Revised WDC System of Warranties Becomes the Sole System of Warranties Declaration (Effective 21 September 2026)
The World Diamond Council's revised System of Warranties reached full implementation on 21 September 2026, ending a five-year transition. From that date, the revised declaration became the sole System of Warranties reference, and WDC says all sales of rough diamonds, polished diamonds, and diamond jewelry should include it on invoices and memos. Beyond the Kimberley Process conflict-diamond assurance, the revised declaration also covers human rights, labor rights, anti-money laundering, and anti-corruption.
What this means for you
Register your company on the WDC System of Warranties website, complete the online self-assessment, and repeat it every 12 months. Replace the old warranty wording on your invoices and memos with the revised declaration now: since 21 September 2026, it has been the sole System of Warranties reference.
OFAC Extends the Grandfathered Import Window for Russian-Mined Diamonds Processed in Third Countries to September 1, 2027 (General License 104B)
On August 26, 2026, OFAC issued Russia-related General License 104B, replacing and superseding General License 104A in full. GL 104B authorizes U.S. import-related transactions for certain grandfathered non-industrial diamonds through 12:01 a.m. EDT on September 1, 2027, one year later than the previous September 1, 2026 deadline.
The authorization applies to qualifying diamonds that were physically located outside Russia before the applicable cutoff date and were not exported or re-exported from Russia after that date: March 1, 2024 for non-industrial diamonds weighing 1.0 carat or greater, and September 1, 2024 for non-industrial diamonds weighing 0.5 carats or greater. Diamonds of Russian origin themselves remain prohibited: the license covers only Russian-mined diamonds processed in third countries. Importers should review the full license text and broker guidance before relying on the extension.
What this means for you
If you hold diamond inventory that qualified under the previous grandfathering rule, review whether it remains eligible under GL 104B and whether it can now be imported into the U.S. through September 1, 2027. Keep documentary proof that each stone was outside Russia before the applicable cutoff date and was not exported or re-exported from Russia afterward. Continue filing the applicable ACE self-certification for each in-scope shipment, using the current language confirmed by your customs broker. Revisit any U.S.-bound shipments that were paused or diverted in anticipation of the September 1, 2026 expiry, as the import window has been extended for another year.
U.S. Section 301 Forced-Labor Tariffs Take Effect: 10% on India, 12.5% on Israel, the UAE, Hong Kong and Thailand
USTR's final action in its 60 forced-labor Section 301 investigations took effect for goods entered for U.S. consumption on or after July 24, 2026. It imposes additional duties of 10% on goods from India, the United Kingdom, Mexico and other listed economies, and 12.5% on goods from the other investigated economies, including Israel, the UAE, Hong Kong and Thailand. Product exclusions are listed separately for each economy in the USTR annexes, so the duty on a diamond, gemstone or jewelry shipment depends on its country of origin and on whether that economy's annex excludes the product.
What this means for you
For goods entered from July 24 onward, add the Section 301 duty that applies to the goods' country of origin to your U.S.-bound quotes and invoices, unless the USTR annex for that origin excludes the product. Recalculate landed cost by country of origin, and review whether existing U.S. supply contracts allocate the added duty to the buyer or the seller. Confirm the tariff treatment with your customs broker before dispatching high-value shipments.
EU Due-Diligence Statements Required for Natural Polished Diamonds of 0.50 ct and Above (from 1 January 2026)
The transition period for EU diamond-sanctions documentation has ended. Since 1 January 2026, importers of in-scope natural polished diamonds of 0.50 ct or more must add a Due Diligence Statement on Diamond Origin to the EU customs declaration. It is a best-effort obligation: the importer must be able to show documentary evidence of reasonable efforts to verify that the diamonds are not of Russian origin, and that evidence must be available on request of the national authority.
What this means for you
If you ship polished diamonds to the EU, make sure the signed Due Diligence Statement travels with each shipment, together with the standard commercial and transport documents. Keep the supporting origin evidence (for example G7 or Kimberley Process data, invoices, grading reports and traceability records) ready to produce on request. In Belgium, the FPS Economy carries out spot checks on polished imports. For goods already in transit without a statement, alert the EU importer, customs broker or Diamond Office contact.
EU Ban on Jewelry With Third-Country-Processed Russian Diamonds Stays Postponed Until the Council Sets a Date
The EU's planned ban on jewelry and other finished goods incorporating Russian diamonds that were processed in a third country was originally due to apply from 1 September 2024. The Council postponed it in the 14th sanctions package (Council Regulation (EU) 2024/1745, 24 June 2024), which added paragraph 4 to Article 3p of Regulation 833/2014.
As of the European Commission's diamond FAQ dated 17 December 2025, no date has been set. The FAQ states that the date of entry into force “has not been set yet, as it depends on what the Council decides in view of action taken within the G7 to pursue that measure,” and that “a new Regulation determining the date of the entry into force of such a ban will have to be adopted by the Council.” The threshold in the postponed measure is 0.5 carats (0.1 grams) or more per diamond.
What is already in force is narrower. Since 1 January 2024 it has been prohibited to purchase, import or transfer jewelry incorporating Russian diamonds where the item originates in Russia or was exported from Russia, and the same applies to jewelry incorporating diamonds of any origin that transited through Russia.
What this means for you
No filing change is required today for jewelry processed in third countries: that ban is not in force. The exposure here is planning exposure. If the Council activates the measure, finished goods already in your inventory or in production could fall within scope.
Practical steps:
1. Identify which finished-jewelry lines contain stones of 0.5 ct or more whose mining origin you cannot currently document.
2. Ask suppliers for origin evidence at stone level rather than parcel level for those lines.
3. Keep dated manufacturing records now.
Article 3p(13) provides an exemption, but only once the ban is activated, for items manufactured before its entry into force that are imported for trade fairs or repairs, and that exemption is only usable if you can evidence the manufacturing date.
The trigger to watch for is a new Council Regulation setting the date. The Commission's guidance indicates it is expected to follow G7 action rather than precede it.
CBP Postpones the ACE Country-of-Mining Data Field for Diamond Imports; No New Date Set
U.S. Customs and Border Protection has postponed the ACE country-of-mining data requirement for diamond imports, which had been expected in April 2025. CBP's ACE deployment schedule (September 2026) lists the mandatory data collection as TBD, pending publication in the Federal Register. The postponement does not remove the existing self-certification requirement: importers must continue filing the applicable ACE self-certification for covered diamond shipments, including certifications related to Russian-origin restrictions and any applicable grandfathered-goods authorization.
What this means for you
Continue filing the CBP self-certification in ACE for every entry under the covered HTSUS subheadings (non-industrial diamonds, unsorted diamonds and diamond jewelry). The country-of-mining data element is not yet required. Keep collecting mining-origin and chain-of-custody documentation anyway: the requirement has been postponed, not cancelled, and CBP may activate it once the Federal Register notice is published.
