Questions about Hallmarking and Assay Offices

[Hollow Void]

Hello,

I’m new to the world of jewellery making and have a few questions. I’ve been searching through google but sometimes find contradictory information so thought it would be best to ask specific questions myself, any help would be very much appreciated.

I’m UK based and going to be selling my rings entirely online. I’m an ex games industry 3D artist, so I’m making my designs in 3D, then 3D printing is used to make the mold and the 925 silver ring is produced using the lost-wax method. Sometimes they will go directly from the manufacturer to the customer, sometimes they’ll be sent by me after antiquing.

Hallmarking
Let’s assume all my rings are over 7.78g. I’ll be using Etsy, Shapeways & i.materialise. My first question relates to the second two. They’re both manufacturers based outside of the UK (Netherlands & Belgium), and they both allow “shops” to be set-up on their websites were your designs can be bought by people. Now, as they’re both based outside of the UK, and technically they’re the ones producing & selling the 925 silver ring (with me receiving money from shapeways/i.materialise at a later point as my 3D design file was used), am I correct in thinking the rings do *NOT* have to be hallmarked even if someone in the UK purchases one? Is this correct? I’d have nothing to do with the production or dispatching of the ring so it would be out of my control anyway.

Now for Etsy. If I’m selling rings via etsy and someone in the UK purchases one, and even if they’re being produced outside of the UK I’m assuming that they still *DO* need to be hallmarked because I’m the direct seller? Is this correct?
Now if I’m using etsy and the buyer is outside of the UK, I’m not as sure on this one but from my reading it seems like the ring does *NOT* have to be hallmarked in this instance? Correct? Incorrect?... sorry I’m just really trying to get my head around this 700 year old law!


Assay Offices
I’ve got some general questions in regards to the assay offices. Are they all using X-ray & laser hallmarking now? That would be my preference. How small can laser hallmarks be? I know some people get a nice sense of pride seeing their hallmark, but personally I want them as small as possible and out of sight.

My rings will be produced on a “made to order” basis, which means sending them to the office one at a time for the most part, so I can’t take advantage of doing multiple rings to save costs. Looking at the London office, from what I’ve read It seems that with the minimum cost, + the hallmarking, + the cost of postage & packing to get it there and back & VAT, it’s going to be about ~£30 per ring. Is that roughly correct? Are all the offices similar or would any be cheaper for me to use?

I’m so sorry for bombarding you all with multiple questions but it’s been difficult to gather definite answers from googling and trying to find people in a similar position asking the same things. I just want to make sure I’m on the right side of the law. Eventually I’d like to start having everything I sell on etsy hallmarked including rings under 7.78g, but for now it’s only going to be when it legally needs to be. As someone just starting out, £30 for hallmarking almost doubles my production costs and adds an extra 7 – 10 days to the length of time a customer will have to wait to receive their purchase in an era when people want things ASAP. It’s a major overhead for me to deal with in these early days. I totally understand the law is there to protect the consumer; it just seems a little archaic in its implementation in these modern times.

On a lighter note, here’s my first two 295 designs produced as a test. It’s a bit of a niche style I guess, bonus points if you can guess the influence. I’m going to need to invest in a proper camera at some point, my phone doesn’t do them justice at all.



Cheers for taking the time to read through

-Richard

[ps_bond]

Hi Richard -

I don't really need to ask you "ZBrush or 3DCoat", do I?

I've not looked at Shapeways or iMaterialise recently on the jewellery front - I went the route of purchasing a 3d printer and getting my items cast. Some things I make moulds of and send waxes instead. If they're manufacturing & selling the items, then they're responsible for the marking - you're just receiving a royalty on the process. If you sell them, on Etsy for example, then it's your problem - they may have been manufactured overseas, but you're selling them in the UK (cf H Samuel et al). You've also got the potential for returns unless they're custom items (debatable if manufacture-on-demand really counts as custom though - I don't think I could argue it convincingly).

London definitely uses XRF for preference and has done for more than a decade (it wasn't new when I had the tour and I've just renewed my mark); I'm not sure I've ever had a piece assayed the traditional way. Laser is available (not sure if they go much below 1mm height from memory) - and with London, costs the same as hand marking (other offices vary). Cost sounds about what you've described, unfortunately - it's not economically viable to send in single pieces of silver like that (the assay charges exceed the value of the metal by a silly margin). I usually factor 2 weeks for assay - there's always finishing work needs to be done once it gets back.

Given what you've described, I'd be inclined to keep your models at less than or equal to 0.741cm^3 (rounded down) in volume.

(ETA - no idea why the system bunged your post into the moderation queue, sorted now and I'll keep an eye out for it doing it again)

[handmadeblanks]

I think everything you need to know about hallmarking can be found here: http://theassayoffice.co.uk/download...wnload-centre2

You will also find info on LASER marking

This guide is a summary: http://theassayoffice.co.uk/uploads/...tals-in-uk.pdf


This is a simple guide worth reading: http://theassayoffice.co.uk/uploads/...Oct%202016.pdf

[art925]

The hallmarking requirements for silver in NL are 8.0 grams and over, both organisations would hold you responsible I would think, but it would be worth checking with them both before you start selling through them. They are very keen over here, they visit without notification on a regular basis.

[handmadeblanks]

This article spells it out clearly and unambiguously: http://theassayoffice.co.uk/uploads/...e-UK_Aug16.pdf

It says:

(Highlights added by me)

Implications for Importers into the UK and Exporters to the UK

Before your goods can be offered for sale they have to have been tested and hallmarked at a UK Assay Office. Unless they are exempt because:

a) The product weighs less than
1.00 gram for Gold
7.78 grams for Silver
0.5 grams for Platinum
1.00 gram for Palladium

b) The product has already been tested and hallmarked in a country which is a signatory to the International Convention on Hallmarking and it bears the Convention “Common Control Mark”.
The following countries are signatories to the convention: Austria, Cyprus, Czech Republic, Denmark, Finland, Hungary, Ireland, Israel, Latvia, Lithuania, Netherlands, Norway, Poland, Slovak Republic, Sweden, Switzerland and the UK.

These laws have an impact on anyone selling products into or within the UK.


The only ambiguity I have found in the wording of the law is in reference to the weight.

For example, with silver

(a) Some articles say products that weigh "less than 7.78 grams" are exempt from hallmarking.
(b) Other articles say products that weigh "more than 7.78 grams" must be hallmarked.

In mathematical terminology:

(a) Means: product < 7.78 grams. So equal to or greater than 7.78 grams must be hallmarked.
(b) Means: product > 7.78 grams. Which means up to and including 7.78 grams is exempt.

I find that confusing.

[Hollow Void]

These laws have an impact on anyone selling products into or within the UK.

This is the part I'm most confused about. I've seen other discussions that come to the conclusion that as the point of sale is outside the UK, it's ok for it then be posted into the buyer in the UK. It would just need to be hallmarked before being re-sold in the UK.

They could be wrong of course, which is why I thought it best to ask specific questions myself.

[handmadeblanks]

This is the part I'm most confused about. I've seen other discussions that come to the conclusion that as the point of sale is outside the UK, it's ok for it then be posted into the buyer in the UK. It would just need to be hallmarked before being re-sold in the UK.

They could be wrong of course, which is why I thought it best to ask specific questions myself.

That's not the way I would interpret it myself. If the product is advertised as deliverable to the U.K then the exporter must have it hallmarked in the country of origin, or, have it sent to a UK assay office first (i.e they must register with an assay office and send it there). But to be sure, e-mail the assay office and find out. I did when I had a query and they are very helpful and friendly. I have dealt with both the London and Birmingham assay office and they really are helpful.

[CJ57]

We no longer have an advisor from any assay office since Steve from LAO was made redundant which is a shame. It would be best to phone an office and take advice from the horses mouth as very often we still get it wrong!

[Wallace]

This article spells it out clearly and unambiguously: http://theassayoffice.co.uk/uploads/...e-UK_Aug16.pdf

It says:

(Highlights added by me)




These laws have an impact on anyone selling products into or within the UK.


The only ambiguity I have found in the wording of the law is in reference to the weight.

For example, with silver

(a) Some articles say products that weigh "less than 7.78 grams" are exempt from hallmarking.
(b) Other articles say products that weigh "more than 7.78 grams" must be hallmarked.

In mathematical terminology:

(a) Means: product < 7.78 grams. So equal to or greater than 7.78 grams must be hallmarked.
(b) Means: product > 7.78 grams. Which means up to and including 7.78 grams is exempt.

I find that confusing.

Sometimes we can overthink things. We are not looking at it in pure mathematical terminology, but hallmarking terminology. If it is 7.78g (and obviously above) always best to err on the side of caution and send it in.

[handmadeblanks]

Sometimes we can overthink things. We are not looking at it in pure mathematical terminology, but hallmarking terminology. If it is 7.78g (and obviously above) always best to err on the side of caution and send it in.

I think you are right anyway. The wording of the Hallmarking act is quite clear:

(1) [ Subject to paragraph 14AA and ] 2 Subject to the provisions of this paragraph, any article [ ,
except an article made of chainwork, ] 2 containing only one precious metal, being a metal of
minimum fineness and of a weight less than that specified in the following table:
gold 1 gram
silver 7·78 grams
platinum 0·5 gram.
[palladium 1 gram.]3