EU Diamond Due Diligence Statement: Importer Guide

Important: This article provides general information and is not legal, customs or sanctions-compliance advice. Regulations and administrative procedures can change. Importers should check the current legislation and instructions from their customs authority, competent national authority or professional adviser before completing a declaration.

Quick answer

The EU Due Diligence Statement on Diamond Origin forms part of the traceability evidence required when importing certain natural polished diamonds into the European Union. Under the current amended EU legislation, mandatory traceability evidence—including a due-diligence statement confirming that the diamonds were not mined, processed or produced in Russia—applies from 24 April 2026 to relevant goods under CN code 7102 39 00.

The importer is responsible for making the declaration on a reasonable, documented basis. A grading report can help identify a diamond, but it does not by itself prove where the diamond was mined.

What is the Due Diligence Statement on Diamond Origin?

The Due Diligence Statement on Diamond Origin is an import document used to support compliance with the EU restrictions on Russian diamonds.

For the relevant natural polished diamonds, it confirms that the goods were not mined, processed or produced in Russia. The importer must also have taken reasonable steps to verify the declared position and should be able to provide supporting records when requested.

The statement is therefore not intended to stand alone. It should be supported by an organised documentation trail connecting the shipment to the available origin, supplier, commercial and transportation information.

The legal framework is found principally in Article 3p of Council Regulation (EU) No 833/2014. The current wording was amended by Council Regulation (EU) 2026/506.

Which date currently applies?

Two dates may appear in industry information:

AWDC instructed importers using the Antwerp route to submit the statement from 1 January 2026. The EU legislation was subsequently amended in April 2026. The amended text now states that the mandatory traceability-evidence requirement for the relevant polished-diamond code applies from 24 April 2026.

Importers should use the current legal text together with the latest operational instructions issued by the authority handling their import. Businesses importing through Antwerp should therefore continue to follow the documents and procedures required by the Diamond Office.

Which diamonds are covered?

The DDS procedure discussed on this page concerns relevant natural, non-industrial polished diamonds falling under CN code 7102 39 00.

The sanctions framework applies to qualifying diamonds with a weight of at least 0.50 carat per diamond. Importers must assess the actual goods, weight, customs classification, origin, processing history and applicable exceptions instead of relying only on a supplier’s general product description.

This page should not be interpreted as saying that every diamond-related product follows the same documentary process. Separate rules can apply to:

• Rough natural diamonds.
• Synthetic or laboratory-grown diamonds.
• Diamond jewellery.
• Industrial diamonds.
• Goods below the applicable weight threshold.
• Grandfathered or legacy goods.
• Goods previously verified under an accepted procedure.
• Temporary imports, returns or other specialised customs movements.

Where classification or scope is uncertain, obtain guidance before the shipment enters the EU.

Who completes the statement?

The formal responsibility sits with the importer bringing the relevant goods into the EU customs territory.

A downstream jewellery retailer that purchases diamonds already in free circulation in the EU does not automatically become the importer responsible for the original customs declaration. However, retailers, manufacturers and wholesalers should still keep appropriate supplier, invoice and product records.

The responsibilities should not be confused:

Using a customs agent does not necessarily transfer the importer’s underlying responsibility to ensure that the declaration and supporting information are correct.

What does the importer declare?

For an in-scope shipment, the statement supports the importer’s declaration that the relevant diamonds were not mined, extracted, processed, produced or manufactured wholly or partly in Russia, including where the diamonds were later processed in another country.

The importer should also be able to demonstrate that reasonable steps were taken to verify the declared origin and to avoid mixing diamonds of unknown origin with goods presented as traceable.

This is why a verbal supplier assurance is weaker than a documented process. The declaration should be based on information that can be retained, connected to the shipment and produced during a check.

AWDC describes the obligation as a best-effort or effort obligation. That does not mean evidence is optional. It means the importer must be able to show a reasonable verification process rather than merely asserting that the origin is non-Russian. See the current AWDC import guidance.

Which records can support the statement?

The appropriate records depend on the transaction and the diamond’s route through the supply chain. A supporting file may include:

• A signed supplier or importer declaration.
• Invoice or consignment documentation.
• Buyer and seller information.
• The applicable CN code and goods description.
• The number of parcels.
• Individual or shipment carat-weight information.
• Shipment value.
• Packing lists.
• Airway bills or other transport documents.
• Places of export and import.
• The transportation route.
• Available country-of-mining-origin information.
• Relevant Kimberley Process documentation from the rough stage.
• A G7 reference where the upstream rough diamond received G7 verification.
• A GF reference for qualifying grandfathered goods.
• Evidence from an appropriate traceability system.
• A laboratory grading report used to connect a specific polished diamond to the transaction.

No single document automatically replaces all other requirements. Importers should be able to connect the information across the supplier, shipment, inventory and customs records.

The European Commission’s diamond-sanctions FAQ provides useful documentary guidance. Because that FAQ was issued before the April 2026 amendment, its dates should be read together with the current legislation.

A practical importer workflow

1. Identify whether the goods are within scope

Confirm:

• Whether the diamonds are natural or synthetic.
• Whether they are rough or polished.
• Their individual weights.
• Their customs classification.
• Whether any relevant exception or grandfathering provision applies.

Do this before shipment whenever possible.

2. Request origin information from the supplier

Ask the supplier for the country of mining origin or the strongest information available to support non-Russian origin.

Depending on the supply chain, this may be supported by upstream Kimberley Process records, G7 information, a supplier declaration or another documented traceability route.

3. Check the records for consistency

Compare the statement and supporting records with:

• The invoice.
• Packing list.
• Weight and parcel count.
• Customs code.
• Shipping documents.
• Grading-report numbers.
• Internal inventory references.

Investigate material discrepancies instead of automatically copying supplier information into the declaration.

4. Keep different documentation histories identifiable

Do not combine documented and unknown-origin stock in a way that makes the individual goods or parcels impossible to distinguish.

Where commercially practical, maintain separate records for:

• Current documented imports.
• Grandfathered goods.
• Legacy stock.
• Buyback or estate diamonds.
• Customer-owned diamonds.
• Goods whose origin information remains incomplete.

For a more detailed explanation, link to the separate guide on diamond aggregation and EU rules.

5. Complete and submit the correct statement

Use the current form and submission procedure required by the customs or competent authority handling the import.

For shipments entering through Antwerp, follow the current Diamond Office instructions rather than copying a form from an old article or email.

6. Retain an auditable file

Store the signed statement with the records supporting it. The file should be searchable by shipment, invoice, parcel or stock reference.

AWDC currently instructs businesses using its procedure to retain the relevant documentation for five years and warns that importers may be required to produce it during spot checks. This is specific operational guidance and should not be presented as a universal record-retention rule for every unrelated business document. See the AWDC G7/EU sanctions FAQ.

DDS, KP, G7, GF and grading reports are not interchangeable

The Kimberley Process governs international trade in rough diamonds. It should not be described as a polished-diamond grading system. The EU implements it through Council Regulation (EC) No 2368/2002.

Does a grading report prove diamond origin?

No. A standard GIA, IGI or HRD grading report primarily records gemological characteristics, such as carat weight, colour, clarity, measurements and other identification information.

A report number can be useful when connecting one polished diamond to an invoice, shipment or internal stock record. However, the presence of a grading report does not automatically prove where the rough diamond was mined.

This distinction also applies to marketing language:

• “GIA graded” identifies a grading service.
• “Polished in India” describes a manufacturing location.
• “Sourced through Antwerp” describes a trading or sourcing route.
• “Mined in Botswana” is a mining-origin claim requiring appropriate support.

For a complete explanation of grading documentation, link to the Diamond Grading Report Guide. For provenance documentation, link to the Diamond Origin Report Guide.

What should downstream retailers do?

Retailers that are not the importer should avoid presenting themselves as the party that filed the original DDS. They can still strengthen their purchasing controls by:

• Buying from identifiable suppliers.
• Retaining invoices and grading reports.
• Recording supplier-provided origin information.
• Connecting documents to stock numbers.
• Keeping buyback and estate diamonds distinguishable from new supply.
• Asking whether relevant imported goods were supported by the required documentation.
• Avoiding origin or traceability claims that exceed the available evidence.

Statements such as “fully traceable,” “guaranteed conflict-free” or “complete mine-to-market provenance” should appear only when the business possesses evidence supporting that exact representation.

Frequently asked questions

Final guidance

The Due Diligence Statement should be treated as the conclusion of a documented verification process—not as an isolated form.

Before importing relevant natural polished diamonds, confirm the scope, obtain the available mining-origin information, check the supplier and shipment records, complete the current declaration and retain the supporting evidence.

Because sanctions legislation can change quickly, verify the current legal text and authority instructions before every material change in procedure.

European trade buyers seeking documented natural-diamond sourcing can contact Dalila Diamonds to discuss available inventory, grading documentation, commercial records and origin information associated with a specific sourcing request.

10. Required Internal Links

Add contextual links using these anchors:

Also link to this page from:

• The planned EU diamond-compliance hub.
• The EU sanctions checklist.
• The Diamond Office import guide.
• The diamond-aggregation guide.
• The mining-origin regulation guide.
• The G7/GF guide.
• Relevant wholesale sourcing pages.

Do not place all links in a generic “related articles” block. Use descriptive links inside the relevant paragraphs.