OFAC Extends Grandfathered Russian-Origin Diamond Import Window to September 1, 2027 Under 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. 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 and Most Other Diamond Hubs
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. The action imposes additional duties of 10% on goods from India, the United Kingdom, Mexico, and other listed economies, and 12.5% on goods from other investigated economies, including Israel, the UAE, Hong Kong, and Thailand, subject to any applicable product exclusions. In-scope diamond, gemstone, and jewelry shipments should be reviewed for the applicable origin-based duty treatment before U.S. entry.
What this means for you
Add the applicable Section 301 duty to every U.S.-bound quote and invoice for goods entered from July 24 onward, subject to any confirmed product exclusion. Recalculate landed cost by origin hub before choosing shipping routes, and review whether existing U.S. supply contracts allocate the added duty to the buyer or seller. Exporters should also confirm tariff treatment with customs brokers 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. In-scope natural polished diamonds of 0.50 ct or more entering the EU now require a Due Diligence Statement on Diamond Origin, supported by documentary evidence showing reasonable efforts to verify that the diamonds are not of Russian origin. A supplier declaration alone is not sufficient. Importers should ensure the DDS and supporting chain-of-custody evidence are prepared before customs clearance.
What this means for you
If you ship polished diamonds to the EU, attach the DDS and relevant chain-of-custody evidence before dispatching each parcel. For goods already in transit without complete documentation, alert the EU importer, customs broker, or Diamond Office contact immediately. Undocumented or late-documented shipments may face delays, spot checks, or blocking before customs clearance, especially at Antwerp and other EU entry points.
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 implementation of the ACE “country of mining” data field for diamond imports, which had previously been expected in April 2025. The current implementation date is listed as TBD. The postponement does not remove the existing self-certification requirement for in-scope diamond imports. Importers must continue filing the applicable ACE/DIS 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 applicable self-certification for every in-scope 0.50 ct-plus diamond entry, but do not populate a country-of-mining field until CBP activates the requirement. Importers should continue collecting mining-origin and chain-of-custody documentation anyway, because the requirement has been postponed, not cancelled, and the data field may be added to ACE when implementation resumes.
