Jewellery: hallmarking and traceability instead of a declaration

Jewellery is one more category that lives outside technical regulations. There is no declaration and no certificate here. Instead there is state control over the circulation of precious metals, mandatory assaying and hallmarking, and traceability of each item in a separate information system. A seller who comes from ordinary retail usually underestimates the amount of requirements.

What is regulated separately

The circulation of precious metals and stones is a separate area of regulation. There are three key elements:

• Special registration. Organizations and entrepreneurs that work with precious metals register with the control authorities.
• Assaying and hallmarking. Products made of precious metals are subject to state assay control. The manufacturer’s mark and the state assay hallmark are applied to them.
• Traceability in an information system. Each item receives a unique identification number, and all operations with it are recorded.

The technical regulations of the Union do not apply to jewellery, so it makes no sense to look for a TR CU for it or to issue a declaration.

Fineness, manufacturer’s mark and hallmark

These are three concepts that people confuse, although they are different things.

A domestically made item without a manufacturer’s mark and a hallmark is not released into free circulation. Imports have their own procedure: imported items also go through assaying and hallmarking, and you cannot sell them before that.

Traceability: what it means in practice

Each item has a unique number, and its whole life, from production or import to the sale to the final buyer, is shown in the state information system. For the seller this means a set of routine duties.

• Registration of the participant of circulation in the system
• Acceptance of a batch with confirmation in the system and not only by the delivery note
• Reconciliation of the physical stock with what is recorded in your name
• Recording of a sale as the withdrawal of the item from circulation
• Recording of returns, losses and transfers between points
• Work with the tags that carry the identifier

The logic is the same as in the labelling of ordinary goods: a discrepancy between the system and the warehouse is already a violation, even if nothing has been lost. A related topic is covered in the article on item-by-item accounting.

Marketplaces and jewellery

The marketplaces treat this category strictly: it needs a special status of the seller and work with traceability, so you cannot sell it “as an ordinary product”.

• They check the special registration
• They require registration in the information system for the circulation of precious metals
• They compare the identifiers of the items
• They control the description separately: the fineness, the metal, the inserts and their characteristics
• They do not allow the sale of items without a hallmark and a manufacturer’s mark

A frequent mistake of newcomers is an attempt to sell items made of precious metals as costume jewellery, to avoid the requirements. This is exposed at the first check of the description and the composition.

What must be in the description and on the tag

• Name of the item and its type
• Metal and fineness
• Weight of the item
• Information on the inserts: name of the stone, characteristics, quantity
• Manufacturer and country of origin
• Identifier of the item
• Price according to the trade rules

The description of the inserts is the place where disputes with buyers arise most often: a natural, an enhanced and a synthetic stone must be clearly distinguished in the description. Silence here is treated as misleading the consumer.

Importing jewellery

• Special registration before the start of operations
• Import through points where state control is provided
• Assaying and hallmarking of imported items before release for sale
• Entering the data into the information system
• Checking that the declared fineness matches the actual fineness; a difference will be found during assaying
• Documents for the inserts, if the stones are declared as natural

The most expensive mistake in imports is to count on a quick sale right after customs clearance. Between the arrival of the batch and the right to sell it there is a procedure that you cannot skip and that is hard to speed up.

Typical mistakes

Steps for a new seller

1. Determine whether the goods really contain precious metals; the whole scheme depends on this.
2. Register for special registration before the first operation.
3. Register in the circulation information system and understand your role: manufacturer, importer or seller.
4. Set up acceptance with confirmation in the system.
5. Check that all items have a hallmark, a manufacturer’s mark and an identifier.
6. Prepare correct descriptions with the fineness, the weight and the characteristics of the inserts.
7. Set up a regular reconciliation of the stock between the warehouse and the system.

If it turns out that the items are made of non-precious alloys, the requirements will be completely different, and then the starting point will be the lists of products and the choice of the form of the document.