Precious metals, hallmarking and fine jewellery

• National hallmarking laws and the Vienna Convention on the Control of the Fineness
• Regulation (EU) 2023/988 — GPSR
• Regulation (EC) No 1907/2006 — REACH
• Directive (EU) 2015/849 — AML for dealers in precious metals

Who has to appoint one

Sellers outside the Union placing precious metal articles on the EU market. Hallmarking is not harmonised: several member states operate compulsory assay office marking, others recognise manufacturer's marks, and the rules differ enough that a single approach fails.

Thresholds and exemptions

Hallmarking thresholds are set nationally by weight and metal. AML obligations attach to dealers above the cash transaction threshold.

What must appear on the label

The fineness mark and, where required, the assay office mark and the responsibility mark, applied physically to the article. Manufacturer and responsible person details for GPSR purposes, and nickel release compliance for items in skin contact.

Marketplace fields

Marketplaces require the responsible person, and precious metal claims are checked because misdescription is both a consumer and a criminal matter in several member states.

Documentation you must hold

Technical documentation and risk analysis, assay certificates or registration with the national assay office where compulsory, AML customer due diligence records, and REACH evidence for nickel and cadmium.

Standards and testing

Fineness assay by an approved laboratory or assay office, nickel release under EN 1811 for skin-contact items, and cadmium and lead screening under REACH.

Language requirements

Any written material information in the language of the member state of sale.

When it applies

Hallmarking before offering for sale in member states with compulsory marking.

How long records are kept

Ten years for product documentation, five years for AML records.

What happens if you do not comply

Seizure and criminal proceedings for false fineness marking, which several member states treat as fraud rather than as a labelling infringement.

Who enforces it

National assay offices, market surveillance and consumer protection authorities, and financial intelligence units.

Where the boundary lies

Hallmarking remains national despite mutual recognition case law, and a foreign hallmark is not automatically accepted. Plated and filled items must be described accurately, since 'gold' applied to plated goods is a misdescription.

Questions we are asked

Is one hallmark valid across the EU?

Not automatically. Several member states require their own assay marking, though mutual recognition principles apply to marks from Convention states.

Are plated items regulated?

They must not be described in a way that suggests solid precious metal, and nickel release rules apply to the base metal in skin contact.