Authorised Representative for Jewellery
Manufacturers placing Jewellery products on the EU or UK market have specific obligations under the EU Directives and UK Regulations. These include appointing an Authorised Representative such as International Associates Limited(where the manufacturer is not established in the EU or UK)
The main issue is that there are many different directives that can apply depending on the types of products you supply. If they do not apply it is still recommended to make a declaration stating this to reduce the likelihood of your products getting stopped during shipment.
Whilst we have given information her relating to the EU Directives, most of them are still applicable in the UK after Brexit as they have adopted into UK Legislation and as yet have not been changed due to Brexit. However, it is recommended that you contact us to check for any changes since publication of this guidance.
These can include: –
General product safety Directive EU GPDS & UK Regulation GPSR
The General Product Safety Directive basically states that all products marketed in the EU must be safe to use and forms a framework for all specific legislation established for specific products and issues. If no specific legal requirements have been set for your product and its uses, the General Product Safety Directive still applies. If there are specific requirements applicable to you, the General Product Safety Directive applies in addition, covering all other safety aspects which may not have been described specifically., You can see more about this directive on our separate page here.
REACH (Registration, Evaluation, Authorisation, and Restriction of Chemicals)
This a regulation enforced by the European Chemicals Agency (ECHA). REACH formally took effect in 2007, with the purpose of regulating the concentrations of chemicals, heavy metals, and pollutants in all consumer products manufactured, imported and sold within the European Union countries.
As jewellery is usually worn on the skin, the use of hazardous chemicals is restricted, The EU has restricted a great number (over 1000) chemicals in products that are marketed in the EU. These are listed in the so-called REACH Regulation ((EC) 1907/2006). Which chemicals are of relevance for you will depend on your specific product and materials.
You should also consider Azo dyes If you use textiles or leather in your products, you products should not contain azo dyes that release any of the 22 aromatic amines which are prohibited. The EU legislation lists the aromatic amines, not the azo dyes which release them. The vast majority of azo dyes are therefore legally acceptable. Moreover, most reputable dye manufacturers only produce legally accepted dyes.
However, border rejections and market withdrawals do show that azo dyes still is an issue that causes problems on the EU market, as a number of tested products still show the prohibited aromatic amines and are consequently withdrawn from the market.
If you have any leather products, you need to address Chromium VI in Leather.
In March 2014 new legislation was adopted that restricts the chromium VI content in leather products. Chromium VI compounds can be formed in leather through the oxidation of chromium III compounds, which are added in some tanning processes.
The restriction is that the chromium VI content should not exceed 3.0 mg/kg.
CITES Convention on International Trade in Endangered Species
Applicable to products made from wild plants and animals. If you use parts of wild plants or animals in your product (e.g., shells, coral, leather, animal parts, pearls,and wood), you need to make sure that these are not from endangered species and thus not fall under the restrictions of the Convention on International Trade in Endangered Species (CITES).
The EU has implemented the requirements in “COMMISSION REGULATION (EU) 2019/2117 of 29 November 2019 amending Council Regulation (EC) No 338/97 on the protection of species of wild fauna and f lora by regulating trade therein” and lists restricted species (including products thereof) and special procedures where applicable.
Hallmarks
In many EU countries, a system of hallmarking and control is used to verify the precious metal content in gold, silvermore recently, platinum or palladium jewellery.
The rules on precious metals control are not harmonised in the EU. In some Member States control and hallmarking of every article by an independent body is compulsory, while others have a voluntary hallmarking system or only require prescribed marking by the manufacturer.
You should research if testing and hallmarking is necessary for your product and the country you are exporting to.Check this overview of rules on hallmarking per country
Material Analysis
In order to obtain the hallmark, semi-finished precious items must be analyzed (or assayed) by an official assay office. The duty of the assayer is to verify that the fineness of the product corresponds to the claims of the maker.
If we take gold as an example, a piece of jewellery with a fineness of 750 corresponds to 18 karats, which means that it contains 75% of gold and 25% of impurities and alloy metals. Alloy metals are added to improve hardness, decrease cost per weight, or other purposes.
Similarly, a fineness of 999 corresponds to roughly 24 karats, ie. 99.95% purity.
Thus, a hallmark represents the guarantee that the precious metal purity is equal or superior by the one indicated by the fineness number.
Hallmarking Convention
Hallmarks have a long history; as such, standards and enforcements might vary greatly among countries. In order to solve this problem, in 1972 several European countries signed the Hallmarking Convention (also known as “Convention on the Control and Marking of Articles of Precious Metals”).
Such a convention has the purpose of simplifying the trade of precious metals among the signatory states, which at the moment include Ireland, the Netherlands, Sweden, and other 17 countries.
Jewellery that conforms with the convention standards receives the Common Control Mark (CCM).
Directive 94/62/EC: Packaging and packaging waste
Beside the Jewellery specific regulations, importers must also familiarize themselves with the Directive 94/62/EC, an EU directive covering heavy metals contents product packaging.
Directive 94/62/EC requires that materials, printing inks, and dyes in packaging contains levels of heavy metals below certain limits. Restricted heavy metals include lead, mercury, and cadmium.
The structure of the packaging and choice of materials should be designed for collection, reuse, and recycling
The packaging may also need to prominently display compliance marks and other requisite labels.
Sustainable performance
Although not mandatory Sustainability is one of the ways for companies to differentiate themselves, and the means of offering sustainable products are numerous, ranging from recycling to choice of sustainable materials, sustainable design, improved social (working) conditions to certification and use of labels
Ther are various schemes that manufacturers can implement on a voluntary basic such as:-
ICMM (sustainable mining),
RJC (Responsible Jewellery Council)
IRMA (Initiative Responsible Mining Assurance).
Fair Trade Initiative
International Associates Limited is an Accredited Certification Body for the RJC, you can see more about the scheme on our services page here.Obligations of the Authorised Representative
Manufacturers are able by written mandate to appoint authorised representatives to performall, or part of the obligations and formalities imposed on manufacturers (either asmanufacturers or responsible persons) by the Directives and Regulations.
International Associates Recommended Scope:
Although the Directives and Regulationsconfirm that much of the compliance requirements can be carried out by the manufacture or his Authorised Representative, such as; carrying out a risk assessment etc Our experience is that most clients will complete these activities themselves, hence we recommend that our responsibilities are limited to the following.:-
a) Keep the Declaration of Conformity and the technical documentation at the disposal of national market Surveillance authorities for 10 years after the pressure equipment or assembly has been placed on the market;
- Documentation check
- Verify the Declaration of Conformity
- Review the Technical Documentation
- Check where applicable that an appropriate conformity assessment exist and Notified Body validity
- Keep the previous documentation (Declaration of conformity, Technical Documentation, certificates issued by Notified Body and amendments) at the disposal of competent authorities (at least ten years)
- Record Retention and Document control, including version controls.
- Ensure Labelling is correct and includes the details of the Authorized Representative.
b) Further to a reasoned request from a competent national authority, provide that authority with all the information and documentationnecessarytodemonstratetheconformityoftheproductorassembly;
c)Cooperatewiththecompetentnationalauthorities,attheirrequest,onanyactiontakentoeliminatetherisksposed bythepressureequipmentorassemblycoveredbythe authorized representative’smandate.
Changing your Authorised Representative.
Changing your Authorised Representative is a fairly straightforward process. First of all, this change should appear in the agreement between the manufacturer and the Authorized Representative (Outgoing and incoming).
To be compliant, the manufacturer should address the following aspects:
The date of termination of the outgoing Authorized Representative and the date of start of the incoming one.
The date until which the manufacturer can show the outgoing AR on the information or promotional material.
The transfer of documents, including confidentiality aspects and property rights
The obligation to the outgoing Authorized Representative to send to the manufacturer or incoming Authorized Representative, any complaints or reports about suspected incidents related to the product for which it has been designated.
Contact Us
For more information about Authorised Representative Jewellery please contact us by using our contact form, by phone or drop us an email. We will be pleased to assist you.
Alternatively get a quote by filling in our enquiry form
