FAQ EU Restrictions on Diamonds

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 tracing technologies across G7 and EU countries to have an effective impact.

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)

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 must be used to prove that polished diamonds originate from verified rough. A G7 certificate is only issued upon import of diamonds via Diamond Office. 

The digital traceability of diamonds will be mandatory as of March 1, 2025. From then, G7 numbers will be used as unique identifiers and must remain with the goods as the diamonds go through the value chain. 

From September 1, 2024, all non-industrial, natural, or synthetic ( laboratory-grown / lab-grown) diamonds (both rough and polished), equal to or larger than 0,5 carat are in scope.

Important: a G7 certificate is only issued for when importing natural rough diamonds in the scope of the G7 sanctions (thus equal to or larger than 0,5 carat, of non-Russian origin). There is no G7 certificate issued for polished (natural and synthetic) diamonds nor for synthetic rough diamonds. Also no G7 certificate is issued when exporting diamonds. 

No, you don't. Although synthetic diamonds (rough and polished) equal to or larger than 0,5 carat are in the scope of the G7 sanctions, no G7 certificate will be issued when importing synthetic rough diamonds via Diamond Office. 

The G7 certificate is only issued for natural rough diamonds equal to or larger than 0,5 carat of non-Russian origin. 

You can use this detailed 'G7 decision tree' (downloadable at the bottom of this page), which guides you through the process of G7-certifying your goods step by step. 

You only receive a G7 certificate for the import via Diamond Office of rough diamonds equal to or larger than 0.5 carat (= goods in scope). 

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.

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 0,5 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 origin 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, AND

- Total shipment value, AND

- Total carat weight of the shipment, AND

- Customs code and description.
 
An Airway Bill (AWB) outlining:

- Import and export locations, AND     

- Transportation route of the shipment.

Diamond Office Template - G7GF Declaration

In case of import or export via Diamond Office, your goods must be accompanied by a completed and signed version of the 'Diamond Office Template - G7GF Declaration'. You can find the 'Diamond Office Template - G7GF Declaration' at the bottom of this page. 

Yes. Russian goods can still be exported since the G7 has only implemented a diamond import ban (which prohibits Russian diamonds from being imported into the G7 and EU markets). There is no diamond export ban. 

Keep in mind that:

• When selling Russian diamonds to a foreign company, all usual export documents have to accompany the goods.
  • These goods cannot come back to Belgium (import ban on Russian Diamonds ≥ 0.5 ct).
     
• When you (as a Belgian-registered diamond company) want to export Russian diamonds that were already in your possession before January 1, 2024 and you want to regularize them (and thus make use of the Grandfathering-principle), you must inform the Diamond Office of this transaction by completing the 'Diamond Office Template - G7/GF declaration' (you can find this template on the bottom of this page). All regular export documents must further accompany your goods. 
  • These goods will receive a GF-number
  • Do note that if these goods return (e.g. consignment) to Belgium, this is only possible if they have a GF-number. 
  • Russian goods will never receive a G7-number (upon import).

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.

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 0,5 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

Diamond Office Template - G7GF Declaration

In case of import or export via Diamond Office, your goods must be accompanied by a completed and signed version of the 'Diamond Office Template - G7GF Declaration'. You can find the 'Diamond Office Template - G7GF Declaration' at the bottom of this page. 

As of Sept. 1, also synthetic diamonds equal to or larger than 0,5 carat are in the scope of the G7 sanctions. 

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 0,5 carat or larger.

b) For synthetic 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, OR 

- Diamond Office Template - G7GF Declaration (it is recommended to use this document of all documents listed here! You can find the 'Diamond Office Template - G7GF Declaration' at the bottom of this page. ) 

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

Optional documentary evidence is: 

- Customs declaration form

- Packing list

- Evidence from traceability systems

As of Sept. 1, also synthetic diamonds equal to or larger than 0,5 carat are in the scope of the G7 sanctions. 

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 0,5 carat or larger.

b) For synthetic 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, OR

- Diamond Office Template - G7GF Declaration (it is recommended to use this document of all documents listed here! You can find the 'Diamond Office Template - G7GF Declaration' at the bottom of this page. ) 

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

Optional documentary evidence is: 

- Customs declaration form

- Packing list

- Evidence from traceability systems

- Time-stamped grading report

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

“I hereby declare that the non-industrial, natural or synthetic (labgrown/laboratory grown) 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. 

When we refer to "Grandfathered Goods” (GF-goods), we mean non-industrial, natural, or synthetic (laboratory-grown / lab-grown) diamonds (both rough and polished) of unknown or Russian origin that a company already possessed before January 1, 2024. The existing stock may not be held in Russia but can be held in another G7 or non-G7 jurisdiction. The ‘Grandfathering principle’ applies to either existing stock in the possession of a Belgian-registered diamond company or a foreign company.

As opposed to the general G7 regulations, are there no size restrictions for 'Grandfathering'. This means that diamonds of all sizes are in scope of the "Grandfathering principle".

These goods are exempt from the ban on Russian diamonds and are not affected by G7 sanctions because they were owned before the sanctions came into effect. Sanctioning these goods and prohibiting their trade would impose an unfair and severe financial burden on diamond companies without significantly impacting Russia's revenues.

The G7 has defined two different mechanisms for Grandfathering your existing stock:

• Mechanism A is exclusively for stock-declared stock (31 December 2023) held in Belgium by a Belgian-registered diamond company.
   
• Mechanism B is for:

1. Stock in the possession of a Belgian-registered diamond company that is held outside Belgium OR
2. For stock-declared stock (dates other than 31 December 2023) that is in the possession of a Belgian-registered diamond company held in Belgium OR
3. For stock in the possession of a foreign company that is held outside Belgium.

First, you should define your situation and choose a matching mechanism (A or B) that applies to your situation. For detailed information on both mechanisms and which steps to undertake to grandfather your goods, you can make use of the following documents: 

1. Grandfathering procedure text: a fully written document that explains in detail and step by step for all possible scenarios how your existing stock can be regularized, which documents are needed for import and export, and how you can finally obtain a Grandfathering certificate.

2. Grandfathering Decision tree: a step-by-step guide explaining how to put the Grandfathering principle into practice. As well as a Grandfathering Decision tree Cheat Sheet (extra advice/suggestions).

3. Grandfathering info session Webinar: explains briefly and concisely what Grandfathering is all about and how to put it into practice as a company. To make it more convenient, here's a copy of the presentation.

4. Here you can also find the GF Documentary Evidence-Based Checklist.

In case of import or export via Diamond Office, your goods must be accompanied by a completed and signed version of the 'Diamond Office Template - G7GF Declaration'. You can find the 'Diamond Office Template - G7GF Declaration' at the bottom of this page. 

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.
 

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
 

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 the scope of the general G7 sanctions (diamonds of 0,5 carats and larger).
 

You can buy from Private Owners:

• Jewellery does not need to be grandfathered (Jewellery in general is not in scope of the G7 sanctions)
• Loose diamonds of known origin can be freely traded 
• Loose diamonds of unknown origin need to be grandfathered

How does that work? -> use Mechanism B of the Grandfathering Principle

You can find a step-by-step explanation of how to use Mechanism B in the 'Grandfathering procedure', as well as an overview of all documents that must accompany your goods when importing or exporting them.

Basically, these date-stamped documentation is required: 

• Date-stamped grading certificate
• Proof of inventory of an inheritance
• Date-stamped receipt or purchase record
  Can be from when the private owner purchased the diamonds
• Insurance documentation
• Or similar

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.
 

A GF number is issued by the FPS Economy and will be mentioned on the import declaration (box 44) at the end of the import verification.

Jewelry is currently not in scope of the G7 sanctions and personal jewelry (in the possession of private people) will never be in scope. 

This means that you can freely trade with jewelry from private people without having to prove their non-Russian origin.  

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.

In case of 'National Trading', the Diamond Office must be informed by e-mail of this transaction. You must send the 'Diamond Office Template - G7/GF Declaration' to GODF@AWDC.be. You find this template digitally fillable template at the bottom of this page. 

In case of 'National Trading', the Diamond Office must be informed by e-mail of this transaction. You must send the 'Diamond Office Template - G7/GF Declaration' to GODF@AWDC.be. You find this template digitally fillable template at the bottom of this page. 

Goods being traded within Antwerp/Belgium between 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.

When grandfathering your goods, they must by accompanied by the 'Diamond Office Template - G7/GF Declaration', when they pass through Diamond Office. On this digitally fillable template, the GF declaration is automatically mentioned. 

If you are, for some reason, not using the strongly recommended 'Diamond Office Template - G7/GF Declaration', you can use this statement on the invoice of the 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."

You can use this 'GF decision tree' or go through the detailed 'Grandfathering Procedure Text'. Those documents will guide you through the process of Grandfathering (and thus regularizing your existing stock) step by step. 

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.

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.

They will be independently audited by a 3rd party. As soon as more information is available, we will share this with the industry. 

The process of setting criteria and validation is ongoing. As soon as more information becomes available we will add it here.

The use of validated traceability systems will only be required from March 1, 2025. As soon as more information on this topic is available, we will add it here and inform the industry. 

Last update: 2 September 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 2024, documentary evidence is required to proof the orgin of the diamonds. 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. However as of 1 March 2025, only KP certificates with single origin or De Beers DTC mixed origin, will be accepted.

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 > 0,5 ct) and not in scope (< 0,5 ct), 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 > 0,5 ct): equal to or larger than 0,5 carat -> IN SCOPE

(< 0,5ct): smaller than 0,5 carat -> OUT OF SCOPE

No additional cost are imposed. Your usual Diamond Office fees are applied. 

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.

If the bank suspects this payment will benefit a sanctioned entity, yes, OFAC sanctions US and Financial sanctions apply.
 

Currently for both rough and polished, physical and documentary evidence checks are performed. As of March 1 2025, the use of digital traceability will be mandatory.

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.

Sanctions only apply to import to G7/EU markets via Diamond Office, for export normal rules of DO continue to apply. 

To ensure the information is accurate, check the import regulations of the countries you are exporting your goods to for the latest & most up-to-date information.

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. 

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).

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.