Shipping fashion jewelry to the United States

Why jewellery is on the list at all

Sellers of fashion jewellery are often the most surprised by this whole affair, because nothing about a pair of earrings suggests an American safety agency. The reason it appears is lead: costume pieces are made of alloys and platings, and that is the family of materials the rules are aimed at.

La Poste puts jewellery among the categories needing the reinforced declaration, which is what turns an abstract American rule into a concrete French problem: it is the line that decides whether your parcel can be posted at all.

A piece for a child is a different object

The dividing line is the same one that runs through clothing and toys. Jewellery designed or intended primarily for children twelve or younger is a children's product, and that brings the whole apparatus: a CPC, a laboratory CPSC has accepted, and the rules on lead content and lead in coatings.

Two things decide the classification, and neither is the size of the piece: how it is designed, and how it is sold. A bracelet with cartoon charms, listed in a children's category, priced for a child's pocket, is a children's product even if an adult could wear it.

For adult jewellery, the texts are silent

Here the honest answer is an absence. Adult fashion jewellery does not appear on CPSC's list of rules requiring a general certificate, and we have not found a CPSC text that names it. We will not fill that silence with a guess, because a confident claim about a customs document is worse than saying what is not written.

When no rule requiring a certificate applies to a product, CPSC provides a declaration for exactly that situation, and it describes it in those words.

Whether your piece is in that case is your judgement as the certifier, not ours and not a website's. What we can do is lay out what the texts say and do not say, produce the declaration with its intended use code, and keep the reasoning attached to the document.

What this means for a small jewellery shop

Split your catalogue in two before anything else: pieces sold for children, and the rest. The first group needs testing and a CPC and should be planned like a product launch. The second, in the current state of the texts, is a declaration - which takes minutes rather than weeks.

Keep the wording of your listings in mind while you do it, because that wording is part of how the product is classified. A shop that sells the same bracelet to adults and to children with two different descriptions is describing two different regulatory objects.

• Disclaim A or B, and the intended use code
• The whole procedure, in order
• Gifts, samples and second-hand