Gaetano Cavalieri about Mineral Conflicts

WHAT ARE the key points of the recently approved EU Mineral Conflicts legislation?

There are several. First: European importers of gold will need to apply due diligence steps in monitoring the integrity of the supply chain, which are consistent with the OECD Guidance. Second: importers of gold below a certain volume will be exempt from having to implement a due diligence system. However, the legislation does not define a fixed volume, but rather states that the thresholds will be set so that at least 95 percent of the total imported volumes into the EU of gold will subject to the new regulations. Third: the new rules will only become fully applicable on January 1, 2021. Fourth: the law considers smelters and refiners to be the most critical juncture in the chain of distribution. If it is possible to successfully monitor all gold passing through these processors, the integrity of the supply can be reasonably defended.WHAT ARE the key points of the recently approved EU Mineral Conflicts legislation? There are several. First: European importers of gold will need to apply due diligence steps in monitoring the integrity of the supply chain, which are consistent with the OECD Guidance. Second: importers of gold below a certain volume will be exempt from having to implement a due diligence system. However, the legislation does not define a fixed volume, but rather states that the thresholds will be set so that at least 95 percent of the total imported volumes into the EU of gold will subject to the new regulations. Third: the new rules will only become fully applicable on January 1, 2021. Fourth: the law considers smelters and refiners to be the most critical juncture in the chain of distribution. If it is possible to successfully monitor all gold passing through these processors, the integrity of the supply can be reasonably defended.

How is CIBJO working to support and help the jewellery industry in ‘translating’ it?

We have been monitoring the legislative process pretty much since it began about four years ago. Now that the law has passed, we are planning several programmes to bring it to the attention of the industry, and to offer information and tools for adapting to the demands of the new regulations. we are looking into organising an educational programme, complete with lessons, webinars and prepared materials, to provide companies with the tools necessary for complying with the rules.

Are these laws for independent designers too or just for the big industry, more established brands?

In general, the industry is moving in a direction where greater, if not absolute traceability is becoming the norm. The law is aimed predominantly at larger importers of gold, but it does signal a general change in the way the industry is regulated. Importers of gold below a certain volume will be exempt from having to implement a due diligence system. Anyway, some of the largest retailers have declared that they will only buy from suppliers who meet certain chain of custody standards. CIBJO in principle supports greater transparency and traceability in the industry, but at the same time insists that this should be achieved in a non-discriminatory way. We will strongly oppose any system that, deliberately or inadvertently, uses restrictive traceability requirements to push smaller and often family-owned companies out of the jewellery business.

Gaetano Cavalieri, President CIBJO