Planning to import or export jewelry to the United States? In this guide, we cover what all Amazon sellers, importers and overseas manufacturers should know about heavy metals and chemicals regulations, labeling requirements, packaging, and lab testing.
If you plan to import jewelry products to the US, it’s important that you understand the safety standards and regulations that apply to your products within the US market.
- Stainless steel jewelry
- Gold and silver jewelry
- Precious stones
- Pearl jewelry
- Plastic jewelry
- Body piercings
- Crowns and tiaras
California Proposition 65
California Proposition 65 restricts more than 800 chemicals and heavy metals in consumer products, including jewelry and accessories. Jewelry containing excessive (i.e., above the set limits) amounts of lead or other restricted heavy metals are not legal to sell – unless the product carries a warning label.
Examples of restricted substances
Here are some heavy metals and chemicals that may be found in jewelry parts:
Importers should be aware that lead is often found, to a varying extent, in jewelry parts and materials. California Proposition 65 requires that “manufacturers and importers of lead-containing jewelry must warn consumers if they will be exposed to lead in jewelry in an amount that exceeds the safe harbor level of 0.5 micrograms per day.”
In March 2017, California Proposition 65 adjusted the maximum amount of cadmium in necklaces to no more than 100 ppm.
For more information, please check the California Office of Environmental Health Hazard Assessment (OEHHA).
California Proposition 65 Lab testing
The only way to verify the compliance of your products is to submit jewelry samples for third-party CA Prop 65 lab testing. Third-party lab testing companies offer comprehensive chemicals and heavy metals testing services according to the substance list and limits set by California Proposition 65.
As such, you don’t need to keep track of the list of restricted substances and their respective limits yourself. All you need to tell the testing company is that you want to book a CA Prop 65 lab test and they’ll take care of the rest for you. Testing companies such as QIMA and Intertek also keeps track of new substances added to the list.
Note that most of the jewelry manufacturers in China and Southeast Asia are generally not able to provide pre-existing California Proposition 65 Lab test reports. This doesn’t necessarily mean that their jewelry parts and other materials are by default non-compliant. But, it makes it harder to assess if they can ensure compliance.
The cost of a California Proposition 65 lab test generally starts from around $100 t0 $200 per jewelry part and material. Notice that the cost depends on various factors:
- Material type
- Number of materials
- Plating, paints, and coatings
Therefore, it’s more costly to test jewelry products consisting of many different jewelry parts and materials, plating or painted in different colors – compared to a product made of a single material.
Click here for information about testing companies that offer California Proposition 65 lab testing services.
You can either choose to attach a warning label to your product or packaging or verify that the jewelry products you import don’t contain any restricted substances above the limits set by the proposition, via a lab test.
If you want to know more about the applications of this regulation, this website provides information about California Proposition 65 warnings you may have seen on consumer products.
Some jewelry parts and materials contain lead, nickel, cadmium, and other substances above the limits set by CA Prop 65. Keep in mind that far from all jewelry parts and accessories are made specifically for the US market. Importers and Amazon sellers should therefore not take CA Prop 65 compliance for granted when sourcing jewelry products and suppliers overseas.
As mentioned, only a third-party lab test can verify if a jewelry part or material is compliant.
FTC Guidelines Section 23 provide detailed requirements on jewelry labeling and advertising, in order to avoid misrepresentation of the materials or manufacturing process, that is handmade, hand-polished, misrepresentation as to silver or gold content, misuse of the word “cultured pearls”, and more.
a. Gold and Silver Jewelry
For precious metals such as gold and silver, but also platinum, palladium, and others, If any fineness is claimed – for instance, 18 karats, which correspond to 75% of gold, – then the company that assumes responsibility for the claim must carve its own name or trademark near the karat quality mark.
In general, any misrepresentation shall be avoided as FTC claims that a particular claim might be considered as deceptive according to the situation and the net impression of the product packaging, advertising, or other promotional items.
Click here to learn more about Section 23.
b. Pearl Jewelry
FTC Guidelines, Section 23.19 defines the various kind of pearls, such as cultured pearls, imitation pearls, and others. Sections 23.20-23.23 forbids false claims about the nature of the pearls you are importing or selling. For example, you cannot claim that imitation pearls are “real pearls”, “genuine pearls”, “precious pearls” or use similar terms.
Also, although the United States adhere to the CITES (Convention on International Trade in Endangered Species) treaty, pearls are subjected to exemption unless they come from endangered species, which is a pretty rare case given the fact that most imported pearls are cultured.
c. Leather Parts
The FTC provides clear guidelines for leather labeling. In short, the importer or manufacturers shall specify whether the product is made in real leather, imitation leather, or others. Also, as for precious metals, no misleading claims can be made about the leather quality.
Country of Origin
A COO label (Country of Origin) is required to be permanently displayed in the products in the United States. Therefore, make sure your jewelry product or packaging has a permanently affixed country of origin label before shipment.
That said, it may not be possible to affix a label on most jewelry products. There is some flexibility when it comes to the placement of the country of origin label, which can also be placed on the packaging. In other words, you don’t need a big ‘Made in China’ engraving on your gold plated bracelets.
- Made in China
- Made in Vietnam
- Made in Thailand
- Made in India
- Made in Brazil
Before beginning the mass production process, creating a country of origin label file and sharing it with your manufacturer is an essential step. Usually, it includes the text that should be printed on the label as a vector graphic. It helps to guarantee the correctness of the label contents. We recommend that you use either the .ai or .eps format for your country of origin file.
Children’s Jewelry: CPSIA
The Consumer Product Safety Improvement Act (CPSIA) was enacted in 2008 in the US, implemented by CPSC (Consumer Product Safety Commission), for the purpose of imposing new testing and documentation requirements and setting new acceptable levels of some chemical substances on children’s products including.
Children’s jewelry is defined by the ASTM as jewelry designed or intended primarily for use by children 12 and under. They include bracelet, brooch, chain, crown or tiara, cufflink, hair accessories, and more. Click here for more classification of children’s jewelry.
The CPSIA requires that all domestic manufacturers and importers (when products are manufactured overseas) of children’s jewelry must ensure that their products are compliant with all applicable and mandatory ASTM substance restrictions and standards. Such standards, for example, includes ASTM Standard F2923.
Note that ASTM F2923 on Children’s Jewelry does not include toy jewelry, such as jewelry that is used with a doll or stuffed animal. Instead, such products must comply with ASTM F963 for children’s toy products.
Further, CPSIA includes limitations on chemicals and heavy metals in all children’s products.
You can learn more about relevant ASTM standards and rules on this page.
As mentioned, jewelry parts and materials, such as beads and chains, may contain excessive amounts of heavy metals and chemicals restricted by the CPSIA and its referenced CPSC and ASTM standards. It’s therefore important to assess the existing compliance track record when sourcing jewelry suppliers overseas.
This is best done by reviewing their existing test reports, as this indicates that the supplier has experience (and ‘compliant subcontractors’) to make jewelry in compliance with the relevant standards.
US market surveillance authorities require that manufacturers or importers hire a CPSC-approved third-party testing company to verify compliance of the jewelry products intended for children with all requirements before importing and selling children’s jewelry and accessories.
You must take the sample that the laboratory tests from the production run of the exact product you are importing, not from any similar product, or a different production run. This is the case even if your supplier has pre-existing test reports for a similar product.
In most cases, when you request a quotation from a CPSC accepted testing company, the company will, at no additional charge, also help you to determine which ASTM and CPSC standards are applicable to your product. This can be very helpful when importing a new product and material, as it’s not always an easy task to assess applicable ASTM standards.
List of CPSC accepted testing companies
- Bureau Veritas
Click here for more CPSC approved testing companies.
CPSIA Testing Costs
CPSIA testing costs depend on the number of jewelry parts, coatings, and the materials used. As such, testing children’s jewelry consisting of several different materials and colors is therefore rather costly. At the same time, the costs are lower when testing children’s jewelry and accessories made of a single material.
- 5 plastic bead colors
- 1 metal clasp
- Cost: $785
- Plastic bangle (single color)
- Cost: $145
You can read more about CPSIA and ASTM lab testing in this guide.
Children’s Product Certificate (CPC)
Importers of children’s jewelry products must certify, in a written Children’s Product Certificate (CPC) based on test results from a CPSC-accepted lab-testing company, that their children’s jewelry complies with applicable children’s product safety rules. The importer is responsible for drafting and issuing the CPC, based upon the test results of a CPSC accepted third-party testing company.
1. Product name and description
2. List of applied and mandatory ASTM and CPSC standards (e.g ASTM F963)
3. Importer information (name, address, e-mail, phone)
4. Contact information of the person with access to the test report (name, address, e-mail, phone)
5. Manufacturing location (city, province, country) and date (month, year)
6. Testing date (month, year) and location (city, province, country)
7. CPSC accepted third-party lab testing company (company, contact person, address, phone, e-mail)
This guide can help you to understand how to draft a CPC for children’s jewelry.
CPSIA Tracking Label
CPSIA requires that all children’s products marketed for use by children ages 12 or younger must contain distinguishing permanent marks, often referred to as “tracking labels”. Tracking labels should be displayed on the products and its packaging and must include the following information:
- Importer company name
- Production location
- Production date
- Batch number
- Pandora J LLC
- Production Location: Hangzhou, China
- Production Date: July 2020
- Batch Number: ADM01-072020-HZ1-CN
You must prepare the layout and contents of the tracking labels on your own and send it to the supplier, which will then print the label according to the layout. Here are a few things that are most commonly included in the label:
- Print position
- Print type
US State Regulations for Children’s Jewellery
Several states in the US other than California have issued their own regulations concerning the chemicals and heavy contents in jewelry products for children. Please see the following table for more details:
|California||Health and Safety Code § 25214.1-25214.4.2 (Metal-Containing Jewelry Law)|
|Connecticut||General Statutes of Connecticut §21a-12d ‘Children’s Jewelry Containing Cadmium: Prohibition; Enforcement’, (Public Act 10-113)|
|Illinois||430 ILCS 140 ‘Cadmium-Safe Kids Act’ (Public Act 96-1379)|
|Maine||Title 38, Chapter 16-D ‘Toxic Chemicals in Children’s Products’|
|Maryland||Environment, §6-1401 through §6-1404 ‘Cadmium in Children’s Jewelry’|
|Minnesota||2017 Minnesota Statutes §325E.3891 ‘Cadmium in Children’s Jewelry’|
|Rhode Island||Title 23 Health and Safety, Chapter 23-24.11 ‘Comprehensive Children’s Jewelry Safety Act’|
|Washington||RCWA 70.240.00 to RCWA 70.240.040 ‘Children’s Safe Products Act’|
Note that this table doesn’t include all state regulations in the United States.
As mentioned, ASTM standards are referenced by CPSIA. That said, ASTM standards also serve as useful quality guidelines when importing and manufacturing jewelry for adults:
Examples of jewelry ASTM standards
- ASTM F2999, Standard Consumer Safety Specification for Adult Jewelry
- ASTM F2923, Standard Specification for Consumer Product Safety for Children’s Jewelry
You can search for additional ASTM standards on their official website.
You can book lab-testing services for your product from internationally recognized lab-testing companies like SGS, Intertek, QMIA, Bureau Veritas.
In addition to regulations and standards covering jewelry and accessories, the complementary packaging (e.g., jewelry boxes) is also subject to labeling and substance regulations.
Heavy Metals Restrictions
Many states in the US have a strict standard regarding the number of heavy metal contents used in packaging materials, such as lead, cadmium, or mercury. Therefore, it is necessary to have a government-recognized third-party lab testing company to examine the eligibility and compliance of your product packaging.
Intertek, SGS, TUV, QIMA and other product testing companies offer packaging materials testing services.
You may also be required that the packaging prominently display any applicable compliance marks and/or country of origin along with other labels.
Amazon Compliance Requirements
Whether you are or planning to become an Amazon premium seller or third-party seller, before listing your jewelry products on the platform, make sure they have undergone all required lab-tests and are compliant with all mandatory United States product safety standards, certification, and labeling requirements. At the same time, read carefully about the selling rules on Amazon’s platform before launching your jewelry products on Amazon.
Further, keep in mind that the requirements can change over time.
How does Amazon check product compliance?
Be prepared for Amazon’s requests for required lab test reports, certificates, product photos, and invoices, which might come at any time. Amazon is strict with the compliance rules for the products sold on its platform.
What can happen if we sell non-compliant jewelry products on Amazon?
Amazon may remove any product listing at its own discretion. While they usually only remove individual SKUs, they may opt to remove all your listings or suspend your account.