Compliance Checklist

GPSR (General Product Safety Regulation)
Jewelry & Watches
Spain 🇪🇸

Complete compliance checklist for the EU General Product Safety Regulation (EU) 2023/988 (GPSR) for jewelry and watches sold on Amazon.es. Covers the Spanish precious metal hallmarking obligation (contrastacion), nickel safety, traceability, and responsible person requirements.

Overview

The EU General Product Safety Regulation (EU) 2023/988 (GPSR) has applied unchanged in Spain since December 13, 2024, as in all EU member states, replacing Directive 2001/95/EC. For jewelry and watches, this means obligations regarding product safety, traceability, risk assessment, and an EU Responsible Person. What sets Spain apart from the rest of the EU market is a distinct, much older hallmarking law: anyone manufacturing, importing, or placing gold, silver, or platinum jewelry on the market in Spain must fulfil the hallmarking obligation (contrastacion) under Ley 17/1985 and its implementing regulation, Real Decreto 197/1988. Unlike Germany, where hallmarking is now only recommended following deregulation, hallmarking in Spain remains a legal requirement. Spain is also NOT a member of the Vienna Convention (Hallmarking Convention) on mutual recognition of precious metal marks – imported jewelry is therefore generally not recognized via the international Common Control Mark system and must be re-hallmarked under Spanish law (exception: a narrow bilateral treaty with Switzerland covering only watch cases and their accessory parts).

Does this apply to my product?

This checklist applies to all economic operators (manufacturers, importers, distributors, fulfillment service providers) selling gold, silver, or platinum jewelry (rings, necklaces, bracelets, earrings, brooches) and watches to consumers in Spain via Amazon.es. Fashion jewelry without precious metal content is not subject to the hallmarking obligation but remains subject to the general GPSR obligations. Particular attention applies to precious metal goods imported from third countries or other EU states, since Spanish authorities generally do not automatically recognize foreign hallmarks in the absence of convention membership.

Step-by-Step Guide

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Register manufacturer/importer mark with the OEPM

Before any hallmarking can take place, the individual maker's mark (punzon de identificacion de origen) must be registered as a trademark with the Oficina Espanola de Patentes y Marcas (OEPM). Only after this registration can the relevant regional registers and assay offices act.

Estimated time: 3-8 Wochen / 3-8 weeks

The individual identification mark (origin punch) of the manufacturer or importer must be registered as a trademark with the OEPM before it may be used on precious metal goods.

OEPM registration decision for the origin punch

Check registration in the regional register (region-specific)Required

Some Autonomous Communities (e.g. Catalonia) require, in addition to the OEPM mark, a separate entry in the 'Registro de fabricantes y/o importadores de objetos fabricados con metales preciosos' before hallmarking is permitted. Requirements and fees differ by region.

Fulfil the hallmarking obligation (contrastacion, Real Decreto 197/1988)

Objects made of gold, silver, and platinum must bear two marks: the registered origin punch of the manufacturer/importer and the guarantee punch of an official or authorized assay laboratory (laboratorio de contraste) confirming the actual fineness.

Estimated time: 2-6 Wochen / 2-6 weeks

Have fineness tested and hallmarked by an authorized assay laboratoryRequired

An official or authorized laboratorio de contraste (e.g. the nationally operating SAVECO, or regional laboratories per Autonomous Community) determines fineness via chemical, physical, or spectroscopic test methods and applies the guarantee punch. Permitted fineness standards (leyes): gold 999, 750, 585, 375; silver 999, 925, 800; platinum 950, 900.

Laboratory assay certificate stating the fineness

Re-hallmark imported precious metal goods under Spanish lawRequired

Since Spain is not a member of the Vienna Convention (Hallmarking Convention / Common Control Mark), foreign hallmarks are generally NOT automatically recognized. Imported precious metal goods must additionally carry the importer's punch and the Spanish guarantee punch. The only known exception is a bilateral treaty with Switzerland covering exclusively watch cases and their accessory parts.

Align fineness claims in the Amazon listing with the applied punchRequired

Claims such as 'oro de primera ley' or 'plata 925' in the listing must exactly match the hallmarked fineness. False claims are sanctionable under Spanish law.

Designate EU Responsible Person and conduct risk assessment (GPSR)

Under Art. 16 GPSR, an EU-based responsible person must be designated for each product if the manufacturer is not established in the EU. Additionally, a written risk analysis under Art. 9 GPSR is required.

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

Determine EU Responsible PersonRequired

Designate an EU-based authorized representative, importer, fulfillment service provider, or specialized agency as the responsible person under Art. 16 GPSR.

Power of attorney / designation agreement for the responsible person

Document internal risk analysisRequired

Create a written risk analysis per Art. 9 GPSR: chemical risks (nickel, lead, cadmium), mechanical risks (small parts, sharp edges), and where applicable electrical risks for battery-powered watches.

Internal risk analysis / risk assessment document

Verify chemical safety under REACH

Jewelry with skin contact must comply with nickel release limits under REACH Annex XVII Entry 27. Lead and cadmium content must also be tested.

Estimated time: 2-4 Wochen / 2-4 weeks

Test nickel release per EN 1811Required

Max. 0.5 µg/cm²/week for products with prolonged skin contact and for piercings/earring posts. An accredited test report is required, including for coated products (EN 12472 wear test recommended).

Nickel release test report per EN 1811 from an accredited laboratory

Traceability and marking in Spanish

Under Art. 18 GPSR, products must be identifiable and traceable. Contact details and consumer information for the Spanish market must be provided in a language consumers understand – Spanish.

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

Apply batch/serial number to product or packagingRequired

Each product or its packaging must bear a unique identification. For very small jewelry items, marking on a tag or the packaging is sufficient.

Provide manufacturer details and contact information in SpanishRequired

State the name, postal address, and electronic contact of the manufacturer, importer, and, where applicable, the EU Responsible Person on the product or packaging – for Amazon.es understandable in Spanish at minimum.

Packaging registration and Amazon.es listing compliance

Anyone placing packaging on the market commercially in Spain must register with the Ecoembes packaging system. Battery-powered watches additionally fall under the Ecopilas battery take-back system. Amazon.es requires the complete GPSR mandatory fields per ASIN.

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

Registration with Ecoembes (packaging)Required

Ecoembes registration confirmation

Registration with Ecopilas for battery-powered watches

For battery-powered watches, additionally register with the Ecopilas take-back system and apply the battery marking (crossed-out wheeled bin).

Complete GPSR mandatory attributes in Amazon Seller CentralRequired

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

Common Mistakes to Avoid

Hallmarking without prior OEPM trademark registration

Consequence: The assay office cannot apply a valid origin punch if the maker's mark is not registered with the OEPM – the hallmark is then not legally valid.

Prevention: Register the mark with the OEPM early (allow several weeks of processing time) before commissioning the first assay.

Assuming a foreign EU hallmark will be automatically recognized in Spain

Consequence: Spain is not a party to the Vienna Convention – without a Spanish hallmark of its own, the goods are considered improperly marked, with a risk of seizure. The Spanish jewelers' association AEJPR regularly conducts unannounced test purchases to check hallmarking.

Prevention: Have every precious metal item imported from abroad additionally hallmarked under Spanish law before selling on Amazon.es, unless one of the rare bilateral exceptions (Switzerland, watch cases only) applies.

No nickel testing for skin-contact jewelry

Consequence: Violation of REACH Annex XVII Entry 27, possible RAPEX/Safety Gate notification, and Amazon listing suspension.

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

Fineness claim in the listing does not match the hallmark

Consequence: Misleading advertising under Spanish consumer protection law, risk of cease-and-desist, and loss of customer trust.

Prevention: Only use fineness claims in the listing taken directly from the assay certificate, never unchecked from supplier claims.

No Ecoembes registration for packaging

Consequence: Violation of Spanish packaging legislation, possible fine, and Amazon may use missing evidence as grounds for a listing review.

Prevention: Register with Ecoembes before the first sale on Amazon.es and report packaging volumes annually.

Frequently Asked Questions

Q1Is hallmarking for jewelry really a legal requirement in Spain?

Yes. Unlike Germany, where hallmarking has only been recommended since the FeinGehG was deregulated, Spanish law (Ley 17/1985, Real Decreto 197/1988) still mandates two marks for gold, silver, and platinum objects: the registered origin punch of the manufacturer/importer and the guarantee punch of an authorized assay laboratory.

Q2Do I need to register my maker's mark before assaying?

Yes. The individual origin punch must first be registered as a trademark with the Oficina Espanola de Patentes y Marcas (OEPM). Some Autonomous Communities such as Catalonia additionally require a separate regional registration, which is only possible after the OEPM registration.

Q3How much does hallmarking jewelry in Spain cost?

There is no nationwide fee schedule. Testing and hallmarking tariffs are set separately by each official or authorized laboratory or Autonomous Community and published in their official gazettes (e.g. an annual resolution in the Balearic Islands). Expect tens to a few hundred euros per product group, depending on volume and metal type.

Q4Is jewelry already hallmarked in France or Italy recognized in Spain?

Generally not automatically. Spain is not a member of the Vienna Convention (Hallmarking Convention), which governs mutual recognition of hallmarks via the Common Control Mark. Imported precious metal goods must therefore additionally bear the Spanish importer's punch and a Spanish guarantee punch. The only known exception is a bilateral treaty with Switzerland covering exclusively watch cases and their accessory parts.

Q5Does the hallmarking obligation also apply to fashion jewelry without precious metal?

No. The hallmarking obligation under Real Decreto 197/1988 applies only to objects made of gold, silver, and platinum. Fashion jewelry made of other materials remains subject to the general GPSR obligations (risk assessment, traceability, EU Responsible Person) and REACH, but is exempt from assaying.

Q6Can SpaceGoats help me with jewelry compliance for Amazon.es?

Yes, SpaceGoats offers support as an Amazon full-service provider for GPSR compliance and coordinating the Spanish assaying and registration processes (OEPM, Ecoembes). Contact SpaceGoats at spacegoats.io for individual consulting.

GPSR (General Product Safety Regulation)Jewelry & WatchesSpain 🇪🇸

Register manufacturer/importer mark with the OEPM

Fulfil the hallmarking obligation (contrastacion, Real Decreto 197/1988)

Designate EU Responsible Person and conduct risk assessment (GPSR)

Verify chemical safety under REACH

Traceability and marking in Spanish

Packaging registration and Amazon.es listing compliance

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GPSR (General Product Safety Regulation)
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