Important new hallmarking requirements for jewellery importers and exporters after Brexit

Did the Brexit deal include anything about hallmarks?

The transition period ended on the 31st of December 2020. The deal negotiated between the UK and the EU did not include any agreements on the continued mutual recognition of national hallmarks between the UK and EU members.

As of the 1st of January 2021, the UK’s previous obligation to recognise EU and EEA national marks ended and similarly the obligation on EU countries to recognise UK national hallmarks also ended.

What does Brexit mean for companies selling EU products in the UK?

Any product bearing an EU national mark, which was placed on the UK market before the 1st of January 2021, can remain on the UK market as it was placed on the market before the end of the transition period. Retailers must be able to provide proof that the goods were placed on the market prior to 1st of January 2021.

Any new product entering the UK market must either have a UK hallmark or a Common Control Mark (CCM.) As a signatory to the International Hallmarking Convention, the CCM will continue to be recognised in the UK.

What does Brexit mean for UK companies selling product in the EU?

Any product carrying a UK national mark, which was in free circulation within the EU, prior to the 1st of January 2021, will continue to be legal in the EU providing there is proof that it was placed on the market before the cut-off date. If product carries a CCM it will continue to be accepted by those EU Member States, if they are also signatories to the Convention.

Which countries are signatories to the Convention?

The Current list of signatories to the International Hallmarking Convention are as follows:

Austria, Croatia, Cyprus, Czech Republic, Denmark, Finland, Hungary, Ireland, Israel, Latvia, Lithuania, Netherlands, Norway, Poland, Portugal, Slovak Republic, Slovenia, Sweden, Switzerland, Serbia and the UK.

Italy have been invited to join and their Parliament are in the process of ratifying the treaty but they will also accept the CCM mark now.

It is also important to remember that the UK exemption weights of 7.78grams for silver, 1gram for gold/palladium and 0.5grams for platinum, may not apply in other countries. For example, in the Republic of Ireland there are no exemption weights. This means that any stock destined for southern Ireland must bear a CCM. You can find details of exemption weights, and accepted finenesses for each Convention signatory country here.

What are the requirements in the EU countries that are not members of the Convention?

Luxembourg and Germany do not require a hallmark as a pre-market authorisation.

In France, a hallmark is a legal requirement. Importers must register with the bureaux de garantie.

In Spain, a hallmark is a legal requirement. Importers must register with an assay office in Spain. Ministry of Industry, Trade and Tourism.

There are legal requirements regarding hallmarking in Belgium. See the Federal Ministry of Finance’s factsheet (PDF).

Will the CCM cost more?

There is no additional cost in applying the CCM. If you have combination punches that you have purchased, then these may need to be replaced. You can add a CCM to an already hallmarked item for a little as 20p per article.