Silver Hallmarking Laws/Rules in France?

[mwj]

Hello, first post on the forum (!) so hello everyone. Apologies in advance if I've got something wrong forum-wise.

So it's a bit of a long shot but I'm hoping there's a hallmark-savvy person out there who knows what the rules are in Europe! I've had a good ol' couple-hour long Google search for an answer to my question but nothing substantial has come up.
I live in FRANCE and have been selling my handmade (mainly) silver jewelry on Facebook for a little while and now a shop has asked me if I'd like to sell in their store. I have also just learned that there are strict rules about marking your jewelry (hallmark/maker's marks) if it's for sale in FRANCE.

My questions are:
1. What are the rules for hallmarking your jewelry in France - can you simply mark the silver with .925 stamp or is it done by a central agency? If so, how and where is this done!? (I've just started reading about selling in the UK and it sounds insanely complicated!)
2. What if your pieces have no flat area or are too small to mark their quality? Do you engrave it in? Is there a weight limit to what you are required to mark?

Again, bit of a long shot but I'd appreciate if anyone has any info on this! Thanks again!

MWJ

[enigma]

France, as Im sure you are aware by now, is somewhat drowning in bureaucracy and red tape.
My way around this when I lived there for 3 years was to have my items hallmarked in the UK which is far simpler.
The UK hallmark is a legal standard almost everywhere and is a higher guarantee than some others in the EU, including France.
HOWEVER I only sold online where the rules are slightly different, Im not certain whether you may have issues if you are selling through a shop within France so you would really need to look into it there.
Are you registered as an artisan?

[pearlescence]

Ask the interested shop, which should know. If they don't their whole operation is suspect, surely.
You will also have to comply with various EU regs such as nickel etc content and distance selling regulations (for your facebook sales)

[mwj]

Hi Enigma, thanks very much for your reply --
Yes it's bureaucratically bountiful here...!
I am set up as an autoentrepreneur (writer) as that's my main income. I've looked at changing to jeweler but you can make and sell 'joallerie' as a secondary activity and NOT change status as long as it doesn't overtake your other job in terms of income, which it hasn't yet. When I need to switch it, it takes a few minutes online so that's not a big problem.
Can I ask how you went about having your items hallmarked in the UK? I'm completely new to this as I've only been making jewelry for a very short time - as you can see I've only just realized this is a requirement - daft I know...! This info would be very very helpful! Thank you!

[mwj]

Hi Pearlescence, thanks for your answer!
The shop is a new cafe that is displaying local artists - they only opened in December so they're learning the rules/taxes/everything as well. I don't suspect any foul play but ignorance the same as me. Perhaps I can ask them to get more information for me as well.
I'm interested to know where I can find the regulations for the EU as far as 'nickel etc content and distance selling regulations' - would you happen to know where I can find this information? So much to learn!!
Many many thanks,
MWJ

[enigma]

I sent my items to the Birmingham assay office for marking, I still do as Im in Portugal now where the bureaucracy is even worse but the sun shines more lol.
https://theassayoffice.co.uk
You have to contact them and have your own mark set up but they are extremely helpful and can explain everything if you give them a call.
However Im not sure what will happen when Brexit goes through with regard to potentially being charged customs fees on items coming back into France from the UK.
Realistically you may be better getting it done in France but I didn't get far enough through the red tape to know how thats all done Im afraid.

[mwj]

Ah we were just in Alvar about a month ago, beautiful and warm, I don't blame you!! ;)
Thank you that's very helpful! If I can't figure out the French system perhaps this will be a good stop-gap. In any case I'll have a chat with them ASAP to figure out a solution.
On another note, how regulated is all of this? I only say that because I think it's odd I hadn't heard anything about it until now - seems like something there'd be a lot of discussion about if it was a major issue/regular problem? Or perhaps I just haven't been knowledgable because I haven't had to know about it before recently. And to be clear I am not implying one shouldn't comply!! I only mean that I find it strange I never knew about any of this before and never heard of anyone having to send all their inventory away to be marked!
I am American so maybe the laws are different there? And if not, then I'll be the first to say I'm completely ignorant on the whole issue. Really hoping to educate myself so thanks for the links and info!!

[enigma]

In the US you can just stamp your own metal, crazy really as then there is absolutely no guarantee that it is what is claimed.
In the UK silver over 7.87 grammes and gold over 1 gramme has to be stamped according to the law, this is done via I think 4 registered offices in the UK.
The rules are slightly different throughout the EU with some ( Portugal being one, don't know who else) having lower weight allowances and also different metal purities allowed to be labelled as 'sterling silver' or '9ct/18ct/24ct gold'.
I only really got as far as finding out that the UK mark is legal in France because my French is rubbish and bureaucracy makes me want to slit my wrists.
Its all a bit bonkers in the EU anyway as it should be one standard across the board because when its not it interferes with trading agreements as is currently the case.
I recall a German chap on here getting pretty peed off with the assay office bod that used to be on here for telling him he wasn't allowed to sell items into the UK labelled as 18ct gold without them being stamped.
In any case I think its around £50 to set up your UK mark if I recall correctly and that would cover you until you can sort things out in France I would think but definitely worth confirming this with the shop concerned.

[mwj]

Brilliant, thanks so much.
I'll inform the shop of what I've learned and see how they want to proceed, great to know there's some kind of (even temporary) solution anyway.
Many thanks again for your help enigma!
Really appreciated.
-MWJ

[handmadeblanks]

@enigma: You have a typo. Silver threshold is 7.78g.

Items must be below the weight to be exempt. i.e.Items below 1.0g of gold, below 7.78g for silver and below 0.5g for platinum are exempt. This is different to saying items above this weight need hallmarking. If a silver item weighs 7.78g or more it needs hallmarking.

[CJ57]

The cost of registering at Edinburgh is £60 + vat for 10 years, there is then the cost of a punch. I recently had to renew mine at around £35

[mwj]

@handmakeblanks -- so from what you wrote I understand
A silver piece less than 7.78g is exempt, above 7.78g needs hallmarking ?
Was just confused by this statement: "This is different to saying items above this weight need hallmarking." How is it different? Just want to understand nuances! Thanks!

[handmadeblanks]

@handmakeblanks -- so from what you wrote I understand
A silver piece less than 7.78g is exempt, above 7.78g needs hallmarking ?
Was just confused by this statement: "This is different to saying items above this weight need hallmarking." How is it different? Just want to understand nuances! Thanks!

Think in terms of:

1) LESS than
2) EQUAL to
3) GREATER than

If a silver item is GREATER than OR EQUAL to 7.78g it must be hallmarked. This is what is meant by items below 7.78g are exempt...

[enigma]

Oops thanks, I have the same typo on my website so better go and change it!

[mwj]

The cost of registering at Edinburgh is £60 + vat for 10 years, there is then the cost of a punch. I recently had to renew mine at around £35

So am I correct in saying you send all your pieces in to Edinburgh where they stamp them for you and return them?
It may seem like an obvious question, sorry, but until this week I'd never heard of this process, so trying to get my head around it! Thanks!

[CJ57]

You register at the office of your choice, London possibly for you although it doesn't matter. I see you can do it online which is where I found the info for Edinburgh
As already described re weight although if I have a large collection I also get my underweight pieces done as well but that's by choice.
Once you've registered with an office and also got your own punch with the makers mark you've chosen you can either give your makers mark to the assay office and they will stamp that part for you or you can keep it as I do and mark with your own mark before sending everything to be tested and marked with an assay mark. You can also have a laser mark done instead for pieces that are more awkward. Each office seems to have different costs for registering that, I had to pay a one off set up charge in Edinburgh but I believe it's different elsewhere.
Hope this makes sense, it seems complicated but my office is really helpful and they are quite patient!

[Dennis]

Yes, but money changes hands too, so it is more economical with bigger parcels.

Once you decide which assay office to go too, you can look up all about them online, or ask for an information pack.
They are also friendly and helpful on the phone.

You get to choose your unique makers mark, made into a stamp by them. But if your work is delicate it can be laser marked instead. Another advantage of lasers is that the size can be varied according to the piece.

There is nothing like the feeling of seeing your work marked for the first time. Dennis.

Oh and it's quite common for me to repeat what Caroline has already said, because I was still typing. I'll have to pull my socks up to get ahead of her.

[enigma]

If you do decide to register with a UK office do make absolutely sure that they are willing to post back to you in France.

[CJ57]

Yes, but money changes hands too, so it is more economical with bigger parcels.

Once you decide which assay office to go too, you can look up all about them online, or ask for an information pack.
They are also friendly and helpful on the phone.

You get to choose your unique makers mark, made into a stamp by them. But if your work is delicate it can be laser marked instead. Another advantage of lasers is that the size can be varied according to the piece.

There is nothing like the feeling of seeing your work marked for the first time. Dennis.

Oh and it's quite common for me to repeat what Caroline has already said, because I was still typing. I'll have to pull my socks up to get ahead of her.

I do it all the time Dennis, no one has replied when I start typing either!

[pearlescence]

Hi Pearlescence, thanks for your answer!
The shop is a new cafe that is displaying local artists - they only opened in December so they're learning the rules/taxes/everything as well. I don't suspect any foul play but ignorance the same as me. Perhaps I can ask them to get more information for me as well.
I'm interested to know where I can find the regulations for the EU as far as 'nickel etc content and distance selling regulations' - would you happen to know where I can find this information? So much to learn!!
Many many thanks,

MWJ

You could try Google

[pearlescence]

You need to do some of the research yourself rather than asking busy people to reinvent the wheel for you

[mwj]

You need to do some of the research yourself rather than asking busy people to reinvent the wheel for you

Hi Pearlescence,
Yes of course. If you'd read the whole thread you'd see I have already spent many hours Googling this topic - to no avail. All that came up was historical information about hallmarking in France (what marks are from which century).
I'm not a lazy info-seeker - you can also see it's my first post. The reason I spent even MORE time signing up to this forum is because I couldn't source information from anywhere else. Thanks though, I'll keep your advice in mind.
Cheers,
-MWJ

[mwj]

If you do decide to register with a UK office do make absolutely sure that they are willing to post back to you in France.

Thanks, good advice. I sent an inquiry to a UK hallmarking office and no reply yet but I will make sure they're happy to send it away. Thanks again!

[mwj]

You could try Google

Cheers.
Yes found some info on general Distance Selling Regulations, thanks. Good to know, I'll update my info on shop, though I normally don't sell abroad.
Was asking more about 'nickel content' comment as that is very jewelry-specific and after more searching nothing's come up. I'll keep looking thanks.

[pearlescence]

Cheers.

Was asking more about 'nickel content' comment as that is very jewelry-specific and after more searching nothing's come up. I'll keep looking thanks.
A search 'nickel' on this forum shows four pages

[enigma]

For some reason I also struggled to find detailed info on this sort of thing for France and Portugal.
Perhaps because my French and Portuguese isn't great but actually at least as likely because neither country has a great online presence.
The UK is amazing in comparison but one wouldn't have necessarily realised that they could have a UK hallmark when living and selling in France.

Mwj, where are you sourcing your silver from? because if its a reputable UK supplier it will be compliant with UK hallmarking but if elsewhere it may not be.
I buy all mine from Cooksons, they have decent prices and a very very good service to France.

[pearlescence]

While we are still in the EU it is the EU rules that matter. (If we stay in the EU hallmarking will probably go as it is a qualitative measure which is anti competitative (means UK metal smiths have to get stuff hallmarked which puts prices up - unfair... or EU selling to UK have to get hallmarked - also banned under single market rules)
Buying metals from India or China is safe if you stipulate that it must be EU compliant, it is America which slaps in the nickel and, assuming the world stops at the border, never manages to differentiate between okay for EU and not.

[mwj]

You register at the office of your choice, London possibly for you although it doesn't matter. I see you can do it online which is where I found the info for Edinburgh
As already described re weight although if I have a large collection I also get my underweight pieces done as well but that's by choice.
Once you've registered with an office and also got your own punch with the makers mark you've chosen you can either give your makers mark to the assay office and they will stamp that part for you or you can keep it as I do and mark with your own mark before sending everything to be tested and marked with an assay mark. You can also have a laser mark done instead for pieces that are more awkward. Each office seems to have different costs for registering that, I had to pay a one off set up charge in Edinburgh but I believe it's different elsewhere.
Hope this makes sense, it seems complicated but my office is really helpful and they are quite patient!

Thank you -- that's very helpful to hear your experience with the process. MUCH APPRECIATED!!
I've already sent off an inquiry about the process and how I can get set up so just waiting to hear back.
Many thanks!

[mwj]

Yes, but money changes hands too, so it is more economical with bigger parcels.

Once you decide which assay office to go too, you can look up all about them online, or ask for an information pack.
They are also friendly and helpful on the phone.

You get to choose your unique makers mark, made into a stamp by them. But if your work is delicate it can be laser marked instead. Another advantage of lasers is that the size can be varied according to the piece.

There is nothing like the feeling of seeing your work marked for the first time. Dennis.

Oh and it's quite common for me to repeat what Caroline has already said, because I was still typing. I'll have to pull my socks up to get ahead of her.

Thanks Dennis, very helpful! That was the second part of my original question - I wasn't sure how they'd mark small/non flat items. Very helpful, thank you very much!

[mwj]

For some reason I also struggled to find detailed info on this sort of thing for France and Portugal.
Perhaps because my French and Portuguese isn't great but actually at least as likely because neither country has a great online presence.
The UK is amazing in comparison but one wouldn't have necessarily realised that they could have a UK hallmark when living and selling in France.

Mwj, where are you sourcing your silver from? because if its a reputable UK supplier it will be compliant with UK hallmarking but if elsewhere it may not be.
I buy all mine from Cooksons, they have decent prices and a very very good service to France.

Yes you're spot on there -- French gov't websites are notoriously terrible and awfully archaic (they often send you in circles or are used to simply tell you to send things in paper copy somewhere!). I buy all my supplies from Cookson in the UK as well, so I suppose that'll make their testing straightforward. I've asked the shop to try to find out more from the chambre de métiers et de l'artisanat so if I find anything out conclusive I'll definitely post it here!

[mwj]

A search 'nickel' on this forum shows four pages

Thanks very much I'll have a read.
I'm hoping that since I buy all my materials from Cookson UK there won't be any problems with this (like you said - USA putting nickel in).
Thanks again.

[enigma]

While we are still in the EU it is the EU rules that matter. (If we stay in the EU hallmarking will probably go as it is a qualitative measure which is anti competitative (means UK metal smiths have to get stuff hallmarked which puts prices up - unfair... or EU selling to UK have to get hallmarked - also banned under single market rules)
Buying metals from India or China is safe if you stipulate that it must be EU compliant, it is America which slaps in the nickel and, assuming the world stops at the border, never manages to differentiate between okay for EU and not.

Yep thats the US all over really lol.

The single market is a nonsense anyway when you consider the massive differences in taxation across the EU- just one example is that in the UK you don't have to be VAT registered until your turn over is above £70k a year, in Portugal its £10k! so there is no even playing field anyway.
In Portugal we also have to mark any silver over 1 gramme.....
I do think hallmarking in itself is a good idea though.

[enigma]

Mwj, yes do post if you find out more as Im sure its something that will come up again at some point.
You are correct, gold and silver from Cooksons will have no issues at hallmarking :)

[pearlescence]

The single market and individual member state's tax decisions are entirely separate.
The single market allows you to import silver from cooksons without having to pay any additional tax as it enters Portugal, and without it being assayed to ensure it complies with any rules which Portugal might chose to apply (without the single market Portugal could insist that silver had to be .935 for example and .925 could not be sold.
Plus, if we do leave the single market if you send goods to the UK for hallmarking the mark might not be acceptable in the EU any more, and your goods might be liable for tax and duty as they cross the border each way
Sales from France or Portugal would certainly attract 20% VAT plus duty of whatever is the correct % for the type as they enter the UK unless worth less than £18. And they would have to have a UK hallmark to be sold to comply with the hallmarking act

[enigma]

Yes the customs duties are certainly a possibility.
I doubt that the UK hallmark standard will be unacceptable anywhere in the EU though as it is currently compliant or higher than everywhere else from my understanding.

[pearlescence]

9ct gold is unlikely to be acceptable.
If we do proceed to be a third state to the EU then it is up to the EU what is acceptable.

[enigma]

I very much doubt that, I just looked it up and found this from the World Gold Council:
" In France, the UK, Austria, Portugal and Ireland, 9 carat is the lowest caratage permitted to be called gold. In Denmark and Greece, 8 carat is the legal minimum standard."

[mwj]

I just heard back from Assay Office Birmingham - here were my questions and their answers:
Hello,
I plan to sell my handmade silver jewellery in France but I don't know any of the following:
1. am I legally obliged to have ALL my pieces hallmarked
2. what is the penalty for NOT having pieces "officially" hallmarked
3. if I have them hallmarked in UK can i sell them in France?
4. is there an exclusion for some kind of jewellery where I don't need to have it hallmarked (I am a one-person jeweller who's making things at home)?
5. are there any other laws I might not know about regarding selling jewellery in Europe?
-------
Thank you for your email, I will answer your questions as you have asked them,
1. No, anything under 7.78gs does not need to be hallmarked.
2. The penalty is trading standards get involved and prosecute.
3. Yes you can sell your items anywhere in the world.
4. No not when it is new, unless it is under the 7.78gs.
5. You would need to check with the countries you are looking to sell in for that information.
You need to be aware of how you sell the items and how you are describing the items for sale.
I hope this has been helpful, if you have any further questions please do not hesitate to contact me,

[handmadeblanks]

Now that you know the answer is 7.78g are you going to invest in an accurate scale or a cheap and nasty one? The law specifies the hallmarking threshold to an accuracy of 2 decimal places. Many of the cheaper scales don’t have a resolution of 0.01g which is what you need.

These are the scales I bought:Kern-Precision-Balance-Pfb-600-2M-PFB-600-2M (http://www.labunlimited.co.uk/s/ALL/6-PFB600-2M/Kern-Precision-Balance-Pfb-600-2M-PFB-600-2M)

[CJ57]

These are the scales I've been using for years and they haven't let me down http://www.cooksongold.com/Jewellery-Tools/Dx-350-Pocket-Scale-350g-X-0.1g-prcode-999-88V

[handmadeblanks]

These are the scales I've been using for years and they haven't let me down http://www.cooksongold.com/Jewellery-Tools/Dx-350-Pocket-Scale-350g-X-0.1g-prcode-999-88V

The resolution on those scales is 0.1g so I am wondering how it handles rounding. Does it round up or down? The threshold for hallmarking gold is 1.0g. If an item weighs for example 0.95g, would those scales read 1.0g or 0.9g? If it rounds up, then it would mean you are sending and paying for items to be hallmarked when they don't require it. In the long run it ends up being false economy. This is the way I rationalise my purchase.

I suppose this is just another Dremel Vs Foredom kind of debate...

[CJ57]

I send everything for assay if I have a large batch so I weigh only for my interest as I'm not required to weigh every item for the assay office. I'm not sure Cookson would sell them if they weren't good enough for the job but I feel no need to rationalise my purchase when they meet my requirements. I used to take my pieces to the chemist in the village when I was more uptight about it.

Couldn't take part in the dremel/foredom debate I've never had a dremel. I always buy the best I can afford or can justify the cost

[art925]

I sent my items to the Birmingham assay office for marking, I still do as Im in Portugal now where the bureaucracy is even worse but the sun shines more lol.
https://theassayoffice.co.uk
You have to contact them and have your own mark set up but they are extremely helpful and can explain everything if you give them a call.
However Im not sure what will happen when Brexit goes through with regard to potentially being charged customs fees on items coming back into France from the UK.
Realistically you may be better getting it done in France but I didn't get far enough through the red tape to know how thats all done Im afraid.

Hi Sarah, I have just a quick question regarding your UK hallmark...as Portugal is a signatory of the International Convention, do you also have to have the Convention Mark on your pieces?

I am considering changing and wondered about cross border hallmarks and sales.

Thanks Les

[enigma]

Hi Les

I just have the standard UK hallmark as this is acceptable in most countries to my knowledge.
TBH I only sell online and so far not in Portugal anyway so I haven't really worried about it ( 99.9% of my sales are UK and USA).