Update on G7 Sanctions: the Sixteenth Sanction Package against Russia

What are the key takeaways?

1. Key Takeaway 1: Essentially there are no changes to scope or documentary evidence requirements for importing diamonds. To import rough diamonds into the EU for the first time, from mixed origin, it is mandatory, as from March 1, 2025, to present a KP Certificate that mentions all countries of origin of the diamonds in the shipment. If available, please provide on the other accompanying documents (invoice, packinglist…),  the breakdown of countries of origin in percentage of the diamonds in the shipment. KP Certificates with Mixed Origin*** will no longer be accepted. This also applies to rough diamonds from mixed origin, coming from mining companies who aggregate their rough production themselves. This does not apply to rough diamonds that are already G7-verified.  
2. Key Takeaway 2: The date on which traceability-based evidence must be provided when importing all diamonds that fall within the scope of the measures will be postponed to January 1, 2026. 

Key Takeaway 1 (Concerning the shipments of diamonds with mixed origin): What does this mean?

Import

What does this mean for diamond companies in Antwerp who IMPORT rough diamonds to the EU from abroad starting March 1, 2025?

• Import of single origin diamonds: nothing changes.
• Import of mixed origin diamonds: when importing rough diamonds that fall within the scope* of the sanctions, that are being imported into the EU for the first time, and that are of mixed mining origin, it is mandatory to present a KP Certificate mentioning the exact countries of origin of the rough diamonds in the shipment (and optionally, if available, the breakdown of countries of origin in percentage). This also applies to rough diamonds from mixed origin, coming from mining companies who aggregate their rough production themselves. For shipments that were previously verified and certified with a G7 certificate, the above requirement does not apply, and Mixed Origin*** can still be mentioned. For shipments that contain both first shipments and already G7-verified parcels, you have to follow the correct procedures for both individually.

Export 

What does this mean for diamond companies in Antwerp who EXPORT rough diamonds from the EU to abroad starting March 1, 2025? This measure was not included in the G7 16th Sanction Package but is a logical consequence of the Package.

• Export of single origin diamonds: nothing changes.
• Export of mixed origin diamonds: when exporting rough diamonds that fall within the scope and with mixed origin, all countries of origin of the rough diamonds in the shipment must now be provided. The different countries of origin should preferably be listed on the invoice. Alternatively, they can be recorded on a self-declaration form.

The new regulations for rough diamonds do NOT apply to:

• Rough diamonds that fall outside the scope
• Rough diamonds that are already G7-certified
• Rough diamonds benefiting from the Grandfathering principle
• Synthetic and polished diamonds

Key Takeaway 2 (Concerning the extended deadline for the requirement to provide traceability-based evidence for diamond imports): What does this mean?

AWDC, in constructive collaboration with the Belgian government, has successfully negotiated with the G7 to postpone the deadline for providing traceability-based evidence for the import of all diamonds within the scope of the measures. The new deadline is set for January 1, 2026.

The reason why AWDC and the Belgian government have insisted on postponing this deadline is because there is currently too much uncertainty about the nature and governance of the traceability mechanism (which will generate the required traceability-based evidence). These aspects must first be clarified by the G7. By pushing back the deadline to January 1, 2026, diamond companies now have much needed time to adequately prepare for its implementation in their daily operations.

What are our next steps:

• AWDC will use this time to support and guide Antwerp-based diamond companies in preparing for the mandatory implementation of the traceability system in their operations. We will do this, among other things, by identifying the needs within the market, organizing various information sessions on topics related to the traceability mechanism, …

   

• The EU, together with its G7 partners, will use this time to continue working on various aspects to ensure the credibility and clarity of this diamond traceability mechanism:
  • Governance: In order to ensure the verification of traceability-based evidence is credible, this initiative needs to encompass solid governance mechanisms embedded in a broad G7-led structure. This governance structure is an essential component of any proposed mechanism to verify traceability-based evidence on the origin of rough and polished diamonds. This also includes matters such as financing of the mechanism, data security and protection and independent traceability standards and validation.
  • Level playing field: To further facilitate the implementation of these measures and maintain engagement with the G7 and third countries, ongoing monitoring of the level playing field among G7 partners regarding diamond-related matters should be conducted. AWDC, together with the Belgian Government, has stressed to the European Union that a level playing field across the entire G7 is a necessary condition to move towards traceability requirements, demanding that a thorough and continuous evaluation is conducted to ensure the European diamond and jewelry industry is not harmed disproportionally by additional restrictions. 
  • Engagement with stakeholders outside the G7: AWDC, together with the Belgian government, has underscored that continuous active engagement with stakeholders outside of the G7 should remain a top priority, for example through the establishment of Export Verification Points in African producing countries.  

*all natural, non-industrial, rough diamonds equal to or larger than 0.5 carat