Developing Indian hallmarking

A roadmap for future growth

About the World Gold Council

Contents

The World Gold Council is the market development

organisation for the gold industry. Our purpose is to
stimulate and sustain demand for gold, provide industry
leadership, and be the global authority on the gold market.

Introduction01

We develop gold-backed solutions, services and products,

based on authoritative market insight and we work with a
range of partners to put our ideas into action. As a result,
we create structural shifts in demand for gold across key
market sectors. We provide insights into the international
gold markets, helping people to understand the wealth
preservation qualities of gold and its role in meeting the
social and environmental needs of society.
Based in the UK, with operations in India, the Far East
and the US, the World Gold Council is an association
whose members comprise the worlds leading gold
mining companies.

Methodology
This report is a holistic study of the Indian gold market.
We gratefully acknowledge the support of local jewellers,
large retailers, gold refineries, trade bodies, gold loan
companies, technological experts, hallmarking agencies
and associations of these agencies as well as the Bureau
of Indian Standards (BIS). Insights were gained from
international subject matter experts and the managementconsulting firm Oliver Wyman.

For more information

Please contact:
World Gold Council
B-6/3, 6th Floor, Laxmi Towers
C-25 Bandra Kurla Complex
Bandra (East), Mumbai 400051, India
+91 22 6157 9100
+91 22 6157 9199
info@gold.org

Developing Indian hallmarking | A roadmap for future growth

Executive summary

02

I: The importance of quality

Reduction of leakage
Enhance exports
Driving employment, boosting industry
Enhancing the monetisation of gold
Key findings

03
04
04
05
05
06

II: Hallmarking in India today

Policy and standards
BIS hallmarks for gold jewellery consist of
several components
Depth and breadth of penetration
Process and technology
Economic viability
Key findings

07
08
08
10
11
11
13

III: Hallmarking in other markets: assessing

best practice
International best practice
Key findings

14
16
18

IV: Future steps: delivering success

Longer-term considerations
Key findings

19
22
22

Introduction
The World Gold Council has conducted a study to assess
the current state of hallmarking in India.
Our intention was threefold:

Our report is comprised of four sections:

To evaluate the existing hallmarking system

First, we outline the importance of quality assurance

To stimulate debate around how best to strengthen

hallmarking processes

Second, we assess the current state of hallmarking,

looking at policy, process, penetration, economic drivers
and governance

To demonstrate the benefits of an effective hallmarking

infrastructure.
This report studies the Indian market holistically and we
consulted extensively with both industry experts and other
stakeholders from across the supply chain. Insights were
gained from subject matter experts, including the Bureau
of Indian Standards (BIS) and the management consulting
firm Oliver Wyman. We also compared the Indian
hallmarking system with best practices in other countries.

Developing Indian hallmarking | A roadmap for future growth

Third, we consider lessons from other countries

And fourth, we set out a roadmap for the future.
Our firm belief is that enhancing the hallmarking system
in India would rebuild trust in the purity of Indian gold,
increase consumer confidence, enhance exports and
create employment. It would also be an essential element
in any successful gold monetisation programme and a
critical element to India becoming jeweller to the world.

01

Executive summary
India has a rich tradition of gold consumption and production.
Cherished as both an adornment and an investment, Indian
households own circa 22,000 tonnes of gold and around 600
tonnes of gold is used in jewellery production each year.
Despite this special relationship with gold, controls around
quality and consumer protection have historically been
relatively light. Across the value chain, the Indian gold
industry has been dominated by small, often artisanal
outlets, operating without licence or accreditation.
This has had several adverse consequences.
Jewellery has suffered from under-caratage and there
has been a widespread concern over this issue of
under-caratage by Indian consumers. This lack of trust
has compromised the Indian gold export market and
made gold less acceptable as collateral for other
productive uses.
In recent years, attempts have been made to remedy the
situation, particularly the establishment of hallmarking
standards by the BIS. This has driven considerable
improvements; however, gold jewellery is still affected
by under-caratage of anywhere from 10% to 15%, on
average, with widespread differences in purity.
This means that, when a consumer purchases an item of
jewellery and is told the gold content is worth INR 10,000,
it is, on average worth INR 8,500 to INR 9,000. In other
words, consumers are routinely cheated.
The Indian gold market would reap extensive and
much-needed benefits, if it were supported by a fully
functioning, credible and rigorous hallmarking system.

Overall, we estimate that exports could increase to at least

US$40bn from US$8bn in 2013 and up to 2.5 million jobs
could be created by 2020, if local consumers, overseas
buyers and financial markets could place their trust in the
quality and purity of Indian gold. We further suggest that
the Governments gold monetisation scheme would be
materially more effective and that consumers would, over
time, appreciate the benefits of reliable, hallmarked gold.
We do believe that Indias current hallmarking model
built around independent hallmarking and assay centres
should be retained. However, we advocate six key shortterm actions to improve its efficiency and effectiveness:
1 Strengthen governance around hallmarking processes
2 Drive customer awareness of hallmarking
3 Incentivise and facilitate targeted expansion of
hallmarking centres
4 Use BIS data to develop a ratings system for jewellers
5 Pilot the BIS Unique ID scheme or other technology
solutions to support hallmarking
6 Pursue membership of the International Hallmarking
Convention or develop an Asian alternative.
Longer term, we would suggest:
1 Moving to a mandatory hallmarking regime
2 Placing the onus of hallmarking on manufacturers.

Under-caratage would be reduced, to the benefit of

consumers
Trust in gold as collateral would be enhanced, making
gold more productive within the Indian economy
Indian jewellery would be more highly valued, thereby
boosting exports
A strengthened market would sustain growth in the
gold jewellery sector, thereby creating significant
employment opportunities.

Developing Indian hallmarking | A roadmap for future growth

02

I: The importance of quality

Gold plays a unique role in Indian society: purchased for
special occasions, frequently presented in the form of gifts and
widely used as a means to preserve wealth. Gold consumption
in India continues to rise.
Golds popularity has driven production and India is now
a leading manufacturer of intricate artisan jewellery.
Purchased by rich and poor across India, it confers status
upon those who own it and is thought of as a good luck
charm by those who receive it.
Gold has a dual purpose both as an adornment and as
an investment. The importance of gold as an adornment
means that a significant proportion of this precious metal
is bought as jewellery. The importance of gold as an
investment means it is vital that this precious metal is
appropriately valued.

These failings would arouse concerns in any geography

but in India a global gold hub they are particularly
challenging for four key reasons.
1 They result in gold leakage for the consumer
2 They affect the reputation of Indian gold and so
reduce exports
3 They minimise the opportunity to create employment
through an effective hallmarking system
4 They have an adverse impact on gold monetisation.

Yet hallmarking is inconsistent and quality control is weak.

Chart 1: The rise of gold consumption in India

Tonnes
1,100
1,000
900
800
700
600
500
400
300
200
100
0
2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

Source: Metals Focus; GFMS, Thomson Reuters; World Gold Council

Developing Indian hallmarking | A roadmap for future growth

03

Reduction of leakage

Enhance exports

Gold leakage means, in essence, that consumers are

being misled when they purchase jewellery (or even
coins). They believe they are buying gold of a certain
caratage and value. In fact, that gold may be under-carated
and overvalued.

Artisanal Indian jewellery is widely prized for its intricacy

and craftsmanship. Yet India currently exports around
US$8bn of gold jewellery, equivalent to just 8% of
the global gold market as shown in Chart 2. This has
significant potential to increase if quality control
is addressed.

The situation is most extreme in the North and East of

India, among smaller, less professional jewellery outlets.
This means that the least advantaged consumers are
those facing the most significant leakage estimated at
between 10% and 15%.
Hallmarking could reduce that leakage, benefiting
consumers across the economic spectrum, but particularly
at the lower end.

By contrast, imports to India account for 20% to 25% of

global gold demand.1
This anomaly arises largely because overseas buyers, e.g.
buyers from the Middle East where hallmarking standards
are stringent, have little confidence in the purity or quality
of Indian gold.
Hallmarking would boost the credibility of Indian jewellery
and thereby drive demand from retailers and wholesalers
in Western markets.
We estimate that exports could triple to US$40bn if
international purchasers felt able to place their trust in
Indian gold.

Chart 2: Indian gold jewellery export values

US$bn
14
12
10
8
6
4
2
0
2004-2005

2005-2006

2006-2007

2007-2008

2008-2009

2009-2010

2010-2011

2011-2012

2012-2013

2013-2014

Source: GJEPC, Hallmarking Convention, World Gold Council

1 Figures based on interviews with industry experts.

Developing Indian hallmarking | A roadmap for future growth

04

Driving employment, boosting industry

A credible hallmarking system would drive demand for
Indian gold both locally and internationally. This would
benefit the market at every stage of the value chain,
including refining, manufacturing, retailing and ancillary
industries.
Given that around 3.5 million people are currently
employed across the Indian gold industry, we estimate
that an additional 2.5 million jobs could be created by
2020, based on annual growth of 8% over the next
five years.
The hallmarking industry itself employs around 2,000
people.2 We estimate this could increase to between
8,000 and 10,000 if hallmarking became more
widespread. This would include personnel at hallmarking
and assaying centres, supervisors at the BIS and workers
in related industries such as chemicals, armoured
transportation and couriering and expert auditors.

Enhancing the monetisation of gold

The government is keen to unlock the earning potential
of gold lying dormant in households. Its gold monetisation
scheme is testament to this ambition. Designed to
encourage gold owners to deposit jewellery and coins
with banks, the scheme is intended to reduce Indias
dependence on imported gold and thereby on
foreign reserves.

At present, out of a national gold stock of around

22,000 tonnes (t), just 600t is monetised3 through loans
and circa 10t has been deposited at banks through
the current gold deposit scheme.
Clearly, this needs to change if gold monetisation is to
become effective. Concerns about the quality of gold
held by both consumers and other institutions are clearly
hampering change.
Under RBI regulations, for example, there is a maximum
loan-to-value of 75% on gold jewellery; valuations are
based on a 30-day average price and evaluators are
obliged to discount under-caratage. Such regulations may
deter consumers from monetising their gold.
Similar challenges arise around assaying gold for gold
monetisation schemes and other potential products,
designed to use gold to stimulate cash flows.
A strong hallmarking system could obviate the need for
such strict controls and increase confidence in the integrity
and value of Indian gold jewellery.
This could enhance gold monetisation in three specific ways:
Increase the collateralisation value of gold in productive
financial schemes
Reduce the costs related to rigorous testing of jewellery
Minimise the application of discounts required as a
hedge against potential under-caratage.

2 Figures based on interviews with industry experts.

3 RBI report.

Developing Indian hallmarking | A roadmap for future growth

05

Key findings

6 The Indian gold industry could be significantly larger

1 There is widespread inconsistency in the quality and

purity of gold in India

7 Currently, it employs 3.5 million people. This could soar

to 6 million, if the industry grew by around 8% a year
over the next five years

2 Consumers suffer from gold leakage

3 This is particularly relevant as Indian consumers hold
gold as an investment as well as for adornment

8 Financial buyers cannot rely on the purity of

Indian gold

4 International consumers lack of trust in Indian gold

9 This is particularly relevant as the government moves

towards launching its gold monetisation scheme

5 Currently gold exports amount to around US$8bn. They

could increase to five times the size if global markets
had more faith in the integrity of Indian jewellery

10 A credible hallmarking scheme could reduce leakage,

boost exports, encourage economic growth and drive
the gold monetisation scheme.

Developing Indian hallmarking | A roadmap for future growth

06

II: Hallmarking in India today

The Indian gold market is not only one of the largest in the
world; it is also responsible for creating some of the most
beautiful, intricate and handmade jewellery. But the industry
has long been hampered by concerns around quality control.
To combat these concerns, the BIS introduced hallmarking
standards and policies, modelled around the UK system.
That was over 15 years ago, in 2000, and several
important steps have been taken since then. More than
300 hallmarking centres have been opened, over 13,000
jewellers are accredited and the BIS has established a

supervisory structure for both hallmarkers and retailers.

As a result, under-caratage has reduced from between
20% and 40% to between 10% and 15%.4

Chart 3: Growth of assaying and hallmarking centres in India

Total number of assaying and hallmarking centres
350
300
250
200
150
100
50
0
2008

2009

2010

2011

2012

2013

2010

2011

2012

2013

Source: BIS

Chart 4: Number of articles hallmarked

Lakhs
300
250
200
150
100
50
0
2008

2009

Source: BIS

4 Oliver Wyman industry interviews.

Developing Indian hallmarking | A roadmap for future growth

07

However, many challenges remain. Hallmarking is not

mandatory and consumer awareness is low. Moreover,
hallmarked and non-hallmarked jewellery are both sold in
the same outlet; and less than one-third of total jewellery
is hallmarked. Operationally, many centres suffer from low
profitability, poor equipment and slack processes. And
from a supervisory perspective, the BIS is not adequately
staffed to fulfil its role effectively.
In this report, we analyse hallmarking from five
perspectives:
current policies and standards
depth and breadth of penetration
processes and technology used
economic viability

Policy and standards

The BIS hallmarking policy is clear, comprehensive and
well defined. However, while policies and standards are
detailed and robust, execution is ineffective.
Whilst consumers have concerns over the caratage of
their jewellery, their awareness and interest in hallmarking
is patchy. Certain areas of the country are underserved
by hallmarking centres, yet numerous centres are
under-utilised.
A number of actions have been taken to try and address
these issues:
The BIS has subsidised equipment costs at assaying and
hallmarking centres
It has reduced licence fees for jewellers in small towns

governance.

It offers training programmes for artisans, hallmarking

centres, jewellers and its own officers
It advertises in the press, online and occasionally
on television
It places signboards in accredited jewellers and
co-brands with certain larger chains.

Focushallmarks
box: BIS hallmarking
components
BIS
for gold
jewellery consist of several components

916
The BIS
logo

A three digit number

(out of a set of six
predefined values)
indicating the purity of
the gold in part-perthousand-format viz;
958, 916, 875, 750,
585, 375

Developing Indian hallmarking | A roadmap for future growth

Logo of the
assaying centre

ABC

A code denoting
the year of
hallmarking

Logo/code of
the jeweller

08

But the impact of these actions remains low.

Industry experts believe there should be one hallmarking
centre for every 20 to 30 jewellers, suggesting a national
network of more than 1,000 hallmarking centres. Yet,
even with just 300 centres, many are underutilised and
usage at some is as low as 10%
Among consumers, there is comparatively little interest
in hallmarking. However, a short survey of predominantly
educated and wealthy people indicated that half would
pay more for purity assurance
Within the unorganised jewellery sector, there is
considerable resistance. Small, independent shops
benefit from undocumented sales so they are reluctant
to formalise their processes. They may gain custom
as consumers place more trust in their jewellery. But
they face significant loss of revenue from a reduction in
leakage and potentially higher tax bills, once all sales
are reported.
The BIS lacks adequate resources to tackle these
challenges. As a result, monitoring and enforcement
are weak. Furthermore, as hallmarking remains
voluntary, the BIS is limited in its ability to force
through the change.

Developing Indian hallmarking | A roadmap for future growth

In June 2015, the government has proposed a new

Bureau of Indian Standards Bill, 2015. The new bill
will provide a legislative framework for following new
provisions other than the provisions in the existing Bureau
of Indian Standards Act, 1986 which is proposed to be
repealed. The proposed provisions in the new BIS Bill,
2015 will empower the Central Government and the BIS
to promote a culture of quality of products and services
through mandatory/voluntary compliance with Indian
standards through the process of product certification
and Certificate of Conformity with a broad objective
of consumers welfare. It is also expected to improve
enforcement of Indian standards.
The proposed provisions will also promote harmonious
development of the activities of standardisation, marking
and quality certification of goods and services, to provide
for compulsory hallmarking of precious metal articles,
widening the scope of conformity assessment, to enhance
penalties, to make offences compoundable and to simplify
certain provisions in the Act. This is a step in the right
direction.

09

Depth and breadth of penetration

Hallmarking infrastructure has developed rapidly since the
BIS scheme was launched in 2000. However, a third of
jewellery is still not hallmarked. And there is considerable
variation in the quality of those items which are.
India has approximately 330 BIS recognised assaying
and hallmarking centres, while applications for setting
up 24 new centres are pending with the Central
government as of 31 March 2015
Tamil Nadu tops the list of BIS recognised assaying
and hallmarking centres with 57, followed by Kerala
with 39. In terms of zones, distribution is uneven; the
South has 153, the West has 65, the North has 111 and
the Northeast has only one. Also, out of the 36 states
(including UTs), 12 have no testing centres
Further, more than 60% of hallmarking centres are
in Indias 20 largest cities and even within cities,
they are often clustered in certain areas. This creates
uneconomic competition and means other areas
are underserved

Discrepancies arise across the jewellery sector too.

Some 80% of high value items are hallmarked, but that
falls to just 10% in the low value category
In the moderate segment the largest in the jewellery
market half is hallmarked and the rest is not
Low penetration in the less valuable segments of the
market arises because customers are less aware of
hallmarking, they have a greater propensity to bargain
and they tend to buy from small, independent jewellers,
who do not participate in the BIS scheme. Keen to
pay as little as possible, these consumers may not
appreciate that the quality of their purchases is often
lower than stated.
Even though, on average, 30% of jewellery is now
hallmarked, there are concerns about the quality and
credibility of some hallmarking centres. This means
the percentage of jewellery hallmarked accurately is
expected to be even lower than 30%.

However, there is also a suspicion that some jewellers

encourage friends and family to open centres near them
to facilitate the hallmarking process. While the BIS
does not sanction such behaviour, it is hard to monitor
and police

Chart 5: Penetration of hallmarking by different segments of jewellery

%
100
10%

80
50%

80%

60
90%
40

50%
20
20%
0
Low value
Not hallmarked

Moderate value

High value

Hallmarked

Note: Low value: >INR 15,000, Moderate value: INR 15,000 to INR 50,000, High value: <INR 50,000 per article at current gold prices.
Source: World Gold Council interviews with market participants

Developing Indian hallmarking | A roadmap for future growth

10

Process and technology

Economic viability

The hallmarking process in India is designed to be

methodical and thorough. Performed at the behest of the
jeweller, items are expected to undergo several technical
and visual checks at certified BIS assaying and hallmarking
centres. These include comprehensive sampling and
testing, according to clearly defined procedures.

A typical hallmarking centre employs between seven and

ten people and costs 60 to 80 lakhs (6 to 8 million rupees)
to set up.

However, the rigour with which these tests are carried out
and the extent to which these processes are applied varies
considerably from centre to centre.

Annual operating costs amount to a further 60 lakhs

(6 million rupees), including wages and rent, as well as
10% royalties payable to the BIS and an annual licence fee
ranging from 13,000 to 20,000 rupees.

Government subsidies are available at this stage, but they

vary from nothing to 30%.

The BIS hallmarking process

BIS certified
jeweller

Return to jeweller

Jewelley

BIS recognised
A&H centre

Unsatisfactory

100% check of
homegeneity

Satisfactory
Reject or
downgrade

Draw minimum
10% sample from lot

Fail

Retest three times

to confirm

Fail

Fire Assay Test

Pass

Hallmarking

Developing Indian hallmarking | A roadmap for future growth

11

On the income side, pricing is flat and the BIS suggest

a fee of 25 rupees per hallmarked article. A typical
centre can hallmark around 1,500 items per day,
suggesting annual revenues of 90 lakhs to 1.2 crore
(9 to 12 million rupees).

Some hallmarking centres cut their prices to as little as

10 rupees per article in a bid to undercut competitors
and drive volume

However, there are wide variations, according to usage.

Some centres resort to pre-arranged deals with

jewellers, agreeing to be less robust in their processes
so as to secure more business. Such centres see
throughput of around 5,000 articles a day, even though
they are set up to hallmark only a quarter of that number,
if proper procedures are followed.

Some centres use low quality equipment to reduce

expenditure and maintenance costs

Hallmarking centres need to operate at a minimum of

50% capacity just to break even. In other words, they
need to be hallmarking 750 articles a day at the BIS
stipulated price of 25 rupees
They need to operate at a minimum of 70% capacity to
achieve a reasonable four to five year payback on their
initial investment

Hallmarking can be a profitable business, ~70% utilisation

is needed to achieve a reasonable 45 year investment
payback horizon, as shown in Chart 6.

Some profitable centres only achieve the desired returns

because they are ultimately controlled or owned by
jewellers, creating clear conflicts of interest

Price-cutting and malpractice arise at least in

part because there is little differentiation between
hallmarking centres, so operators are hard-pressed to
secure business, particularly in cities.

Loss making centres suffer because they operate in

areas where there is little demand for hallmarking. In
such cases, BIS price controls create further challenges

Chart 6: Setting up a hallmarking centre; payback period 1 vs. capacity utilisation 2

Payback period (in years)
70
63.7
60
Assaying and hallmarking centres need to
operate at a 65 to 70% utilisation level to
realise a 4 to 5 year payback period

50
40
30

33.0

20
10

5.2
8.5

0
50

55

60

65

3.8

70

2.4
75

80

1.8
85

90

1.4
95

100
Utilisation (%)

1 Payback period is defined on an initial setup cost of INR 70 lakhs.

2 100% utilisation level assumes that a typical hallmarking centre can effectively test and hallmark ~1500 articles a day at INR 25 per article.
Source: Oliver Wyman

Developing Indian hallmarking | A roadmap for future growth

12

Governance
The BIS has developed extensive governance policies.
Management roles and responsibilities are clearly defined
and BIS personnel are expected to review assaying and
hallmarking centres at least twice a year.
Centres are obliged to keep accurate records of their
activities and hold these for at least three years. They
are expected to conduct internal audits twice a year,
record audit findings and implement improvements
where necessary.
Each centre is supposed to have a designated quality
manager, equipment is expected to be checked on
a regular basis, staff should be properly trained and
procedures should be in place to rectify issues highlighted
when jewellery is tested.
The BIS aims to monitor centres through regular visits,
check hallmarked samples on the open market and send
them to different centres to verify their purity.
Centres that fall short of quality and accuracy standards
are supposed to be fined by the BIS.
The BIS also aims to visit each certified jeweller about
twice a year to ensure that they are carrying out adequate
quality controls on items sent for hallmarking.
However, these policies are rarely enforced.5
First, the BIS is understood to be chronically
understaffed so it does not have the capacity to carry
out the requisite checks on hallmarking centres
or jewellers

Key findings
Hallmarking infrastructure has developed rapidly since
the BIS scheme was launched in 2000
However, a significant percentage of jewellery is still
not hallmarked. And even hallmarked items vary widely
in purity
The BIS has established clear and comprehensive
policies and standards. But it lacks the resources and the
manpower to enforce them
Hallmarking is voluntary and consumer awareness is
limited so jewellers are neither obliged nor incentivised
to become certified
The BIS has established thorough and robust testing and
sampling processes
However, the rigour with which tests are carried out
and the extent to which processes are applied varies
considerably from centre to centre
Hallmarking centres need to operate at a minimum of
50% capacity just to break even at the BIS stipulated
price of 25 rupees
Many cannot achieve this target so they resort to
price-cutting and malpractice
The BIS has developed extensive and detailed
governance policies
But it would need substantial extra resource to
implement and enforce these policies effectively.

Second, the BIS does not have dedicated laboratories

for gold hallmarking so there is little capacity for testing
jewellery. There are relatively few BIS branches too so
activity varies widely across India
Third, the BIS receives annual licence fees from
hallmarking centres and nominal fees from accredited
jewellers, but these do not cover its costs. The shortfall
in resources means there is little opportunity to increase
staff numbers to adequate levels and training is limited.
Crucially too, surveillance suffers.
The BIS would need substantial extra resource to be
able to implement and enforce its policies effectively,
drive hallmarking across India and increase confidence
in Indian hallmarked items both nationally and
overseas.

5 Multiple sources interviewed for this study.

Developing Indian hallmarking | A roadmap for future growth

13

III: Hallmarking in other markets:

assessing best practice
Hallmarking is principally designed to instil confidence.
So an effective hallmarking system bolsters both domestic
and export markets by giving purchasers faith in the gold
they are buying.
Looking across the world, hallmarking systems fall into
three broad categories. In countries such as Bahrain,
Sri Lanka and Japan, hallmarking processes are owned
and operated by the government.

In countries such as China, Germany and the US,

manufacturers are required to perform hallmarking
at source.
In countries such as the UK, France, the Netherlands,
Hong Kong and Singapore, independent licensed centres
operate as assaying and hallmarking centres. This is the
model that India has adopted.

Table 1: Three models of hallmarking

Ouality control is achieved using one of three prevalent models, each with its benefits and challenges
Description
Benefits

Government owned

Independent assay offices

Manufacturer driven

Hallmarking processes owned and

operated by government agencies

Independent licensed private centres

operate as assay offices

Manufacturer required to perform

hallmarking

Authority possesses control of

hallmarking infrastructure and process
and therefore better ability to maintain
process quality

Processes can be tailored locally within

the construct of overarching standards
set by the hallmarking authority

Reliance on third party freight services

Attribution of fault in case of errors may

Requirement of building enablers for

for transfer of valuables

be challenging (i.e. manufacturer vs.

hallmarking agency)

supervision of manufacturers (i.e.

licensing, supervision policy etc.)

Creates additional supervision burden

High pressure on judicial system for strict

(i.e. hallmarking agancies needs to be

monitored)

enforcement and adequate negative

incentives to create deterrence

Economics need to be viable for

Challenging to implement with small

hallmarking franchises to be attracted

to business; potential for localised
demand/supply mismatches (given
inherent challenge in transportation of
jewelry over long distances)

manufacturers

Ability to cater to diverse/geographically

spread out jewellery sources is a
challenge

Centralised processes may not fully cater

to diversity of needs arising from various
forms/designs of jewellery

Typical
prerequisites

Smaller geographical expanse/

High standards of data and record

An efficient public enterprise with

Strong supervisory infrastructure to

concentrated jewellery markets

adherence to service levels

Absence of bureaucratic procedures

keeping to enhance accountability

supervise hallmarking centres as well
as retailers

Egypt, Bahrain, UAE, Sri Lanka, Japan

Higher at source control;

lower reliance on enforcement

Developing Indian hallmarking | A roadmap for future growth



Easier implementation of hallmarking in

countries with large geographical area

Strong supervisory infrastructure to

supervise hallmarking centres as well

as retailers

Robust consumer protection laws to

provide recourse in cases of fraud

Combination free market measures

Imposition of deterrent negative

UK, Austria, France, Netherlands, Portugal,

Spain, Hong Kong, Singapore

Germany, China, Italy, Malaysia, USA

(provisions for easy consolidation of

hallmarking centres) and govt initiatives
(tax breaks and subsiders for centres in
under-penetrated areas) to match
demand and supply

Example
countries

Elimination of redundancy in the

value chain of gold jewellery as easy
for manufacturers to vouch for their
own production

Easier to manage change in processes


C
 ost considerations less relevant
Challenges

Significantly greater ability to cater to

a larger geographical area (franchise
model)

incentives

Lower control at source;

Higher reliance on enforcement

14

Government-owned model
This model has three principal benefits:

Independent assay offices

This model has two key benefits:

The government controls hallmarking infrastructure so it

is better able to maintain quality standards

It functions well in large countries, with diverse,

widely-dispersed markets

It is easier to implement changes in hallmarking

processes

Processes can be tailored to suit local needs, under

overarching hallmarking standards.

Cost considerations are less relevant.

However, there are significant challenges:

However, there are several challenges:

When errors arise, it can be hard to identify who

is at fault

The system relies on third parties to transfer

valuable goods
It is logistically difficult to operate in large geographies
where jewellers are widely dispersed
Centralised processes may not cater to the needs of
diverse forms of jewellery.
As such, this model is particularly well-suited to smaller
countries or those with concentrated jewellery markets.
An efficient, non-bureaucratic and service-oriented
public sector is also helpful.
Manufacturer-driven model
This model has two specific benefits:

Hallmarking agencies need to be monitored, creating an

additional supervisory burden
The economics need to be viable to attract potential
hallmarking franchisees
There is the potential for mismatches between supply
and demand. Cities may see too much supply and less
accessible areas may be underserved.
Given these constraints, this model is best suited to
countries with high standards of record-keeping and a
strong supervisory infrastructure. A combination of free
market measures and government initiatives can help to
ensure a balance between supply and demand.

Manufacturers can vouch for their own production so

efficiency is maximised across the value chain
It is easier to implement in large countries.
However, there are challenges:
An infrastructure needs to be created to supervise and
monitor manufacturers
The model imposes significant pressures on the
judicial system to ensure that hallmarking standards
are maintained
Smaller manufacturers may have insufficient resources
to comply.
As such, this model is best suited to countries with the
capacity to supervise hallmarking centres and jewellery
retailers. Robust consumer protection laws and the
ability to impose effective deterrents are also helpful.

Developing Indian hallmarking | A roadmap for future growth

15

International best practice

To assess best practice on a global basis, this study has
analysed international systems from the five perspectives
discussed in the preceding chapter: policy, penetration,
process, economics and governance.
Implementing policy
To drive efficiency and effectiveness, our analysis
indicates that five key policies should be adopted.
1 Hallmarking should be mandatory
2 Standards should be detailed, practical and broadly
in line with those established by the International
Hallmarking Convention

In Egypt, the Ministry of Trade and Industry set up the

Jewellery Technology Centre in 2006 to provide training
courses around design, assaying and hallmarking.
In Turkey, the jewellery hallmarking is done on a voluntary
basis, penetration remains weak. Export jewellery is
hallmarked by the government mints; other hallmarking
facilities are located only at large centres (Ankara, Istanbul
etc.) and therefore standardised hallmarking is infrequently
performed by jewellers in other areas.
Penetration
Comprehensive policies and processes are clearly
beneficial but hallmarking is most effective when it is
widely adopted. Our analysis highlights four key ways to
encourage adoption.

3 The onus of hallmarking should lie with manufacturers,

particularly in large countries

Mandatory hallmarking is arguably the simplest method

4 Hallmarking authorities should increase consumer

awareness, particularly if hallmarking is voluntary

Raising consumer awareness can also increase

penetration

5 Dedicated vocational training programmes should be

established to ensure staff have the requisite skills.

Tax breaks and subsidies should encourage franchisees

to open centres in underserved areas

In the UK, for example, hallmarking is compulsory,

jewellery has to be tested and hallmarked, training is
offered at assay offices and guided tours are available to
increase awareness.

Secure freight services for valuables should improve

penetration in areas where there are few jewellers or
manufacturers.

In Singapore, hallmarking is voluntary but certified

jewellers have to test and hallmark all gold items.
Retailers and manufacturers are certified by the Singapore
Assay Office and retailers are incentivised both to seek
certification and to advertise it.
In China, the National Jewellery Quality Supervision and
Inspection Centre offers vocational courses to groom
talent for both jewellery design and inspection.

Developing Indian hallmarking | A roadmap for future growth

In the UK, for example, there are only four assay offices,
but overall penetration of hallmarking is high because it is
mandatory on all jewellery above a gram.
In Singapore, only 41 retailers and 33 manufacturers,
wholesalers and traders are certified by the SAO, but
consumer awareness programmes have been launched
and are supported by the retail community.

16

Process and technology

Appropriate equipment and methodology are essential,
if hallmarking is to be carried out effectively. Our analysis
has identified seven components of best practice.

Economics
Hallmarking is most likely to succeed if the centres where
it takes place are profitable. This can be achieved in a
variety of ways.

1 An XRF machine should be used for homogeneity tests

Price setting, where the price is fixed by a government

body, following consultation with jewellers, hallmarking
centres and customers

2 Sampling should be conducted according to specified

standards and assay offices may increase sample size
or melt items completely if there are serious quality
concerns
3 Advanced sampling methods may also be performed,
such as historical data-based dynamic sampling
4 Fire assaying should be used to determine the quality
of gold
5 The assaying centre should define minimum lot sizes to
optimise costs and streamline operations
6 There should be well-defined service levels for
each process
7 Laser hallmarking is preferable to surface etching.
In the UK, for example, the number of samples taken
depends on the quantity and nature of each parcel.
Dynamic sampling is also performed to assess historical
success and failure rates of individual jewellery dealers.
In Singapore, jewellery undergoes XRF testing, sampling
and fire assaying, while laser hallmarking is performed on
all items.
In the UAE. XRF based homogeneity tests, fixed sampling
and cupellation are performed according to Dubai
Municipal Standards. The Dubai Central Laboratory defines
the maximum number of articles that can be submitted
and hallmarking is available via etching and laser.

Price capping, which encourages competition among

centres, to the benefit of consumers
Additional revenue generation, where hallmarking
centres can pursue related business, such as
refurbishing jewellery or customised logos
Demand assurance through contracts with large
manufacturers
Fiscal intervention via subsidies on initial investment and
tax breaks
Consolidation where necessary, overseen by regulators
and monitored through competition law.
In the UK for example, prices are capped so each
assay office defines its own pricing with reference to
jewellery type. Pricing is also based on sample size and
manufacturers history, thereby encouraging them to
deliver a better product.
The UK industry has also consolidated so seven
hallmarking centres have closed and only four remain to
cover the entire country. Assay offices generate more
revenue by providing tailored hallmarks, sequential
numbering for coins and corporate brand logos.
In Singapore, the price is set by the Singapore assay
office and defined on a per article basis. Failure and
reconfirmation tests are charged at pre-defined rates.
In the UAE, prices are fixed, depending on the method
used for assaying and the type of jewellery being tested.

Developing Indian hallmarking | A roadmap for future growth

17

Governance
Hallmarking centres are only truly effective if their
hallmarks can be trusted. This relies on effective
governance. Our analysis indicates that governance can be
strengthened in five key ways.
Licenses and certifications issued by hallmarking
authorities should be subject to evaluation, at least once
a year
Authorities should take random samples from jewellers
to ensure hallmarking practices are rigorous
Severe fines should be imposed if jewellery is not of
the stated quality. In certain cases, licences may need
to be revoked
There should be strong rules to minimise conflicts of
interest between supervisors and the supervised
Consumers should be able to test their jewellery
independently at an assaying centre of their choice to
cross-check hallmark veracity.
In Singapore, the Singapore Assay Office (SAO) notifies
certified jewellers two days in advance before conducting
inspections. However, consumers can use SAO services
to check the purity of items purchased.
In the UAE, strong criminal laws and strict enforcement
create a strong deterrence against fraud. Additionally,
random inspections are conducted and hefty fines
imposed if cases of inaccuracy are found.
In Thailand, the state-owned Gems and Jewellery Institute
of Thailand is responsible for the assaying and hallmarking
of gold jewellery. But surveillance is conducted by the
Office of the Consumer Protection Board and the Tourism
Authority of Thailand.
In the UK, manufacturers are ranked based on past
success. These rankings are used to determine sample
size. Poor performers have to submit more samples,
which increases cost; strong performers submit fewer
samples, which reduces cost.

Developing Indian hallmarking | A roadmap for future growth

Key findings
Models
There are three distinct hallmarking models used around
the world: Government-owned, manufacturer-driven and
independent assay offices.
Government-owned works best in smaller countries
with an efficient public sector
Manufacturer-driven works best in countries with a
strong supervisory infrastructure, robust consumer
protection and the ability to impose effective deterrents
on rule-breakers
Independent assay offices work best in countries with
excellent record keeping and the ability to monitor
and enforce standards. The system also benefits from
elements of free market dynamics and government
initiatives.
International best practice
Hallmarking is most effective if it is mandatory and
manufacturer driven
Active monitoring drives compliance and minimises
conflicts of interest
Consumer awareness should be high
Hallmarking staff need thorough training
Appropriate equipment and methodology are essential
Price-capping or bespoke pricing can bolster demand
Tax breaks and other incentives can encourage centres
to open
Where necessary, consolidation can also help centres to
operate profitably
Random testing by authorities and consumers reduce
malpractice
Strong fines act as an effective deterrent.

18

IV: Future steps: delivering success

The Indian gold jewellery market is extremely complex. There
are more than 400,000 jewellers, most of which are small and
independently operated. The manufacturing base is also highly
fragmented and many operators are small-scale.
Consumers are extremely value conscious and will
sometimes focus more on price than quality, particularly
as many are unaware of hallmarking.
Consumers, retailers and manufacturers are widely
dispersed across India, imposing considerable logistical
challenges on hallmarking in remote areas.
It is also relatively easy for centres and jewellers to game
the system as supervision and enforcement remain weak.
Nonetheless, improvements have been made since the
BIS hallmarking system was introduced. Standards
have been developed, more than 300 centres have
been opened and awareness programmes have
been established.

In the longer-term, we would suggest more structural

changes.
i) Make hallmarking mandatory so all gold jewellery has
to be hallmarked
ii) Transition to a manufacturer-driven system as
international analysis suggests that this is the most
efficient and effective model.
We outline these recommendations in greater
detail below.
Strengthen governance
A successful hallmarking system depends on strong
governance. We would therefore advocate the following
measures:

As a result, 30% of jewellery is now hallmarked, leakage

has more than halved to between 10% and 15% and
consumer awareness is gradually increasing.

Ensure the BIS has national representation and robust

internal processes so jewellers and hallmarking centres
can be adequately monitored and supervised

Against this backdrop, we believe that India will

derive the greatest benefit from hallmarking if it persists
with the current system in the short and medium term,
but drives positive change via a range of specific
initiatives to:

Clarify responsibility for failure between jewellers and

hallmarking centres

1 Ensure that governance is effective so hallmarking

centres and jewellers operate with integrity
2 Improve consumer understanding of the benefits of
hallmarking via a well-planned customer awareness
programme

Develop more stringent deterrents if jewellers or

hallmarking centres breach the rules
Create and publicise an effective whistle-blower
programme against jewellers and hallmarking centres
Publicise the independent assay option. Already
available to consumers once they have purchased
jewellery, it is barely used and would help to root out
malpractice.

3 Incentivise and facilitate targeted opening of

hallmarking centres
4 Use existing analytics to develop a ratings system
for jewellers
5 Pilot BIS Unique ID scheme (discussed on page 20)
and other technology solutions to support hallmarking
6 Pursue membership of the International Hallmarking
Convention or develop an alternative.

Developing Indian hallmarking | A roadmap for future growth

19

Improve customer awareness

Many consumers are unaware of BIS hallmarking,
particularly those living in rural areas. Even among
educated consumers, only half are interested in or use
BIS hallmarks. Increased awareness will drive penetration
and encourage best practice. We would therefore
advocate that the BIS:
Develops and implements a compelling and granular
consumer awareness and adoption strategy
Targets messages to specific audiences, using
questionnaires and focus groups to identify gaps in
awareness and major concerns
Identifies feasible modes of delivery, such as
roadshows, advertising and stalls at retail outlets
Learns from previous successful public awareness
campaigns
Measures the impact by conducting surveys and focus
groups and tracking increases in hallmarking
Develops support systems among academics, gold
loan companies, NGOs and the media to help
propagate the message.
Promote targeted opening of hallmarking centres
More than 60% of hallmarking centres are concentrated
in Indias top 20 cities and there is further concentration
within the cities themselves. This results in pricecutting and poor practice in concentrated areas and
little awareness of or access to hallmarking elsewhere
in the country. We would therefore advocate that the
BIS undertakes an extensive programme to understand
the manufacturing volumes, circulation and sales of
gold jewellery at a granular level across the country
which would then allow it to identify areas of under and
oversupply and design policies to match demand with
supply. Tax breaks and other incentives could be offered
in areas of undersupply and royalty charges could be
fine-tuned in areas of oversupply.

Developing Indian hallmarking | A roadmap for future growth

Use data to develop a ratings system for jewellers

The BIS rules stipulate that hallmarking centres should
store data for three years. This information is neither
checked nor used adequately. If it were properly collected
and stored, it could be put to good use. We would
therefore advocate that:
A central data library is created, managed by the BIS
and used to store all hallmarking data, which could be
used to generate analytics on jewellers and hallmarking
centres that can be used in numerous ways
Dynamic and bespoke sampling should be carried out on
lots from jewellers and those with a strong track record
would have fewer inspections and require less testing
thereby reducing their costs
Jewellers and hallmarking centres performance should
be publicised on a central website to actively encourage
best practice with reduced royalties offered to the better
performing centres, thereby cutting prices for jewellers
and driving volumes.
Pilot BIS Unique ID schemes and other technology
solutions to support hallmarking
The current hallmarking system provides scant information
to allow consumers to trace items of jewellery. This is
natural, given the size of most jewellery items. We would
therefore suggest that the BIS should actively pursue
piloting its idea of a BIS Unique Identification (UID) system
for hallmarked jewellery. This would also appeal to the
younger population thats becomng increasingly digital.
This would offer four key benefits:
It would allow consumers to track changes of ownership
It would improve accountability, thereby discouraging
leakage
It would provide consumers with relevant information
It would allow consumer to use channels including
mobile apps, SMS and email to verify the authenticity of
their purchases.

20

Despite these advantages, UID schemes provoke concern

across the gold market:
Jewellers worry about prolonged liability
Some consumers prefer not to declare gold purchases
so as to minimise tax liabilities
If a photograph is the only way to link an item of
jewellery to the card, there is significant potential
for forgery
UID schemes may increase the proportionate cost of
small jewellery items on a percentage basis. They may
also reduce throughput at hallmarking centres
A chip-based solution has been considered for the UID
project, but it would create significant technological
challenges
Above all, while the UID scheme will enhance
traceability and therefore increase jewellers
accountability, it will neither directly reduce leakage
of gold nor increase hallmarking penetration.
We therefore believe that the UID project should be
introduced in phases.
First identify two or three cities with different
characteristics
Roll out UID schemes in these cities, by educating
jewellers, consumers and manufacturers about the
benefits they confer
If consumers and other stakeholders respond positively
to the scheme and under-caratage is reduced, full-scale
implementation could be considered after fine tuning the
programme.
Pursue membership of an international convention
The Vienna Convention was established to encourage
the international gold jewellery trade by providing a
common set of technical requirements and a Common
Control Mark (CCM). There are now 18 members of the
International Hallmarking Convention (IHC), all of which
are in Europe with one in Israel. Widely regarded as
evidence of international quality, member countries allow
goods marked with a CCM to be imported without
further testing.

If India were to become a member of this convention,

it would encourage strong internal standards and robust
quality control. It would also drive acceptance of Indian
gold on international markets. Joining the IHC involves
a detailed four-stage process, designed to ensure that
applicants have the appropriate systems, policies and
governance in place and that testing and sampling are
sufficiently rigorous.
To bolster the chances of success, we would therefore
advocate that:
The authorities should position India as jeweller to the
world with an extremely strong domestic market and
a growing export offer, focused on intricate and unique
designs. This could increase export volumes significantly
(Chart 7)
Efforts undertaken by the BIS to establish an effective
hallmarking industry should be highlighted
Key members of the convention should be identified so
India can articulate why it should be a member.
If membership is not feasible in the near future, we
believe India should take the lead in propagating the
idea of an Asian convention, including such countries
as China and Thailand, who are not part of the IHC.

Chart 7: Potential to increase Indian gold jewellery

export values
US$bn
45
5X

40

40

35
30
25
20
15
10

5
0
2013

2020

Source: World Gold Council survey of industry experts

Developing Indian hallmarking | A roadmap for future growth

21

Many large Asian markets are structured differently and

have different needs from IHC members. There is a high
proportion of small-scale manufacturers and jewellers,
gold jewellery is deeply rooted in Asian cultures and it is
used as an investment vehicle. India and China are also
among the fastest growing economies in the world and
gold jewellery is a significant share of their gross GDP.
An Asian convention would have three specific benefits:
Establish a high-quality, common and consistent
standard across all Asian markets to promote exports
Serve as a forum to exchange ideas, technology and
best practice
Promote Asian interests in global gold markets.

and drive consolidation within the unorganised jewellery

manufacturing industry, thereby creating economies of
scale and enhancing professionalism.
We would suggest a gradual transition over five to
seven years.
First, ensure a clear separation between retailers and
manufacturers
This would include separate licensing requirements,
as well as special considerations for talented
small-scale or artisan manufacturers
Second, define a policy to supervise and monitor
manufacturers

Longer-term considerations

Third, facilitate the establishment of adequate

hallmarking infrastructure at all manufacturers,
such as equipment, computers and data networks.

We have two longer-term recommendations, all of which

could be phased in over the next decade.

Key findings

Make hallmarking mandatory

Today, around 30% of jewellery is hallmarked and leakage
stands at 10 to 15%. Both these statistics have improved
considerably since BIS hallmarking was introduced, but
there is some way to go. Hallmarking is further weakened
by poor practices at hallmarking centres, often driven by
under-utilisation.
We would suggest a gradual move to a mandatory regime
over the next four to five years.
First, jewellers and consumers need to understand the
benefits of hallmarking. This could be achieved through
educational programmes, seminars and the media
Second, policies need to be made watertight so even
small jewellery items should require hallmarking.
Jewellers could also be incentivised initially with tax
breaks or other benefits
Third, BIS infrastructure needs to be enhanced both
internally, via increased staff numbers, and externally,
via increased numbers of hallmarking centres
Fourth, the new regime should be implemented in a
phased manner.
Transition the onus of hallmarking to manufacturers
Responsibility for purity lies naturally with the
manufacturer so it makes sense to transition the onus
of hallmarking to them. This would ensure clarity
around roles and responsibilities in the gold industry

Developing Indian hallmarking | A roadmap for future growth

The current hallmarking system in India is best suited to

its short and medium term needs
However, certain specific initiatives will improve gold
market functionality and reputation
Governance needs to be strengthened throughout
the process
Consumer awareness programmes should be
implemented to drive understanding of the benefits
of hallmarking
More hallmarking centres should be opened in areas
where none or few exist
Existing analytics should be used to rate jewellers and
adjust testing and supervision requirements accordingly
BIS Unique ID schemes could be piloted alongside other
technology solutions to support hallmarking
India should pursue membership of the International
Hallmarking Convention or develop an alternative
Asian convention.
In the longer-term, we would suggest more
structural changes
Make hallmarking mandatory so all gold jewellery has to
be hallmarked
Transition to a manufacturer-driven system.

22

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Published: July 2015