Compliance Checklist

GPSR (General Product Safety Regulation)
Jewelry & Watches
France 🇫🇷

Complete GPSR compliance checklist for jewelry and watches on Amazon.fr: product safety under Regulation (EU) 2023/988, French hallmarking (poinçons de garantie), nickel safety and DGCCRF requirements.

Overview

The General Product Safety Regulation (GPSR, Regulation (EU) 2023/988) has applied EU-wide, and therefore in France, since December 13, 2024, covering jewelry and watches. In addition to the general GPSR obligations (risk assessment, traceability, EU responsible person), France operates a centuries-old, standalone fineness and hallmarking system (poinçons de garantie) for precious metal articles made of gold, silver and platinum. This system is enforced not by DGCCRF but by French customs (Direction Generale des Douanes et Droits Indirects, DGDDI) via the Bureau de la Garantie, and is codified in the Code general des impots. Precious metal jewelry placed on the French market for the first time above certain weight thresholds must carry a state or DGDDI-approved fineness mark plus a registered maker's/responsibility mark (poinçon de maitre or poinçon de responsabilite). DGCCRF separately monitors general product safety (GPSR) and the correct advertising of fineness claims.

Does this apply to my product?

This checklist applies to all economic operators (manufacturers, importers, distributors, fulfillment service providers) selling jewelry (rings, necklaces, bracelets, earrings, piercings, brooches) and watches to consumers in France via Amazon.fr. The hallmarking obligation specifically covers new gold jewelry from 3 grams and silver jewelry from 30 grams; lighter items are exempt from mandatory hallmarking but must still be advertised accurately. Precious metal goods imported from non-EU countries must be assayed and stamped by DGDDI or an approved control body upon entry, unless they already carry a recognized international convention mark (Vienna Convention / Common Control Mark).

Step-by-Step Guide

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Designate EU responsible person and determine GPSR role

As with any product on the EU market, jewelry and watches also require an EU-based responsible person if the manufacturer is established outside the EU.

Estimated time: 1-2 weeks

Own role as economic operator under GPSR identifiedRequired

Determine your role: manufacturer, importer or distributor. Private label sellers who have jewelry manufactured under their own brand qualify as manufacturers with the most extensive obligations – including registering their own responsibility mark with DGDDI (see step 2).

EU responsible person designated (Art. 16 GPSR)Required

Designate an EU-based responsible person with name, postal address and electronic contact address if your company is based outside the EU. This person serves as the point of contact for DGCCRF and must have access to the technical documentation.

Mandate agreement with the EU responsible person

Hallmarking under French law (poinçons de garantie)

New precious metal goods made of gold, silver and platinum above the weight thresholds must carry a state fineness stamp and a registered responsibility mark – a purely French requirement that goes beyond GPSR.

Estimated time: 2-4 weeks

Responsibility mark (poinçon de maitre / poinçon de responsabilite) registered with DGDDIRequired

Manufacturers and importers of precious metal goods must register an individual, lozenge-shaped responsibility mark bearing their initials and an identifying symbol with French customs (DGDDI) before placing jewelry on the French market. This mark uniquely identifies the responsible party to customs and consumer protection authorities.

DGDDI registration confirmation of the responsibility mark

Fineness mark (poinçon de titre) applied for gold, silver and platinum jewelryRequired

Gold jewelry from 3 grams and silver jewelry from 30 grams must carry the legal fineness mark: an eagle's head ('tête d'aigle') for French gold, a Minerva head ('tête de Minerve') for French silver, each with digits distinguishing fineness (e.g. 750, 585, 375 for gold; 950, 925, 800 for silver). Imported goods assayed at entry instead receive a scallop-shell import mark ('poinçon d'importation').

Assay certificate of fineness from the Bureau de la Garantie or an approved control body

Weight thresholds for hallmarking exemption verifiedRequired

Gold jewelry under 3 grams and silver jewelry under 30 grams are exempt from mandatory hallmarking. This exemption does not remove the obligation to use accurate, verifiable fineness claims – false claims remain punishable even for exempt products.

Verify chemical safety (nickel, lead, cadmium)

As throughout the EU, the REACH restrictions for skin-contact products apply to the French market and are checked by DGCCRF as part of GPSR market surveillance.

Estimated time: 1-3 weeks

Nickel release tested per REACH Annex XVII Entry 27Required

Jewelry with prolonged skin contact, as well as piercings and earring posts, must not exceed the nickel release limit of 0.5 µg/cm²/week per EN 1811. Coated products must also be tested (wear simulation per EN 12472), as coatings wear off over time.

Nickel release test report per EN 1811 from an accredited laboratory

Lead and cadmium content tested per REACHRequired

Jewelry must not exceed the REACH limits for lead and cadmium (respective Annex XVII entries). Particularly relevant for fashion jewelry made from alloys and for colored plastic or enamel parts.

Lead/cadmium content test report from an accredited laboratory

Risk assessment, traceability and technical documentation (GPSR)

The general GPSR obligations regarding risk assessment, traceability and technical documentation apply unchanged in addition to the French hallmarking requirements.

Estimated time: 1-2 weeks

Internal risk analysis per Art. 9 GPSR documentedRequired

Assess chemical risks (nickel, lead, cadmium), mechanical risks (swallowable small parts in children's jewelry, sharp edges) and, for battery-powered watches, electrical risks. For children's jewelry, the Toy Safety Directive 2009/48/EC may additionally apply.

Internal risk analysis / risk assessment document

Traceability via batch/serial number ensuredRequired

Each product or its packaging must carry unique identification. For very small jewelry items, this can be shown on a tag or packaging if direct marking is not practical. DGCCRF can require disclosure of the entire supply chain within 10 days.

Technical documentation compiled (10-year retention)Required

Technical documentation must include product description, risk analysis, applied standards, test reports (nickel, lead/cadmium), and the assay and hallmarking evidence, and must be retained for 10 years after placing on the market.

Technical dossier including assay and hallmarking evidence

French-language labeling and battery obligations

Consumer information must be in French (Loi Toubon). Battery-powered watches are additionally subject to French EPR obligations for batteries.

Estimated time: 1 week

Contact details and warnings provided in FrenchRequired

Name, postal address and electronic contact of the manufacturer or EU responsible person, as well as all warnings (e.g. choking hazard from small parts), must appear in French on the product, packaging or leaflet in accordance with the Loi Toubon.

Battery EPR registration for battery-powered watchesRequired

Anyone placing battery-powered watches on the French market for the first time must register as a battery producer and join an approved eco-organization (e.g. Corepile or Screlec). The crossed-out wheeled bin symbol must be affixed to the battery or product.

Registration evidence with an approved eco-organization for batteries

Amazon.fr listing compliance

Amazon.fr requires all mandatory GPSR data to be registered in Seller Central and can suspend listings without complete information.

Estimated time: 1-2 days

GPSR mandatory fields completed in Amazon Seller CentralRequired

Enter manufacturer data, EU responsible person, contact details and warnings for each ASIN in Seller Central. Product images should show the fineness mark and responsibility mark where recognizable and relevant to consumers.

Common Mistakes to Avoid

Responsibility mark not registered with DGDDI

Consequence: Without a registered responsibility mark, precious metal goods subject to hallmarking may not be placed on the French market. Customs (DGDDI) can seize goods and impose a fine for violating the hallmarking obligation.

Prevention: Register your responsibility mark with the competent Bureau de la Garantie before selling jewelry subject to hallmarking in France.

Fineness claims advertised without hallmarking or test evidence

Consequence: False or unsubstantiated fineness claims (e.g. '925 silver' without evidence) violate the Code general des impots and can be prosecuted as consumer fraud – even for products exempt by weight.

Prevention: Only use fineness claims when substantiated by hallmarking or a material test certificate.

Missing or outdated nickel testing for skin-contact jewelry

Consequence: Violation of REACH Annex XVII Entry 27. DGCCRF can order a recall under GPSR market surveillance and trigger a RAPEX/Safety Gate notification.

Prevention: Have all skin-contact jewelry, including coated products, regularly tested per EN 1811 and EN 12472.

Imported jewelry brought in without French assay or a recognized convention mark

Consequence: Goods without valid fineness evidence can be held by customs. If neither French hallmarking nor a recognized Vienna Convention mark (CCM) is present, the goods are not fit for the market.

Prevention: Clarify before import whether a CCM mark is already present, or have the goods assayed and stamped by DGDDI or an approved control body upon entry.

Frequently Asked Questions

Q1Does all jewelry need to be hallmarked in France?

No. Only new precious metal goods made of gold from 3 grams and silver from 30 grams are subject to mandatory hallmarking. Lighter items and pure fashion jewelry without precious metal content are exempt, but must still be advertised accurately – false fineness claims remain punishable in any case.

Q2What is the difference between the responsibility mark and the fineness mark?

The responsibility mark (poinçon de maitre / poinçon de responsabilite) uniquely identifies the manufacturer or importer and is registered once with DGDDI. The fineness mark (poinçon de titre, e.g. eagle head for gold or Minerva head for silver) confirms the actual precious metal content per item. Both marks are required together, not as alternatives.

Q3Can I simply sell jewelry with a German or UK fineness certificate into France?

Not without further steps. Certificates issued outside the Vienna Convention (Common Control Mark) are not automatically recognized by French customs. Without a valid CCM mark, goods must be assayed upon entry by DGDDI or an approved control body and stamped with the French import poinçon.

Q4Which authority is responsible for jewelry compliance in France – DGCCRF or customs?

Both, for different aspects. DGCCRF oversees general GPSR product safety (risk assessment, traceability, responsible person) and the accuracy of advertising claims. French customs (DGDDI), via the Bureau de la Garantie, is specifically responsible for hallmarking precious metal goods.

Q5What happens if I don't meet GPSR or hallmarking obligations on Amazon.fr?

Amazon can suspend the listing for missing GPSR mandatory data. DGCCRF can impose fines and recalls for safety violations; DGDDI can seize goods and issue separate fines for missing or incorrect hallmarking under precious metals legislation. Both procedures can run in parallel.

GPSR (General Product Safety Regulation)Jewelry & WatchesFrance 🇫🇷