Compliance Checklist

GPSR (General Product Safety Regulation)
Jewelry & Watches
Italy 🇮🇹

Complete compliance checklist for GPSR (EU) 2023/988 for jewelry and watches on Amazon.it: general product safety, nickel safety, Italian hallmarking law (Legislative Decree 251/1999) and CONAI packaging registration.

Overview

The EU General Product Safety Regulation (EU) 2023/988 (GPSR) has applied unchanged in Italy as in all EU member states since 13 December 2024, replacing Directive 2001/95/EC. For jewelry and watches this means obligations around product safety, traceability, risk assessment and an EU Responsible Person. What sets Italy apart from the rest of the EU market is its own, considerably older hallmarking law: anyone manufacturing, importing or placing precious metal jewelry (gold, silver, platinum, palladium) on the Italian market must register with the competent Camera di Commercio (CCIAA) under Legislative Decree No. 251 of 22 May 1999 and is assigned an individual Marchio di Identificazione (identification mark), which must be struck onto every item together with the legal fineness stamp. Unlike in Germany, this registration is not voluntary but a statutory precondition for sale. Since 15 December 2023, Italy has also joined the International Hallmarking Convention, giving manufacturers simplified market access to the 21 member states via accredited assay offices (including Alessandria-Asti, Arezzo-Siena, Vicenza) using the Common Control Mark (CCM).

Does this apply to my product?

This checklist applies to all economic operators selling jewelry (rings, necklaces, bracelets, earrings, brooches) and watches made of precious or base metals to consumers in Italy via Amazon.it. Special attention applies to precious metal jewelry (registration obligation with the Camera di Commercio, fineness stamp), products with skin contact (nickel relevance under REACH) and battery-powered watches.

Step-by-Step Guide

Progress0/12 (0%)

Designate EU Responsible Person

Under Art. 16 GPSR, an EU-based responsible person must be designated for each product if the manufacturer is not established in the EU. This general GPSR obligation applies identically in Italy as in any other EU member state.

Estimated time: 1-2 Wochen / 1-2 weeks

EU Responsible Person determinedRequired

Designate an EU-based authorized representative, importer, fulfillment service provider or specialized agency as the responsible person under Art. 16 GPSR. This person must have sufficient authority and resources to fulfill product safety obligations.

Power of attorney / designation agreement for the responsible person

Contact details registered on Amazon.itRequired

Register the complete contact details of the EU Responsible Person in Amazon Seller Central under the GPSR compliance fields – name, address and email per ASIN.

Product Safety and Risk Assessment

Internal risk analysis under Art. 9 GPSR for chemical (nickel, lead, cadmium), mechanical and, where applicable, electrical risks (battery-powered watches) – the substantive requirements are identical across the EU under REACH limits.

Estimated time: 1-3 Wochen / 1-3 weeks

Nickel release tested (REACH Annex XVII Entry 27)Required

Jewelry and watches with prolonged skin contact, as well as piercings and earring posts, must comply with the nickel release limit of max. 0.5 µg/cm²/week under EN 1811. A test report from an accredited laboratory is required – the limit is identical regardless of the country of sale.

Nickel release test report per EN 1811

Internal risk analysis documentedRequired

Prepare a written risk analysis under Art. 9 GPSR covering chemical, mechanical and, where applicable, electrical risks, including swallowable small parts in children's jewelry.

Internal risk analysis / risk assessment document

Traceability and Product Marking

Under Art. 18 GPSR, products must be marked to enable identification and traceability – in addition to the Italy-specific hallmarking obligations in Step 4.

Estimated time: 1 Woche / 1 week

Product identification applied (batch/serial number)Required

Each product or its packaging must bear a unique identification. For jewelry this can be on a tag, packaging or an enclosed leaflet.

Manufacturer details in Italian on product/packagingRequired

Name, postal address and electronic contact address of the manufacturer/importer and, where applicable, the EU Responsible Person must be indicated on the product or packaging. For Amazon.it, information must be provided at least in Italian so that it is understood by consumers.

Italian hallmarking law: registration with the Camera di Commercio

Unlike in Germany, hallmarking in Italy is a statutory obligation with a mandatory prior registration step – Legislative Decree No. 251/1999 requires approval before a stamp may even be used.

Estimated time: 4-8 Wochen / 4-8 weeks

Marchio di Identificazione applied for with the competent Camera di CommercioRequired

Anyone manufacturing, importing or placing precious metal jewelry (gold, silver, platinum, palladium) on the Italian market must register with the Camera di Commercio (CCIAA) of the competent province and is assigned an individual numeric Marchio di Identificazione. The CCIAA may conduct an on-site inspection before entry in the Register of Assignees.

CCIAA registration confirmation with assigned Marchio di Identificazione

Have punches manufactured and apply fineness markingRequired

After the Marchio di Identificazione is assigned, the registration holder has punches manufactured in the required sizes; the CCIAA fits these with an official authentication stamp. Alternatively, since a 2012 regulation (DPR 208/2012), laser marking is possible via a USB token issued by the competent Camera di Commercio. Each item bears at minimum the identification mark and the legal fineness stamp (e.g. 750 for gold, 925 for silver).

Proof of authenticated punches or laser USB token

For export intent: check International Hallmarking Convention

Italy joined the International Hallmarking Convention on 15 December 2023. Accredited assay offices (including Alessandria-Asti, Arezzo-Siena, Vicenza) can carry out testing and apply the Common Control Mark (CCM) plus the national mark (Italia Turrita), enabling simplified market access to all 21 convention member states without re-testing in the destination country.

Packaging registration with CONAI

Anyone placing packaging on the Italian market commercially for the first time must register with the CONAI system (Consorzio Nazionale Imballaggi) and pay an environmental contribution (Contributo Ambientale CONAI, CAC) per material fraction.

Estimated time: 1-2 Wochen / 1-2 weeks

CONAI membership applied forRequired

Register with CONAI for all packaging types placed on the Italian market (sales, secondary and shipping packaging) and material fractions (paper/cardboard, plastic, composite material, etc.), including ongoing reporting of packaging volumes and payment of the CAC.

CONAI membership number and volume reports

Amazon.it Listing Compliance and Document Upload

Amazon.it enforces GPSR requirements through listing attributes and document uploads; for precious metal jewelry, Italy-specific evidence (Marchio di Identificazione) is additionally required.

Estimated time: 3-5 Tage / 3-5 days

GPSR mandatory attributes completed in Seller CentralRequired

Enter manufacturer name and address, EU Responsible Person, product identification and safety warnings where applicable for each ASIN in Amazon Seller Central.

Proof of Marchio di Identificazione for precious metal jewelry kept readyRequired

Keep CCIAA registration confirmation and fineness evidence as PDF ready for Amazon compliance requests and Italian market surveillance (Camera di Commercio, and historically Guardia di Finanza during customs checks).

Common Mistakes to Avoid

Applying German or French hallmarking understanding to Italy

Consequence: Unlike the German FeinGehG (fineness stamp largely voluntary), Italy requires prior CCIAA registration as a statutory obligation. Selling without a Marchio di Identificazione violates D.Lgs. 251/1999 and risks seizure of goods.

Prevention: Complete CCIAA registration and Marchio di Identificazione assignment before the first sale of precious metal jewelry in Italy, regardless of whether a German or French equivalent already exists.

Misunderstood GPSR obligations as a complete compliance solution for Italy

Consequence: GPSR covers general product safety but does not replace national hallmarking law. A seller who only fulfills the EU Responsible Person and traceability requirements but lacks CCIAA registration remains non-compliant for precious metal jewelry.

Prevention: Address GPSR and hallmarking obligations separately and fully complete both before listing on Amazon.it.

Missing nickel testing for skin-contact jewelry

Consequence: Violation of REACH Annex XVII Entry 27, product recall, RAPEX/Safety Gate notification. The limit applies identically in Italy as in the rest of the EU.

Prevention: Have all skin-contact jewelry tested per EN 1811 at an accredited laboratory before placing on the market.

Overlooked CONAI registration because already registered with LUCID (DE) or Citeo (FR)

Consequence: Packaging registers are organized separately by country. A LUCID or Citeo registration does not cover Italy. Missing CONAI membership can lead to fines and Amazon listing issues.

Prevention: Check separately for each target market whether a dedicated packaging registration is required (LUCID for DE, Citeo for FR, CONAI for IT, Ecoembes for ES).

Frequently Asked Questions

Q1Do I need to register with the Camera di Commercio even if I only sell fashion jewelry without precious metal?

No. CCIAA registration and the Marchio di Identificazione under D.Lgs. 251/1999 apply only to precious metal goods (gold, silver, platinum, palladium). Fashion jewelry without precious metal content remains subject to the general GPSR obligations (responsible person, traceability, nickel testing), but not to hallmarking law.

Q2Can I simply continue using my German or French fineness mark on the Italian market?

No, not without Italian approval. First-time sales in Italy require your own CCIAA registration with an assigned Marchio di Identificazione. If you already hold a Common Control Mark from another convention state under the International Hallmarking Convention (Italy a member since 15 Dec 2023), this can ease market access, but does not automatically replace the national registration requirement in all cases.

Q3What is the difference between the Marchio di Identificazione and the fineness stamp?

The Marchio di Identificazione is the individual, numeric manufacturer mark registered with the CCIAA that identifies the responsible party. The fineness stamp (e.g. 750, 925) indicates the legal precious metal content. Together, both marks form the complete Italian hallmark and must be applied jointly to every item.

Q4Does CONAI apply in addition to LUCID registration if I already sell to Germany?

Yes. Packaging registers are organized separately per EU country. LUCID only covers Germany. Selling into Italy requires a separate CONAI membership with reporting of Italian packaging volumes.

Q5What happens if I sell precious metal jewelry without a Marchio di Identificazione on Amazon.it?

Selling without a valid identification mark and fineness stamp violates D.Lgs. 251/1999. Sellers may not hold such goods ready for sale; possible consequences include seizure by the competent authorities and fines. Amazon can also independently suspend listings that lack mandatory GPSR information.

GPSR (General Product Safety Regulation)Jewelry & WatchesItaly 🇮🇹