Mixed-Origin Kimberley Process Certificates for EU Imports

Compliance notice: This guide provides general information and is not legal, customs or sanctions advice. Requirements can change, and their application depends on the goods, shipment history, commodity code and parties involved. Always check the current legislation and instructions from the relevant customs and competent authorities before importing or exporting diamonds.

A mixed-origin rough-diamond parcel contains diamonds mined in two or more countries. Under the Kimberley Process Certification Scheme, international shipments of rough diamonds must move between participating countries with validated Kimberley Process documentation and tamper-resistant packaging.

For applicable first imports into the European Union, a generic declaration such as “Mixed Origin***” is no longer automatically sufficient. Since 1 March 2025, the mining countries for in-scope mixed-origin rough diamonds must be clearly stated and supported by consistent traceability documentation. Previously verified goods may be treated differently, but the importer must retain evidence of that verification.

What is a mixed-origin Kimberley Process certificate?

Under the EU regulation implementing the Kimberley Process, a parcel of mixed origin is a parcel containing rough diamonds from two or more countries of origin.

The country of origin is the country in which the rough diamonds were mined or extracted. It is not necessarily:

• The country that exported the parcel.
• The country in which the diamonds were sorted.
• The country where they were cut or polished.
• The location of the dealer or wholesaler.
• The country through which the shipment entered the EU.

A parcel containing rough diamonds mined in Botswana, Canada and Namibia is therefore a mixed-origin parcel, even if it was sorted and exported from a single trading centre.

The Kimberley Process applies to rough diamonds covered by the relevant headings for unsorted, unworked or simply sawn, cleaved or bruted diamonds. It does not function as a grading-report system for polished diamonds or finished jewellery.

When is a Kimberley Process certificate required?

The Kimberley Process Certification Scheme controls international trade in rough diamonds between participating countries.

For an import into the European Union, the rough-diamond shipment must generally:

• Come from a Kimberley Process participant.
• Be accompanied by a valid certificate issued and validated by the exporting participant’s competent authority.
• Travel in a tamper-resistant container.
• Arrive with its seals intact.
• Be identifiable as the consignment described by the certificate.
• Complete the applicable customs and competent-authority procedures.

The EU operates as one Kimberley Process participant. Its internal borders do not create separate KP participants, but ordinary customs, tax, transport and sanctions requirements continue to apply.

The EU lists Union authorities for Kimberley Process import and export controls in Antwerp, Prague, Idar-Oberstein, Dublin, Torino, Lisbon and Bucharest. This broader KP-authority network should not be confused with the particular Antwerp verification arrangements used for applicable EU Russian-diamond sanctions controls.

What does the certificate prove?

A properly issued KP certificate provides shipment-level information for a rough-diamond consignment and shows that it is being traded through the Kimberley Process system.

It does not, by itself:

• Grade a diamond’s cut, colour, clarity or carat weight.
• Determine the market value of a diamond.
• Prove the mining origin of an individual polished stone after aggregation and manufacturing.
• Provide complete mine-to-retail traceability.
• Verify every environmental, labour or human-rights claim.
• Guarantee that the diamonds satisfy every EU sanctions requirement.
• Establish that a finished ring is “KP certified.”

The Kimberley Process uses a specific definition of conflict diamonds connected to rough diamonds used by rebel movements or their allies to finance conflicts aimed at undermining legitimate governments. Businesses should not turn that narrow certification into unsupported claims about every aspect of ethical or sustainable sourcing.

Origin, provenance and processing location are different

These terms must not be used interchangeably:

Mining origin The country where the diamond was mined or extracted.

Country of provenance The last Kimberley Process participant from which the shipment was exported.

Processing location The country in which a diamond was sorted, cut, polished or incorporated into a product.

Trading location The commercial centre from which a supplier sold or dispatched the diamonds.

For example, a diamond mined in Canada, polished in India and sold through Antwerp remains Canadian in mining origin. Antwerp is the trading or import location, not the mining origin.

What changed for mixed-origin EU imports?

For applicable first EU imports of in-scope natural, non-industrial rough diamonds, the strengthened origin-verification requirements took effect on 1 March 2025.

For a mixed-origin parcel, the documentation must clearly identify all countries in which the diamonds were mined. According to AWDC’s implementation guidance, the previous generic entry “Mixed Origin***” is no longer accepted on its own for an applicable first EU import.

Where available, a percentage breakdown by mining country may be added to the invoice or packing list. The essential requirement is that the declared countries and accompanying records allow the competent authority to assess the shipment’s origin and traceability.

The applicable EU legislation also requires relevant rough goods to be submitted through the designated verification process with a Kimberley Process certificate that clearly states the mining country or countries.

Importers should not rely on an older certificate format simply because it was previously common in the trade.

Can “Mixed Origin***” still appear?

It may still appear in limited situations, particularly where the goods were already verified through the applicable G7 process and the importer can prove that status with the corresponding evidence.

That does not create a general exemption for every mixed-origin parcel. The business must be able to demonstrate the shipment’s previous verification and retain the documents connecting the current goods to that verification.

If a shipment combines:

• Rough diamonds entering the system for the first time; and
• Rough diamonds that were already G7 verified,

the parcels should be separated and processed under their respective procedures. Combining them without maintaining their individual documentary histories can make verification substantially more difficult.

The competent authority and customs administration—not the commercial supplier—make the final decision on the acceptability of the evidence.

Which diamonds fall within the strengthened checks?

The sanctions traceability provisions principally concern specified natural, non-industrial diamond goods at or above the applicable 0.5-carat threshold and the relevant commodity classifications.

However, importers should not make a threshold decision based only on an informal description such as “small stones” or on the total parcel weight. Commodity classification, stone size, parcel composition and the precise legal wording all matter.

Where a mixed parcel contains different sizes, classifications or verification histories, obtain shipment-specific advice from the competent authority or a qualified customs professional.

Separate prohibitions may also apply because of the identity of a producer, supplier or sanctioned party, regardless of whether a simplified size-based assumption appears to apply.

Documentation checklist for a mixed-origin parcel

Before dispatch or import, verify that the business holds the documentation appropriate to the shipment.

This may include:

• The original, valid Kimberley Process certificate.
• A clear list of every mining-origin country for an applicable mixed-origin parcel.
• The invoice or pro-forma invoice.
• Seller and buyer identification.
• A detailed goods description.
• Relevant CN or HS classifications.
• Parcel and package references.
• Number of stones or parcels, where applicable.
• Carat weight.
• Declared value and currency.
• Packing list.
• Consignment note.
• Customs declarations.
• Air waybill or other transport records.
• Export and import locations.
• Transport route.
• G7 verification evidence or certificate number, where applicable.
• GF reference, where applicable.
• Traceability-platform records.
• Laboratory or technical records when relevant and available.
• Evidence connecting previously verified diamonds to the present parcel.
• Internal sanctions-screening and supplier-due-diligence records.

Every document should describe the same commercial movement. Differences in weight, parcel references, origin declarations, seller identity or route should be resolved before submission.

KP certificate, G7 certificate, GF number and due-diligence statement

These records serve different purposes.

Current EU law moved the application date for the relevant due-diligence statement requirement for polished diamonds under CN 7102 39 00 to 24 April 2026. That polished-diamond requirement is separate from the mixed-origin KP-certificate rules discussed on this page.

Read the dedicated guides before applying any of these terms to a shipment:

• G7 Certificate vs GF Number
• EU Diamond Due Diligence Statement

Aggregation and segregation

Aggregation occurs when diamonds from different mines, countries, parcels or verification histories are combined.

Once goods are aggregated, the records must still support the origin information declared for the resulting parcel. A business should not replace documented origin countries with an unsupported generic mixed-origin declaration merely because the stones have been combined.

A defensible control process includes:

1. Recording the identity and status of each incoming parcel.
2. Separating first-time imports from previously verified goods.
3. Preserving certificate and verification references.
4. Recording when and how parcels are combined.
5. Carrying every relevant mining country into the resulting documentation.
6. Reconciling the outgoing weight with the incoming records.
7. Investigating unexplained weight or origin discrepancies.
8. Keeping supporting evidence available for authority checks.

For a fuller treatment, see the Diamond Aggregation EU Rules guide.

A practical verification workflow

Before accepting or shipping an applicable mixed-origin parcel:

1. Confirm the goods Determine whether the shipment contains natural rough diamonds and confirm the correct customs classification.

2. Establish the shipment history Identify whether it is a first EU import, a previously verified parcel, grandfathered stock or a combination of different categories.

3. Identify every mining country Do not treat the exporting, sorting or polishing country as the mining origin.

4. Review the KP certificate Check the issuing authority, validation, dates, parcel details, weight, seals and mining-origin declaration.

5. Reconcile supporting documents Compare the certificate with the invoice, packing list, customs records, transport documents and traceability evidence.

6. Confirm the verification route Determine whether the shipment must be submitted to the Antwerp verification node or handled through another applicable KP procedure.

7. Screen the parties Check the supplier, beneficial owners, intermediaries, carriers and other relevant counterparties against current sanctions requirements.

8. Resolve discrepancies before shipment Do not assume that a material mismatch can be corrected after arrival.

9. Retain the complete audit trail Store the records in a way that connects the physical parcel, certificate, customs entry and subsequent commercial movement.

Use the EU Diamond Sanctions Compliance Checklist alongside shipment-specific professional advice.

Practical examples

Example 1: First EU import with named countries

A parcel contains rough diamonds mined in Botswana, Canada and Namibia. The KP certificate clearly lists all three mining countries, and the invoice, packing list and traceability records are consistent.

The parcel may proceed to the relevant authority checks, but the documentation does not guarantee automatic clearance. Customs and the competent authority retain decision-making responsibility.

Example 2: Generic mixed-origin declaration

A first EU import contains applicable rough diamonds, but its certificate states only “Mixed Origin***.” The supplier cannot provide proof of prior G7 verification or identify the mining countries.

For the applicable strengthened EU import process, the generic declaration alone is not sufficient.

Example 3: Previously verified parcel

A mixed-origin parcel was previously verified through the applicable G7 process. The current importer holds the corresponding certificate and records connecting the present parcel to that verification.

The previous verification may support the shipment’s treatment, but the importer must still satisfy applicable KP, customs, transport and record-retention requirements.

Example 4: Verified and unverified goods combined

A shipment contains one previously verified parcel and one parcel entering the EU system for the first time.

The importer should not treat the entire shipment as previously verified. The goods should remain segregated, with each parcel following its applicable procedure.

Common mistakes to avoid

• Using “Mixed Origin***” without checking whether named mining countries are required.
• Treating the exporting country as the mining origin.
• Calling a grading report an origin certificate.
• Assuming a KP certificate alone proves compliance with EU sanctions.
• Combining verified and unverified goods without separate records.
• Failing to reconcile weights and parcel references.
• Describing a polished diamond or ring as “Kimberley Process certified.”
• Claiming broad ethical or sustainability guarantees from KP documentation.
• Relying on an old industry summary after the underlying EU regulation has changed.
• Using a supplier declaration without supporting commercial and transport records.
• Assuming that a size threshold overrides party-based sanctions.
• Waiting until the shipment reaches customs to investigate documentation gaps.

Why polished-diamond buyers should understand this

A retail buyer normally does not receive the original KP certificate that accompanied an upstream rough-diamond shipment. Rough diamonds may be divided, aggregated, polished and incorporated into jewellery before reaching the consumer.

Retailers and polished-diamond buyers should therefore ask for accurate origin and supply-chain representations without suggesting that an individual finished diamond carries its own KP certificate.

For the distinction between provenance records and grading documents, read the Diamond Origin Report Guide. Businesses importing diamonds should also consult the Diamond Mining Origin EU Regulation guide.

Frequently asked questions

Source verified diamond supply

Dalila Diamonds supports professional buyers with documented natural-diamond sourcing and transparent inventory information. Documentation availability and compliance requirements depend on the goods and transaction.

View the current diamond inventory or contact Dalila Diamonds to discuss a specific sourcing requirement.