Diamond Aggregation Under EU Rules: A Practical Compliance Guide

Reviewed: 6 September 2026 Next scheduled legal review: December 2026, or earlier if EU rules or official guidance changes.

> This guide provides general information for diamond and jewellery businesses. It is not legal, customs or sanctions advice. Requirements depend on the product, CN classification, individual diamond weight, transaction date, processing route and available evidence. Before importing or transferring goods, check the current EU legislation and obtain transaction-specific advice from the relevant national authority or customs professional.

Quick Answer

Diamond aggregation means combining diamonds from different parcels, origins or documentation histories. Combining diamonds from several lawful and documented sources is not automatically prohibited. The compliance risk arises when mixing prevents a business from showing which origin and import records apply to the resulting parcel or stone. European businesses should therefore separate traceable goods from diamonds of unknown or unresolved origin, retain parcel-level records and assess each import using the current version of Article 3p of Council Regulation (EU) No 833/2014.

Diamond Aggregation at a Glance

What Does Diamond Aggregation Mean?

In this context, aggregation is an operational supply-chain problem rather than a separate diamond grade or laboratory characteristic.

It can occur when a business:

• Combines stones from different suppliers
• Merges several parcels into one stock lot
• Splits one parcel between branches or customers
• Repackages melee diamonds
• Replaces supplier references with internal stock numbers
• Recuts a large diamond into smaller stones
• Removes diamonds from returned or estate jewellery
• Mixes customer-owned stones with company inventory
• Combines goods with different import or grandfathering histories

The term should not be treated as meaning that every mixed-origin parcel is illegal. A parcel containing diamonds from several documented lawful origins may be commercially valid.

The important question is whether the business can still connect the resulting goods to records supporting their origin, processing route and import history.

What the EU Diamond Restrictions Cover

Article 3p of Council Regulation (EU) No 833/2014 introduced restrictions in phases.

The current binding wording appears in the consolidated Council Regulation (EU) No 833/2014. The 24 April 2026 commencement date was established by the later Council Regulation (EU) 2026/506.

For the relevant third-country-processing provisions, the Regulation uses a threshold of 0.5 carat per natural diamond or 0.1 grams per synthetic diamond. The assessment is made per diamond, not by adding together the total weight of every stone in a parcel.

The exact treatment of jewellery and other products incorporating diamonds must be checked separately against Part C of Annex XXXVIIIA and the current commencement wording. Businesses should not assume that every loose-diamond date automatically applies in the same way to finished jewellery.

Important Clarification About the 2026 Date

Some European Commission and AWDC materials prepared or updated in December 2025 discuss an expected 1 January 2026 implementation date for the polished-diamond workflow.

The later binding amendment specifies 24 April 2026 for mandatory traceability evidence, including the due-diligence statement, for products under CN code 7102 39 00.

The later legislation controls the legal commencement date. Older guidance can still provide useful operational context, but it should not be copied as if it were the current legislative text.

The European Commission describes its sanctions FAQs as implementation guidance and notes that only the Court of Justice of the European Union can authoritatively interpret EU law. Businesses should consult the Commission’s current sanctions FAQ collection alongside the binding Regulation.

When Does Aggregation Create a Compliance Problem?

Aggregation becomes risky when the available records no longer support the conclusion being made about the combined goods.

For example, imagine that a business has:

• Parcel A with documented mining-origin information
• Parcel B with documented non-Russian evidence
• Parcel C with no usable origin information

If all three parcels are mixed without recording their identities and quantities, the documentation for Parcels A and B does not automatically establish the origin of every diamond in the new parcel.

The problem is not simply that several parcels were combined. The problem is that documented and undocumented goods can no longer be distinguished.

The European Commission’s diamond due-diligence guidance specifically addresses controls intended to avoid the aggregation of unknown-origin diamonds with traceable goods. Its restrictions on diamonds FAQ should be read with the later 2026 amendment where dates differ.

Known Mixed Origin Is Not the Same as Unknown Origin

These two situations should be treated differently.

Documented mixed origin

A parcel may contain diamonds from several identified mining countries. The relevant records identify those countries and remain connected to the parcel.

Unknown or unresolved origin

The business cannot establish the necessary origin information from the available records, or the documents cannot be reliably matched to the goods.

“Mixed origin” should never be used as a substitute for “we do not know.”

For relevant rough-diamond imports, the Kimberley Process certificate and the EU verification requirements must be followed. Since 1 March 2025, the applicable certificate must clearly state the mining country or countries for the relevant goods rather than relying on an unsupported generic description.

For a detailed explanation, use the separate guide to mixed-origin Kimberley Process certificates.

A Practical Parcel-Control System

A workable control system does not need to use one particular commercial software platform. It does need to preserve the connection between the physical goods and the supporting records.

Each parcel or individually tracked stone should have a persistent internal identifier.

The file connected to that identifier should record, where relevant:

• Supplier
• Supplier parcel or stone reference
• Internal stock reference
• Purchase date
• Invoice number
• Natural or synthetic classification
• Rough or polished status
• CN code used for the transaction
• Number of diamonds
• Total carat weight
• Individual-weight range
• Declared mining country or countries
• Processing country
• Import date and route
• Customs declaration reference
• Kimberley Process certificate information
• G7 or GF reference, where applicable
• Due Diligence Statement information, where applicable
• Supporting supplier declarations
• Grading-report number
• Any split, merge, recut or repackaging event
• The employee who approved the record

Not every field will apply to every diamond. The record should reflect the actual transaction instead of filling gaps with assumptions.

Record Every Split and Merge

When a parcel is divided, the system should show:

Original parcel → New parcel 1 + New parcel 2

When parcels are combined, it should show:

Source parcel A + Source parcel B → Combined parcel C

The new record should preserve:

• Source parcel references
• Quantity or weight contributed by each source
• Date of the combination
• Reason for the change
• New physical location
• Responsible employee
• Documents connected to every source

Deleting the original parcel record after a merge destroys part of the audit trail. Close the original record operationally, but retain it in the history.

Separate Stock by Documentation Status

A practical inventory structure can include the following categories:

“Legacy,” “estate” or “previously owned” does not automatically establish a legal exception. The applicable conditions and evidence must be checked for the transaction.

See the separate guide to grandfathered diamonds and legacy stock.

Documents That Perform Different Functions

Diamond records are not interchangeable.

A standard GIA, IGI or HRD grading report should not be presented as proof of mining origin. Learn more in the diamond grading report guide.

G7 Certificates and GF Numbers Are Not Interchangeable

AWDC explains that a G7 certificate number is issued in connection with the qualifying import and verification of relevant natural rough diamonds through the designated authority. It is not issued directly for polished diamonds, synthetic rough diamonds or exports.

A GF number concerns a specific grandfathering procedure and documentation history.

Businesses should not:

• Call every supplier reference a G7 certificate
• Claim a polished diamond received its own G7 certificate
• Use a GF number from one parcel for unrelated inventory
• Treat either reference as a diamond grade
• Assume that possession of a number removes the need to examine the transaction

See the separate guide to G7 certificates and GF numbers. AWDC’s G7/EU sanctions FAQ provides practical Antwerp guidance, but the current EU Regulation remains the controlling legal source.

Polishing Location Is Not Mining Origin

A diamond may be:

• Mined in one country
• Traded through another
• Polished in India
• Graded by a laboratory elsewhere
• Sourced commercially through Antwerp
• Sold by a European jeweller

None of those later locations automatically changes or proves where the natural diamond was mined.

“Polished in India,” “sourced in Antwerp” and “graded in Belgium” describe different parts of the supply chain. They should not be used as substitutes for mining-origin evidence.

Read the separate guide to diamond mining origin under EU rules.

What to Do Before Combining Parcels

Before any physical combination, the responsible employee should confirm:

1. Are the diamonds natural or synthetic?
2. Are they rough, polished or incorporated into another product?
3. What CN code applies?
4. What is the weight of each diamond?
5. Which transaction and import dates apply?
6. What are the mining-origin and processing records?
7. Are any goods supported through a grandfathering history?
8. Do any documents contain inconsistencies?
9. Can the source of every part of the new parcel remain identifiable?
10. Will the new parcel be imported, exported or returned after processing?

If those questions cannot be answered, the parcel should remain separate until a competent person reviews it.

Workshop, Repair and Customer-Owned Diamonds

Jewellers should apply separate controls to customer property.

A repair intake record should include:

• Customer name or account reference
• Photograph of the item
• Description of the stone or stones
• Visible inscription or report number, where present
• Estimated or recorded weight
• Date received
• Work requested
• Workshop tray or envelope number
• Date returned to the customer

A customer’s diamond should not be placed in general stock or combined with business-owned goods.

If the work requires cross-border movement, replacement stones, removal of diamonds or a change of ownership, obtain transaction-specific customs and sanctions advice.

Import and Reimport Require a Fresh Review

A diamond’s previous presence in the EU does not mean every future movement is automatically permitted.

Before reimporting goods after consignment, grading, recutting, repair or manufacturing outside the EU, verify:

• When and where the goods were previously located
• Whether evidence of prior EU location exists
• Whether the goods changed during processing
• Whether the original and returned goods can be matched
• Whether grandfathering or other provisions are being relied upon
• Which records must accompany the customs declaration

For Antwerp-specific procedures, use the separate Diamond Office import guide.

Supplier Questions to Ask Before Purchase

Ask the supplier:

• What is the documented mining country or countries?
• Where were the diamonds polished?
• Which records support the origin statement?
• Are any diamonds at or above the applicable individual threshold?
• Has this parcel been mixed with goods having unknown or unresolved origin?
• Does a G7 or GF reference apply?
• Was a Due Diligence Statement used for the relevant import?
• Can the records be connected to this exact parcel or stone?
• Is the inventory current, legacy, returned or previously owned?
• Can the documentation be retrieved later if the goods are exported or reimported?

A verbal assurance may begin the discussion, but it should not replace the records required for the particular transaction.

Frequently Asked Questions

Build a Defensible Diamond Record

Good aggregation controls preserve the identity and documentation history of every parcel through purchasing, sorting, manufacturing, sale and cross-border movement.

Dalila Diamonds can provide the commercial and product records held for a specific supplied parcel. Buyers and importers remain responsible for determining which legal, customs and sanctions requirements apply to their transactions.

For a broader operational review, use the EU diamond sanctions compliance checklist.