Planning to import or manufacture jewelry in the European Union? In this guide, we cover what all jewelry importers and exporters must know about REACH, hallmarking, packaging regulations and more.
- Stainless steel jewelry
- Zinc alloy jewelry
- Plastic bead jewelry
- Ceramic jewelry
- Jewelry boxes
REACH, short for Registration, Evaluation, Authorisation, and Restriction of Chemicals, is 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.
More than 1000 chemical substances are recorded in the restriction list at the time of writing, and the list is still expanding, as new chemicals and heavy metals are added each year. Any products or material (e.g. stainless steel) that contain concentrations of the shortlisted substances above the set limits are in violation of the REACH regulations and thus subject to the prohibition in the EU market. Consumer products also include jewelry products, such as bracelets or earrings.
Here are some substances covered by REACH which may be found in jewelry parts:
- Polycyclic aromatic hydrocarbons
Substances of Very High Concern (SVHC)
The European Chemicals Agency (ECHA) updates the list of restricted substances annually to ensure that the list of hazardous chemical substances is comprehensive, up-to-date and covers recently found toxic chemicals in the products. Note that jewelry importers and manufacturers don’t necessarily need to stay up to date with the SVHC list as lab testing companies take care of that.
As mentioned above, jewelry importers have the responsibility to ensure that the products are fully compliant. Lab testing is the only way to determine whether the products are compliant with the REACH regulation (e.g. confirm if the substance content is below the set limits).
Here are some companies offering REACH compliance testing:
- Bureau Veritas
You can find more companies in this guide.
Importers can get a package of comprehensive lab-tests according to the compliance regulations. In most cases, a lab-test costs around $200 for each product, depending on the quantities, materials, and colors of your jewelry product.
You can learn more about REACH lab testing in this guide.
Jewelry parts may contain excessive amounts of chemicals and heavy metals, such as lead, nickel, and cadmium. Keep in mind that this is the case for a wide range of materials used to make jewelry, including stainless steel, zinc alloys, ceramics, leather, plastics, paints, print inks, and coatings.
While REACH compliance is mandatory in the EU, plenty of jewelry materials and parts are not made with REACH compliance in mind. Further, most jewelry suppliers in low-cost manufacturing countries don’t have access to test reports and substance data from their subcontractors.
What this means, in plain English, is that most jewelry suppliers don’t have a clue whether their materials and components are REACH compliant or not. As such, third-party lab testing is the only way to verify if your jewelry product is REACH compliant. It’s also important to inform your supplier of your compliance requirements in advance.
Gold and Silver Jewelry (Hallmarking)
In many EU countries, the hallmarking system is used as a mechanism to certify the precious metal content – gold, silver, and, more recently, platinum or palladium.
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 jewelry 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.
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.
Jewelry that conforms with the convention standards receives the Common Control Mark (CCM).
Although two major quality grading systems for pearls exist – the AAA-A scale and the A-D scale, – there is not a widely recognized standard or regulatory requirement. You can get in touch with the SSEF (Swiss Gemological Institute) or the GIA (Gemological Institute of America) If you still want to get a grading test report from a well-known institute.
Also, when using parts of wild plants or animals in your jewelry products, you must make sure beforehand that they are not from endangered species listed on the Regulation (EU) 2019/2117.
Such a list includes several kinds of mother of pearl, corals, shells and other species, including all species protected by the CITES (Convention on International Trade in Endangered Species).
If the product is included in the above-mentioned regulation, an import authorization must be presented.
However, keep in mind that most imported pearls are cultured pearls. In this case, they shall not be subjected to CITES.
There are currently no specific labeling requirements in place covering leather used to make jewelry and other accessories, other than wallets. That said, importers and manufacturers should not make false claims regarding the grade or quality of the leather
General Product Safety Directive (GPSD)
The General Product Safety Directive (GPSD) was enacted in 2001, for the purpose of regulating the safety of the products manufactured, imported, sold in the EU market, including jewelry.
Manufacturers or importers need to self-draft and issue GSPD compliance document for their jewelry products, based on their own assessment, which must consider the behavior of both adults and children.
We recommend importers to create a risk assessment document to keep a record of the potential hazards that might be caused by your products.
It is voluntary to have your product conduct a GPSD compliance test. However, we still recommend importers to have their products lab-tested by an accredited lab-testing company for compliance.
GPSD is separate from the 25 CE marking directives, each of which is mandatory for one or more specific categories of the product, and doesn’t require CE marking itself.
Directive 94/62/EC: Jewelry Packaging
Beside jewelry specific regulations, importers must also familiarize themselves with the Directive 94/62/EC, an EU directive covering heavy metals contents product packaging. Note that Directive 94/62/EC is also applicable to jewelry packaging.
Heavy Metals Restrictions
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.
Importers might be required to provide eligible lab-testing reports on the product packaging from an accredited third-party. Labs that perform packaging materials testing include Bureau Veritas, SGS, TUV, and QIMA.
The testing costs are relatively low, starting from around $40 per material and color.
Additional Packaging Information
1. The structure of the packaging and choice of materials should be thought for collection, reuse, and recycling.2.
2. The packaging may also need to prominently display compliance marks and other requisite labels.
Amazon Europe Compliance Requirements
Amazon requires that all products sold in its platform meet all legally required EU product standards, regulations, certifications, and labeling requirements. It’s therefore important to carefully study the product category requirements in the Amazon Seller Central for each product you are considering selling.
How does Amazon check product compliance?
Amazon sellers should prepare test reports, certificates, product photographs, and invoices of their jewelry products before listing new SKUs in the platform. It is likely that Amazon requests the above-mentioned documents from the sellers for inspection.
What can happen if we sell non-compliant jewelry products on Amazon?
Once Amazon detects that a seller is selling non-compliant jewelry products on Amazon, the company may take immediate action on removing product listing or freeze seller’s account. Please make sure you understand all the compliance rules relevant to the jewelry products you are selling in the EU.