.

The document states that the principle of mutual recognition “establishes that a Member State cannot forbid the sale on its territory of products which are lawfully marketed in another Member State, even if they were manufactured according to different technical rules.”

It also states that the principle applies to products that are not subject to harmonised EU law. This is relevant to jewellery, as hallmarking is not harmonised across all EU states.

The document then lists several different types of marks for precious metals that exist in the EU:

• The Assay Office Mark
• The responsibility mark (or sponsor’s mark) of the manufacturer
• The fineness mark that indicates the nature of the product
• The Common Control Mark (CCM)

I cover the Common Control Mark (CCM), which is recognized by many EU member states, in the next section of this guide.

The document also lists several legal cases concerning the Court of Justice of the European Union, to provide examples of situations in which a state could (or could not) prohibit the marketing of articles of precious metal imported from other EU member states.

Common Control Mark (CCM) – Hallmarking Convention

The Hallmarking Convention is an international treaty that allows signatory states to facilitate the cross-border trade of precious metal articles.

In short, articles that are marked with the Convention “Common Control Mark” (CCM) can enter the territory of signatory states without additional control or marking.

So far, the Convention has 22 contracting states, including Austria, Ireland, Italy, the Netherlands, and Sweden.

Other hallmarking requirements

According to the guidance page “Hallmarking requirements and the EU” published on GOV.UK, the Common Control Mark (CCM) is recognised by many EU countries. Other countries, however, have their own requirements. Here I provide a summary of what I have found.

Country	Marking
Austria	Common Control Mark (CCM)
Belgium	Hallmarking required (must register with an assay office)
Croatia	Common Control Mark (CCM)
Cyprus	Common Control Mark (CCM)
Czechia	Common Control Mark (CCM)
Denmark	Common Control Mark (CCM)
Finland	Common Control Mark (CCM)
France	Hallmarking required (must register with the bureaux de garantie)
Germany	Hallmarking not required
Hungary	Common Control Mark (CCM)
Ireland	Common Control Mark (CCM)
Italy	Common Control Mark (CCM)
Latvia	Common Control Mark (CCM)
Lithuania	Common Control Mark (CCM)
Luxembourg	Hallmarking not required
Netherlands	Common Control Mark (CCM)
Poland	Common Control Mark (CCM)
Portugal	Common Control Mark (CCM)
Slovakia	Common Control Mark (CCM)
Slovenia	Common Control Mark (CCM)
Spain	Hallmarking required (must register with an assay office in Spain)
Sweden	Common Control Mark (CCM)

Note that the signatory of the Hallmarking Convention may also have their own marking requirements. According to Assay.ie, for example, in Ireland “precious metal articles must bear an Irish hallmark or an International Convention hallmark”.

Also, even though some countries may not require hallmarking, you must still avoid making false claims (e.g., claiming that your product has 18 karats when this is not true).

Other grading systems

In this section, I list grading scales and systems for pearls, diamonds, and other precious materials.

Pearl Jewellery

I could not find an EU or national grading system for pearls. However, I found that several websites that specialise in pearls claim that the following systems are the most common for grading pearls:

• A-AAAA scale
• A–AAA scale
• A–D scale (Tahitian scale)

These systems take into consideration characteristics such as lustre and shape, in order to classify the pearls.

Diamonds

As for pearls, I could find an EU or national grading system for diamonds. However, I found that the 4Cs Framework is commonly used to grade diamonds. The framework grades diamonds based on the following characteristics:

• Carat
• Colour
• Clarity
• Cut

Note that Regulation (EC) 2368/2002 implements the Kimberley Process certification scheme for the international trade in rough diamonds. Its goal is to prevent the flow of “conflict diamonds”.

Other materials and products

The World Jewellery Confederation, or CIBJO (Confédération International de la Bijouterie, Joaillerie, Orfèvrerie des Diamants, Perles et Pierres) provides guidelines, industry standards, and grading standards such as the Blue Books for several materials, such as:

• Gemstones
• Pearls
• Corals
• Diamonds
• Related artificial materials

Substance Restrictions

The following regulations set substance restrictions for jewellery sold in the European Union:

• REACH Regulation (EC) No 1907/2006
• POPs Regulation (EU) 2019/1021
• Mercury Regulation (EU) 2017/852

Materials used to manufacture jewellery can, and often do, contain lead, cadmium and other restricted substances. This is perhaps the primary compliance risk when it comes to jewellery.

Years ago, we worked on a project for zinc alloy jewellery. Testing later revealed that the amount of cadmium exceeded the REACH Annex XVII limits many times over. The explanation at the time was that zinc ore is more likely to contain cadmium.

As such, the specific risk depends on the material, with examples listed in the table below.

Substance Risks

Material	Substance risk (example)
Stainless steel jewellery	Nickel
Zinc alloy jewellery	Cadmium
Plastic jewellery	DEHP and other phthalates
Wooden jewellery paints and coatings	DEHP and other phthalates
Leather accessories	Lead and hexavalent chromium

Testing

Many jewellery manufacturers and part suppliers cannot provide existing substance data. In such cases, third-party lab testing is generally needed to verify the substance contents in jewellery

General Product Safety Regulation (GPSR)

General Product Safety Regulation (GPSR) mandates that all consumer products sold in the EU are fundamentally safe. Jewellery is a consumer product and therefore subject to the GPSR.

Most jewellery products do not pose serious safety risks, but the GPSR does set documentation and labelling requirements that must be followed nonetheless.

Overview

✅ Identify standards/safety criteria

✅ Create technical documentation

✅ Create instructions and safety information (if necessary)

✅ Affix label information

• Type, batch or serial number
• Manufacturer name
• Manufacturer postal and electronic address

Children’s jewellery

Additional measures to ensure safety must be taken for children’s jewellery. For example, small parts, sharp points, and general choking hazards must be eliminated to the extent possible.

Just to be clear, children’s jewellery means any jewellery intended for children. Toy jewellery is another category, which I cover below.

Toy Jewellery

The Toy Safety Directive covers products designed or intended for use in play by children under 14 years of age. For example, DIY jewellery crafting kits for children could fall within the scope of the Directive, which triggers a range of requirements.

What ultimately matters is the age group, and whether the jewellery is intended for use in play (which makes it a toy).

Overview

✅ Comply with EN 71 standards

✅ Verify safety through testing

✅ Affix labels and warnings

✅ Affix CE marking

✅ Provide instructions

✅ Age warning and small parts warning

✅ Create a Declaration of Conformity

✅ Create Technical Documentation

Fauna and Flora Derived Jewellery – Regulation (EC) 338/97 on the protection of species of wild fauna and flora by regulating trade therein

This Regulation aims to guarantee the conservation of endangered species of wild fauna and flora by regulating their trade. For example, we found that it lists types of:

• Pearls
• Corals
• Shells
• Wood
• Claws

Here are the main requirements:

a. The import of specimens of endangered species requires a permit issued by an authority in the EU state of destination (or an import notification)

b. Export from the EU requires an export permit

c. Covered species are listed in Annexes A to D, which provide a different degree of protection.

• Covered species are listed in Annexes A to D, which provide a different degree of protection.

Jewellery Packaging – PPWR

Jewellery packaging can be subject to the EU Packaging and Packaging Waste Regulation (PPWR). That being said, some jewellery packaging is likely exempt based on the following:

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An item which is an integral part of a product and is necessary to contain, support or preserve that product throughout its lifetime and where all elements of that item are intended to be used, consumed or disposed of together should not be considered to be packaging given that its functionality is intrinsically linked to it being part of the product.

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For example, a jewellery box used to contain a diamond ring would likely be considered an “integral part of a product necessary to contain, support or preserve that product throughout its lifetime”.

But the PPWR would still apply if packaging is discarded. This includes plastic wrapping, parcels, and bags.

I should also mention that jewellery boxes are still subject to GPSR, REACH, and other regulations.

You can learn more about PPWR requirements in this guide.

FAQ

Is hallmarking required for jewellery in the EU?

Hallmarking is required in most EU states. Also, articles marked with the Convention “Common Control Mark” (CCM) can be sold in all the convention signatory states, which include many EU states.

Is CE marking required for jewellery?

No, CE marking is not applicable to jewellery products in general. The only exemption I can think of is toy jewellery, which is subject to the Toy Safety Directive.

Products that do not fall within CE marking regulations and directives cannot be CE marked.

Does the GPSR apply to jewellery?

Yes, the GPSR applies to consumer products, and jewellery is a consumer product, which places this category within the scope of the regulation.

Note that the GPSR is applicable to jewellery both for children and adults.

Does the PPWR apply to jewellery packaging?

Our understanding is that the PPWR exempts packaging that is used to permanently store jewellery. For example, boxes and containers used for bracelets, necklaces, and rings are likely not subject to the PPWR.

That said, this must be evaluated on a case-by-case basis.