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FAQ EU Restrictions on Diamonds
GENERAL
What does the G7 certificate stand for?
All rough diamonds that have passed G7 verification through Antwerp, Belgium as designated G7 authority, receive a G7 certificate. This a 35-digit number that is mentioned on the import declaration under box 44. This number is the reference that needs to be used to evidence that polished diamonds originate from verified rough.
As of Sept 1, it will be mandatory to be able to evidence this using digital traceability data. G7 numbers will be used as unique identifiers in this process and need to be included as the diamonds go through the value chain.
What is the diamond import ban?
Last update: 22 December 2023
On 6 December 2023, building on the statements of February and May 2023, the Leaders of the Group of Seven (G7) agreed to introduce import restrictions on non-industrial diamonds, mined, processed, or produced in Russia, by 1 January 2024, followed by further phased restrictions on the import of Russian diamonds processed in third countries targeting 1 March 2024.
The EU sanctions on Russian diamonds contained in the 12th sanctions package (Article 3p of Council Regulation No. 833/2014) are part of this concerted G7 effort to introduce an internationally coordinated diamond ban, that aims at depriving Russia of this important revenue stream estimated at EUR 4 billion per year, of which approximately EUR 1.5 billion are annual imports into the EU.
The European Commission has been engaging with G7 countries and other key partners, including industry, with the aim of designing and ensuring the effective implementation of coordinated restrictive measures, including through tracing technologies across G7 and EU countries to have an effective impact.
What documents are required to import rough or polished natural diamonds into the EU?
To import rough or polished natural diamonds into the EU using documentary evidence, a set of minimum information is required to be prepared and available prior to, or at the time of importation.
For rough and polished natural diamonds, the following cumulative information is required to be available.
Mining country of origin.
Names of buyer and seller.
CN codes and description.
Number of parcels in a shipment.
Weight in carat of the diamond(s) if at least one diamond (if multiple diamonds are shipped in a parcel) is of 1.0 carat or above.
Value of the diamonds.
Place of importation, exportation, and route of transportation as applicable depending
on the lifecycle of the diamond(s) prior to importation in the EU.
The type of documents containing the above information required for submission with entry may vary. But it is the importer’s responsibility to ensure the documentation meets all the above information requirements. As an illustrative and non-exhaustive list, please consider the below examples of documentation.
For rough natural diamonds
- KP certificates with single origin for diamonds at or above 1.0 carat.
- KP Mixed origin from De Beers DTC "Botswana Sort"
- KP certificates with mixed origin accompanied by documentary evidence, proving that no diamonds at or above 1.0 carat in the shipment are mined in Russia, are recognised during a transition period between 1 March 2024 to 31 August 2024, after which only KP certificates with single origin or De Beers DTC mixed origin* will be accepted.
Additional documents proving the required information may include:
- Customs declaration form
- Invoice
- Packing list
- Transport documentation, e.g. waybill document
- Evidence from traceability systems
For polished natural diamonds
- Signed attestation or supplier declaration confirming that none of the diamonds at or above 1.0 carat in the shipment are mined in Russia. Download the template here.
Evidence supporting the attestation or supplier declaration is mandatory and may include:
- Customs declaration form
- Invoice
- Packing list
- Transport documentation, e.g. waybill document
- Laboratory grading report
- Evidence from traceability systems
While optional (except for goods of CN codes 7102 31 00 and 7102 10 00 with a weight equal to or above 1.0 carat), it is recommended that importers consider using the G7 import node in Belgium (see Question 9 above) by the end of the sunrise period (31 August 2024) to obtain a G7 Certificate, to support transition to the requirement starting 1 September 2024. Rough diamonds are preferably imported using single origin KP certificates. Rough diamonds imported using mixed origin KP certificates will be able to receive a G7 certificate, provided documentary evidence demonstrates (including for imports in the EU) non-Russian provenance of diamonds during the sunrise period (1 March – 31 August 2024). The documentary evidence does not apply to De Beers DTC mixed origin* KP certificates.
Canada may develop a node to issue G7 certificates for Canadian diamond mining producers, which could be operational by 1 September 2024.
* De Beers’ so-called ‘Botswana Sort’ diamonds are accepted because they consist of aggregated diamonds not mined in Russia (Botswana, Canada, Namibia and South Africa).
What are the different stages of the diamond ban?
Last update: 22 December 2023
Article 3p of Council Regulation No. 833/2014 prohibits the purchase, import, or transfer of Russian non-industrial diamonds in several stages:
- As of 1 January 2024, diamonds (natural and synthetic) and products incorporating diamonds (jewellery) listed in Parts A, B and C of Annex XXXVIIIA of Council Regulation No. 833/2014 are banned if they originate in Russia or have been exported from Russia. The same applies to such goods (of any origin) if they transited through Russia;
- As of 1 March 2024, the prohibition applies also to Russian natural diamonds as listed in Part A of Annex XXXVIIIA that have been processed in a third country, consisting of Russian diamonds equal to or above 1.0 carats per diamond;
- As of 1 September 2024, the prohibition applies also to Russian natural and synthetic diamonds and jewellery incorporating Russian diamonds (all products listed in Parts A, B and C of Annex XXXVIIIA) that have been processed in a third country,
consisting of or incorporating diamonds originating in Russia or exported from Russia with a weight equal to or above 0.5 carats or 0.1 grams* per diamond.
* Synthetic diamonds are measured in grams in the Combined Nomenclature (1 carat = 0.2 grams)
PROCEDURE
Procedure 1 (coming soon)
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Procedure 2 (coming soon)
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Procedure 3 (coming soon)
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Procedure 4 (coming soon)
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PRACTICAL
Which documents do you need for Rough diamond imports?
Each shipment you intend to declare must be accompanied by a complete set of documents, including:
a) It is recommended to include a packing list indicating whether the shipment includes diamonds of 1 carat or larger.
b) For ROUGH diamonds, the following documents are mandatory:
The mining country of origin, established through:
- A single origin Kimberley Process certificate, OR
- A mixed origin Kimberley Process certificate for De Beers Botswana Sort, OR
- A mixed origing Kimberley Process certificate: please note you will need additional documentary evidence proving the origins in the mixed parcel
An invoice detailing:
- Names of the buyer and seller,
- Total shipment value
- Total carat weight of the shipment
- Customs code and description.
An Airway Bill (AWB) outlining:
- Import and export locations
- Transportation route of the shipment.
Which documents do you need for Polished diamond imports?
Each shipment you intend to declare must be accompanied by a complete set of documents, including:
a) A packing list indicating whether the shipment includes diamonds of 1 carat or larger.
b) For POLISHED diamonds the following documents are required:
A signed supplier declaration (download template here), this can be:
- A declaration on the invoice, OR
- A separate declaration from the supplier, OR
- A separate declaration from the importer
An invoice, with:
1. The names of the buyer and the seller, AND
2. The total value of your shipment, AND
3. The total weight of your shipment in carat, AND
5. The customs code and description
6. If known, information about country of mining origin or "non-Russian origin"
An Airway Bill (AWB), with:
- The name of the place of importation, AND
- The name of the place of exportation, AND
- The route of transportation of your shipment
What text should be on the import declaration for polished diamonds?
“I hereby declare that the non-industrial, natural diamonds in this shipment were not mined, produced, extracted, or manufactured wholly or in part in the Russian Federation, notwithstanding whether such diamonds have been substantially transformed into other products outside of the Russian Federation.”
You can download the declaration here.
Practical 4 (coming soon)
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GRANDFATHERING PROCEDURE
What is the definition of "Grandfathered Goods"? (Existing stock)
Grandfathered goods are rough and polished diamonds of Russian or unknown origin which you purchased before January 1st 2024 and which are still in your stock.
How can I use existing stock, so-called "grandfathered" goods?
A system to accommodate existing rough and polished stocks of Russian origin (purchase predating sanctions) and of unknown origin is being discussed by G7. As soon as more information becomes available we will update this information.
What do we do about goods bought from clients (recycled diamonds)?
Recycled diamonds fall under grandfathered or existing stock rules and will be part of a system currently being decided by the G7 to accommodate existing/grandfathered stock.
What does the following phrase mean: "GOODS NOT SUBJECT TO RESTRICTIONS OF REJ EU 833/2014"?
Goods that are out of scope or potentially goods purchased before restrictions came into effect.
When buying jewelry from private people: How do you prove they are not Russian?
Jewelry is currently not in scope, personal jewelry will never be in scope.
Referring to Regulation 833/2014 Question 9 on the import of polished diamonds (+0.5ct), do I understand correctly that after Sept 1st, they will have been traced back to their G7 rough certificate?
Yes
Does this (previous question) mean that all polished stones (+0.5cts) will have to have passed Antwerp as a rough stone before?
Yes
What does this (previous two questions) mean for old polished diamonds in stock and regularly are sent around the world and will be for many years. How will they have to be imported after Sept 1st?
A system to accommodate existing rough and polished stocks of Russian origin (purchase predating sanctions) and of unknown origin is being discussed by G7.
What will the GF number look like?
Like the G7 number, the GF number will consist of 35 digits, structured as “GF+33 digits”, which will be issued by the FPS Economy
Who is responsible for informing the Diamond Office that we are talking about Grandfathered stock?
The person shipping the goods is responsible for informing the diamond office that the goods are grandfathered and/or need to be grandfathered. This can be done on the shipping documents or, alternatively, through the template below.
What if I have not yet submitted my stock declaration by July 1st, 2024?
Should you not have declared your stock of 31 December 2023 by the time this document is released, you will not be eligible to have your goods grandfathered through mechanism (A), but would have to work with mechanism (B).
Who will issue the GF number, and where can this number be found?
The FPS Economy will issue the GF number, and this which will be declared on the customs forms.
TRACEABILITY
Can spot checks take place with GF goods? What would spot checks look like in terms of GF goods?
FPS Economy will perform spot checks as it has always done in the function of stock declaration submissions on the enterprise-bookkeeping level and, should it be deemed necessary, on the shipment level.
Can a GF number be issued for polished diamonds?
Yes, unlike G7 numbers, which are only issued to rough diamonds, each shipment, whether rough or polished, can receive its own GF number. This would be for all goods declared on the stock declarations, not just for diamonds that are considered in scope (0,5 carats and larger).
Do goods being traded on the internal market need to pass through the Diamond Office?
No, goods being traded within Antwerp from 2 Belgian-registered diamond companies do not need to pass through the Diamond Office as they will not receive a GF number. A GF number is only issued when you move goods OUT of your stock and pass-through DO.
What is the difference between a G7 and a GF number?
To receive a G7 number, you have to prove the origin of your goods through evidence. G7 numbers are only issued to rough diamonds whose origin is known and not Russian.
For GF goods, you have to prove that your goods were part of your stock before 31/12/23 based on date-stamped evidence. GF numbers can be issued for both rough and polished goods.
If you have stock that was declared on your stock declaration but where you do not know the origin, those goods can receive a GF number.
How would Belgian-registered Diamond companies inform DO about national trading (practical guidelines/procedures)
Suggestion on Page 3:” Selling stock from a Belgian-registered Diamond Company to a Belgian-registered Diamond Company (internal market trading)”.
Is there a declaration that we need to put on our invoices if we are talking about grandfathered goods?
Suggestion for the declaration on the invoice for grandfathered goods, similar to the one for a G7 shipment:
"I hereby declare that the non-industrial, natural, or synthetic diamonds in this shipment are of unknown or Russian origin and were in the possession of a Belgian-registered diamond company and declared on their stock declaration submitted for the year ending 31 December 2023. These goods are 'Grandfathered goods."
Which Customs codes are relevant?
7102.10 Natural, rough, non-sorted diamonds
7102.31 Natural, rough sorted diamonds
7104.21 Synthetic/lab-grown, rough diamonds
7102.39 Natural, polished diamonds
7104.91 Synthetic/lab-grown, polished diamonds
How will G7 certificate numbers be used in future? How will these be linked with polished goods when they have been imported initially as G7 certified rough?
Through traceability tech, the G7 number will be used as an identifier in the transformation of rough to polished alongside other data captured in that process which is added to the traceability track.
Will we be obliged as a tender house to have a traceability system in place by September, and always share origin info with the clients that buy rough?
All industry players will be obliged to use traceability systems, your clients will need the traceability data in their operations so if you don’t provide it this will lead to problems for your buyers.
Will the traceability system we put in place be audited, and if so, by who?
They will be independently audited by a 3rd party
Which platform can I use for traceability?
The process of setting criteria and validation is ongoing. As soon as more information becomes available we will add it here.
The industry has no idea about the requested traceability and blockchain mandate - could you elaborate?
We will host a separate webinar as soon as details are known.
KP & ORIGIN
What is the link with Kimberley Process (KP) certification?
Last update: 1 March 2024
The KP has a key role to play in controlling rough diamonds and ensuring that they are conflict free. The sanctions on Russian diamonds apply to both rough and polished diamonds. The system of implementation of the sanctions on diamonds will complement KP certification and verifications and will use the KP certificate - of single origin - as part of its verification.
The control measures of the ban on Russian diamonds will be implemented in phases. From 1 January 2024 the use of KP certificates will be accepted as evidence of country of origin for imports of rough diamonds. From 1 March a traceability system in the form of a Blockchain based G7 ledger will be in use but KP certificates will still be accepted as evidence of country of origin if no Russian diamonds are mixed with other origins. While mixed parcels will be accepted, as the certificates for such parcels do not disclose the origin, it is therefore needed to provide, in addition to the KP certificate, evidence proving that diamonds, over the weight threshold, are of non-Russian origin. As of 1 September 2024, the obligation to use the G7 ledger for rough diamonds will be mandatory under the EU’s restrictive measures while the KP certification requirements will continue to apply. However as of 1 September 2024, only KP certificates with single origin or De Beers DTC mixed origin, will be accepted (see Question 12).
KP & Origin 2 (coming soon)
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KP & Origin 3 (coming soon)
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KP & Origin 4 (coming soon)
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DIAMOND OFFICE
How come such a webinar wasn't organized a few months prior to the implementation of the EU law, while AWDC knew the major requirements and implications this would have to the industry?
Because most of the requirements were decided and published by G7/EU on or after March 1st.
How can you guarantee that compliant shipments will have priority for clearance at DO?
Because shipment processing is now based on whether or not they fit all requirements and the submission for import has all necessary documents.
What does delay the import clearance at DO? And is there something we can do to fast track the goods?
Make sure your shipment and documents fit the requirements mentioned in the decision tree.
Could you share with us what the G7 certificate looks like? We have been informed that this is a 35 character number and suggest creating QR code instead.
35 character number remains but will be embedded in a digital certificate including QR code
SPECIFIC EXAMPLES
For a shipment containing a mix of -1ct and +1ct stones, do I need 2 invoices?
No you do not need 2 separate invoices.
If you mix diamonds in scope and out of scope, the rules of diamonds in scope apply. Follow the decision tree on requirements, depending rough or polished you will have different requirements.
As long as you separate the parcels for what is in scope (= or > 1ct) and not in scope (< 1ct), and indicate this on your packing list you only have to fulfill the additional requirements, e.g. declaration for polished, for the parcels in scope.
CLARIFICATION:
(= or > 1ct): equal to or larger than 1 carat -> IN SCOPE
(< 1ct): smaller than 1 carat -> OUT OF SCOPE
Specific examples 2 (coming soon)
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FUTURE: TRANSIT
What about transit goods? When will the system be in place?
Transit goods ref FPS Economy, depends on the willingness of customs agencies outside of EU to accept the sealing to be broken and resealed, a necessary step to do G7 verification.
What about transit goods from De Beers goods bought from the secondary market?
Secondary market goods need to have a G7 verification number, which whoever sells to you should mention on the invoice of the goods you buy. De Beers goods are not exempt of having to pass G7 verification
FUTURE: SEPTEMBER
More answered questions coming soon...
INDUSTRY / PROTOCOL
Will it cost us more money to get G7 certified goods
We refer to point 2.17 of the Q&A of the G7, the estimated cost should be limited, a minimal, flat fee would apply, eg 20$ regardless of value.
As a tender house do we need to add the G7 number on the invoice?
A G7 number is issued on the import declaration, box 44 at the end of the import verification. Once goods are imported and G7 certified, it is recommended to all industry players to add the G7 number on invoices when selling the goods. Having this G7 number will be necessary to demonstrate the verified origin of the rough for example when goods return as polished after polishing outside of the G7/EU.
Can the US correspondent bank block a USD payment for a diamond transaction because of the last Russian sanctions? If yes, can the bank block a payment for a transaction outside of the G7?
If the bank suspects this payment will benefit a sanctioned entity, yes, OFAC sanctions US and Financial sanctions apply.
Is there really a scientific approach or just a paper declaration to check the goods origin? If only paper declaration then why limit to 0.50carats weight, not same process for all rough and polished imports?
Currently for both rough and polished, physical and documentary evidence checks are performed. As of Sept 1, the use of digital traceability will be mandatory.
BEYOND BELGIUM / INTERNATIONAL
More answered questions coming soon...
EXPORT
What about exports? What are the procedures and do you have a guide for the requirements of other countries?
Other jurisdictions have different requirements, the goal of the G7 initiative is exactly to have alignment, we will continue to strive for clarity in other jurisdictions, where clear guidelines are published, we will add them to our webpage www.awdc.be/en/g7.
Do we need specific documents or declarations to export (from Antwerp) a +1ct diamond to another country?
Sanctions only apply to import, for export normal rules of DO continue to apply.
To ensure the information is accurate, check the import regulations you are exporting your goods to for the latest & most up-to-date information.
Many suppliers only say non Russian for 1ct+, but some countries require exact origin of rough. How do we adapt to that?
This is brought to the attention of the EU Commision and G7 partners regularly. If you have examples it is important to flag them, so this info can be shared with other partners as soon as possible. In case you have examples, it is important to provide substantial evidence of exact cases, and not just hearsay.
JEWELLERY
Can I travel with diamond jewellery to and from Russia?
Last update: 22 December 2023
Yes, the prohibition of Article 3p does not apply to jewellery incorporating Russian diamonds for personal use of natural persons travelling to the European Union or of their immediate family members travelling with them, as long as it is owned by those individuals and not intended for sale.
A similar exemption also applies to the gold ban of Article 3o and to the ban on exports of diamond jewellery included in the luxury goods list in Annex XVIII of Council Regulation No. 833/2014 (Article 3h).
Is diamond jewellery incorporating Russian diamonds banned?
Last update: 22 December 2023
Yes, as of 1 January 2024 it is prohibited to purchase, import, or transfer jewellery incorporating Russian diamonds as listed in Part C of Annex XXXVIIIA of Council Regulation No. 833/2014 if it originates in Russia or has been exported from Russia. The same applies to jewellery incorporating diamonds of any origin that transited through Russia.
In addition, as of 1 September 2024, this prohibition is extended to jewellery that has been processed in a third country, incorporating diamonds originating in Russia or exported from Russia with a weight equal to or above 0.5 carats or 0.1 grams per diamond.
Furthermore, there is a ban on gold jewellery (Article 3o) and precious metal jewellery (Article 3i) from Russia.
Questions?
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Please note:
- Questions will only be answered if they haven't previously been asked/responded to.
- Questions will be responded to within a week.
- The Questions and Answers will be uploaded to this page.