Navigating the New Era: Why EU Diamond Importers Face Stricter Russian Due Diligence in 2026
The global diamond industry is standing on the precipice of its most significant regulatory shift in decades. As the European Union continues to tighten the noose on Russian revenue streams following the geopolitical shifts of recent years, a new mandate is set to redefine how diamonds are traded, tracked, and verified.
Starting January 1, 2026, a new chapter of compliance begins. Importers bringing polished diamonds into the European Union will no longer be able to rely on simple, broad-stroke assurances. Instead, they must navigate a rigorous framework centered around the mandatory “Due Diligence Statement on Diamond Origin.” This document is not merely a piece of paper; it is a legally binding testament to a trader’s commitment to transparency and a definitive break from the era of “don’t ask, don’t tell” sourcing.
The Evolution of Compliance: Moving Beyond Simple Attestations
For years, the diamond trade operated under a relatively straightforward expectation: importers were asked to attest that they were not knowingly purchasing Russian gems. This was largely a reactive stance. However, as of January 2026, the EU is moving toward a proactive, evidence-based model.
According to Ine Tassignon, spokesperson for the Antwerp World Diamond Centre (AWDC), the new requirements represent a “higher standard” than anything previously seen in the European market. In the past, the burden of proof was relatively light. Importers would essentially sign off on the fact that their goods were non-Russian. But the landscape has changed. The new form requires a more active level of participation in the supply chain.
The New Standard of “Reasonable Steps”
The crux of the 2026 regulation lies in the importer’s ability to affirm that “reasonable steps have been taken to verify the declared origin.” This terminology marks a shift in legal responsibility. It is no longer enough to say, “I didn’t buy from Russia.” Importers must now prove that they actively investigated their suppliers to ensure that diamonds were not mined in Russia and, crucially, that they took measures to avoid the “aggregation of diamonds of unknown origin” with traceable goods.
Aggregation—the practice of mixing diamonds from various sources into a single parcel—has long been a challenge for traceability. The new EU rules aim to dismantle this “blind spot” by requiring traders to keep traceable goods separate from those whose origins cannot be verified with absolute certainty.
Understanding the Scope: The 0.5-Carat Threshold
One of the most critical details for traders to understand is the specific scope of these new rules. The EU has focused its regulatory lens on polished diamonds weighing 0.5 carats and above.
This threshold is significant because it covers a vast majority of the “commercial” and “bridal” sectors of the industry. While smaller melee diamonds are currently exempted from these specific due diligence statement requirements, the 0.5-carat rule captures the high-value stones that generate significant revenue.
Why 0.5 Carats?
The decision to set the bar at 0.5 carats (roughly 0.1 grams) aligns with the G7’s broader strategy to target the most lucrative segments of the Russian diamond trade. By focusing on larger stones, the EU can enforce stricter traceability without completely paralyzing the high-volume, low-value melee trade, which is notoriously difficult to track on a stone-by-stone basis.
The Burden of Proof: What Counts as “Traceability Evidence”?
The “Due Diligence Statement” is a self-declaration, but as Tassignon points out, it is much more than a routine administrative task. “Importers have to be able to prove that what they are stating is true,” she explains. This means being prepared for spot checks conducted by the Diamond Office in Antwerp or other EU customs authorities.
To satisfy these requirements, importers must maintain a robust paper trail. The EU’s recently released FAQ outlines several forms of acceptable “traceability evidence”:
1. Traditional Certification: The Kimberley Process and G7 Certificates
The Kimberley Process (KP) certificate remains a cornerstone of the industry, but for the EU, it is often just the starting point. When companies import rough diamonds into Antwerp, they receive G7 certificates. These documents are vital for proving that the rough material was verified upon its first entry into a G7-compliant jurisdiction.
2. Technological Solutions: Tracr and Everledger
The industry is increasingly turning to blockchain-based traceability solutions. Platforms like Tracr (developed by De Beers) or Everledger provide a digital “passport” for diamonds, recording every step of a stone’s journey from the mine to the retail counter. While the use of these platforms is not yet mandatory, the EU and AWDC strongly encourage their adoption as they provide the most ironclad defense during a customs audit.
3. Supplier Attestations and Digital Communication
Perhaps the most practical advice for smaller traders is the requirement to document all inquiries. If you ask a supplier about a diamond’s origin, you must keep the email. “You have to prove that you did your research,” says Tassignon. Keeping a meticulous record of supplier communications, invoices, and signed attestations from the seller is now a mandatory part of business operations.
The “Grandfathering” Rule: Protecting Existing Stock
A common concern among traders is what happens to diamonds that have been in stock for years. The EU has addressed this through a “grandfathering” provision.
Diamonds purchased prior to January 1, 2024, are not subject to the new Russian sanctions rules. These stones are considered “clean” by virtue of their purchase date. However, there is a catch: the trader must be able to provide documentary proof—such as an original invoice or inventory record—that clearly shows the diamond was acquired before the 2024 cutoff. Without this proof, the stone may be treated as new stock and subjected to the full weight of the 2026 due diligence requirements.
The Postponement of Digital Traceability: A Sigh of Relief
Interestingly, while the new rules are tighter, the EU has stepped back from one of its most controversial proposals. Initially, there were plans to make the use of a digital traceability platform mandatory by 2025 or 2026. However, in a move that has brought relief to many in the industry, this requirement has been shelved for the time being.
“Traders are relieved that a digital solution is not required immediately,” Tassignon says. The decision reflects the reality that the industry is currently divided. While larger corporations have the infrastructure to implement blockchain tracking, many small and medium-sized enterprises (SMEs) are still in the early stages of digital transformation.
Bridging the Gap for Smaller Businesses
The AWDC has been vocal about the need for a “robust traceability system” that actually works for everyone, not just the industry giants. By allowing for a transition period where documentary evidence (like emails and paper certificates) is accepted alongside digital records, the EU is attempting to prevent smaller players from being priced out of the market by high compliance costs.
The Role of the Antwerp World Diamond Centre (AWDC)
As the primary hub for the global diamond trade, Antwerp sits at the heart of this regulatory storm. The AWDC has taken a lead role in educating the industry, providing guides and FAQs to help traders navigate the transition.
The Diamond Office in Antwerp will be the front line for enforcement. Importers must be prepared for physical inspections and audits of their due diligence records. The message from the AWDC is clear: transparency is no longer optional; it is the new price of admission to the European market.
Looking Ahead: The Future of Ethical Sourcing
The implementation of the Due Diligence Statement on January 1, 2026, is part of a larger global trend toward ESG (Environmental, Social, and Governance) accountability. Consumers, especially younger generations, are demanding to know the history of the luxury goods they purchase. By removing Russian diamonds from the supply chain and requiring rigorous proof of origin, the EU is positioning itself as a leader in ethical luxury.
While the transition may be challenging, it ultimately strengthens the integrity of the natural diamond market. By weeding out “diamonds of unknown origin,” the industry can provide consumers with the certainty they crave, ensuring that every sparkle is backed by a clean and documented history.
Conclusion: Prepare Now for 2026
For EU diamond importers, the clock is ticking. The year 2025 should be seen as a “preparation year.” Traders should use this time to:
- Review their supplier lists and request formal origin policies.
- Organize their records for “grandfathered” stock.
- Implement a system for archiving all procurement-related communication.
- Explore digital traceability solutions to future-proof their operations.
The diamond industry has always been one of evolution. From the rough mines of the 19th century to the high-tech labs of today, it has constantly adapted to a changing world. The new Russian due diligence requirements are simply the next step in that journey—a move toward a more transparent, responsible, and ethical future for everyone involved in the “world of brilliance.”
