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24 May 2019
Fashion accessory and luxury goods importers of fine and costume jewellery containing gemstones or precious metals (eg, gold) should be aware of a proposal being considered by Department of State (DOS) officials.
DOS officials recently met with trade organisations in New York City to discuss requiring the jewellery industry to declare the country of origin for all materials used in jewellery products. The possible origin declaration requirement would be for all raw materials used in jewellery (eg, diamonds, coloured gemstones and metals (eg, gold)). In addition, the new rules might require a chain of custody declaration (ie, the movement from owner to owner).
The DOS noted that the new requirements were being considered because the Kimberley Process – an international certification scheme that regulates the diamond trade 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 DOS believes that the unregulated sale of diamonds is therefore funding abusive regimes in Iran, Venezuela and some African countries. According to the DOS, providing US consumers with information regarding the origin (and possibly other supply chain information) of raw materials used in jewellery 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. Importers should begin to review their supply chains to understand how their goods could be affected if the new rules are implemented.
For further information on this topic please contact Anthony V Lupo, Teresa Polino or Elyssa R (Emsellem) Kutner at Arent Fox LLP by telephone (+1 202 857 6000) or email (email@example.com, firstname.lastname@example.org or email@example.com). The Arent Fox LLP website can be accessed at www.arentfox.com.
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