Fashion accessory and luxury goods importers of fine jewelry and costume jewelry containing gemstones and/or precious metals (e.g., gold), should be aware of a current proposal being considered by State Department officials.

State Department officials recently met with trade organizations in NYC to discuss requiring the jewelry industry to declare the country of origin of all materials in products of jewelry. The possible origin declaration requirement would be for all raw materials in jewelry such as diamonds, colored gemstones, metals (such as gold), and the like. Additionally, the new rules might require a declaration of chain of custody, i.e., the movement from owner to owner.

The State Department noted that the new requirements were being considered because the Kimberley Process, an international certification scheme that regulates the trade of diamonds to prevent the sale of conflict diamonds, is inadequate. Specifically, the Kimberley Process has failed to expand its definition of conflict diamonds to include abuses by governments. The State Department believes the unregulated sales of diamonds is therefore funding abusive regimes such as Iran, Venezuela, and countries in Africa, and that providing US consumers with information regarding the origin, and possibly other supply chain information, of the raw materials used in jewelry, is important in the fight against such regimes.

In light of these developments, affected importers should consider closely monitoring the proposed requirement and becoming involved in the process by lobbying themselves or through trade associations. Additionally, importers should begin to review their supply chains to understand how their goods could be affected if the new rules are implemented.