Product Disclosure: Synthetic and Treated Stones

Disclosure of laboratory-grown stones is now subject to an explicit labelling rule in Turkish law as well: since 24 June 2026, the Regulation on the Jewellery Trade (Kuyum Ticareti Hakkında Yönetmelik) has required synthetic stones to be clearly identified on labels, on invoices and in advertising. The sector's own standard regulates the matter more broadly: provision 29 of the Code of Practices introduces a prohibition on claims that covers not only synthetic stones but also treated and imitation stones.

The scope of the provision is broad. It covers all members that sell, advertise or market products containing treated, reconstructed, composite, imitation or laboratory-grown diamonds and coloured gemstones. Advertising and marketing are subject to the provision just as much as sales.

What Does COP 29 Prohibit?

Three obligations are introduced together. The first is that the information given complies with applicable law and follows internationally recognised standards. The second is that no false, misleading or deceptive statement is made and that such statements contain no material omission.

The third concerns proof: the claims made must not be misleading and must be verifiable. Verifiability is linked to provision 14 of the standard, on claims. For a statement to be defensible, therefore, it is not enough for it to be true; it must also be possible to show its basis.

The concept of material omission is familiar in Turkish law. In contract negotiations and at the time of sale, concealing information capable of influencing the buyer's decision produces the same result as an active misrepresentation. What the standard records is this principle, translated into the language of the sector.

How Are Physical Characteristics Disclosed?

In its second paragraph, the standard sets concrete criteria for the disclosure of physical characteristics. For gold, silver and platinum group metals, accurate disclosure of fineness is mandatory. A formal requirement is added to this: the description of fineness or content must be as conspicuous as the word “gold” or “silver” or its abbreviation.

The same logic applies to plating. The use of gold, silver or a platinum group metal as a plating material must be accurately disclosed; the description of the plating and the fineness or content of the material used must, again, be as prominent as the name of the metal. Any quality marks used are applied in accordance with applicable law or internationally recognised industry standards.

This criterion does not conflict with the fineness and hallmarking regime in Türkiye; it adds a visibility requirement on top of it. If the fineness is correct but has been left in the background in the product's promotion, a non-conformity arises under the standard.

What Requirement Applies to Those Issuing Appraisal Reports?

Provision 31 of the standard targets gemmological laboratories and businesses that issue grading, research, analysis or appraisal reports. They are required to establish documented policies and procedures and a formal management system, and to have defined roles and responsibilities for graders and appraisers.

There are two further requirements. If the business issuing reports is also engaged in selling the products in scope, it must document and implement the procedures it follows to avoid all potential or actual conflicts of interest. In addition, the technical requirements affecting the chain of custody, the validity of testing and the reporting of results, as well as the equipment and calibration procedures, are documented.

This provision directly targets a structure frequently seen in practice: a business that both sells a stone and issues the report on that stone. In such a structure, the evidential value of the report comes to depend on whether its conflict of interest procedures have been documented.

What Is the Equivalent in Turkish Law?

It is built on three routes. The first is a direct administrative rule: under the subparagraph added on 24 June 2026 to Article 11 of the Regulation on the Jewellery Trade, synthetic stones are identified on labels, product certificates, invoices and websites, and in advertising and promotional materials with the wording “synthetic”, “laboratory-produced” or “artificially produced”; in shops they are sold in a separate section, and online in a separate category. The Regulation governs synthetic stones; for treated, composite and imitation stones, the gap is filled by the standard and the general provisions.

The second route is the seller's liability for defects. A statement that the stone is natural constitutes an undertaking as to its quality; where the stone does not have that quality, the buyer's elective remedies come into play. What is decisive here is how the stone is described in the contract and on the invoice.

The third route is the consumer protection legislation on commercial advertising and unfair commercial practices. A misleading statement gives rise not only to contractual liability towards the buyer but also to a risk of administrative sanctions. In addition, the unfair competition provisions may be invoked with respect to competitors.

The means of proof is the same on all three routes: the appraisal report. For this reason, the laboratory requirements in provision 31 of the standard are, for the purposes of Turkish law, not an abstract quality criterion but an element that determines the value of the report before the court.

What Is the Most Common Mistake?

Misrepresenting the nature of the certificate. RJC certification is a company certification, not a product certification; it does not trace the origin of a particular piece of jewellery and gives it no guarantee of provenance. Promotion that creates the impression that a particular product is certified falls within the standard's own prohibition.

The organisation's handbook records this separately: members may not use the logo or certificate number in a way that makes misleading claims about certification, and may not give the impression that certification applies to facilities or materials outside the scope of certification. Correct use of logos is also checked in mandatory audits; incorrect use is a ground for a major non-conformity and for suspension of the certificate.

What Should Be Done?

• Identify synthetic stones with one of the wordings in the Regulation on the label, the certificate, the invoice and the website and in advertising; present them in a separate section in shops and online.
• Describe laboratory-grown, treated, reconstructed, composite and imitation stones separately in the contract, on the invoice and on the label.
• Make your statements not only true but verifiable; keep their basis on file.
• Show fineness and plating information with the same prominence as the name of the metal; take the visibility requirement into account at the design stage.
• If you both sell stones and issue reports, put your conflict of interest procedures in writing and implement them.
• Assess the appraisal report together with the description of quality in the contract; the difference between the two is the core of the dispute.
• Do not present certification as a product guarantee; make it visible in promotional texts that it is a company certification.
• Limit the use of the logo and certificate number to the scope; do not use them for facilities and materials outside the scope.

Warning. The information in this article is for general information purposes and does not constitute a legal opinion. Foreign exchange and precious metals legislation is a frequently changing area; the amounts, rates, thresholds, time limits and dates in this article may change in line with the legislation in force. Verify the latest version of the legislation before every application and transaction. Current texts are available at mevzuat.gov.tr.

Source: RJC Code of Practices Standard, December 2024 (COP 14, COP 29.1, COP 29.2, COP 31.1) · RJC Member Certification Handbook v1.0, February 2025 (§ 4.1.3 Table 4, § 5.3 Table 11, § 5.9) · Regulation on the Jewellery Trade, Article 11 (as amended by the Official Gazette of 24 June 2026, No. 33290) · Turkish Code of Obligations (Law No. 6098) (provisions on liability for defects) · Law No. 6502 on Consumer Protection and commercial advertising legislation · Turkish Commercial Code (Law No. 6102) (Türk Ticaret Kanunu) (unfair competition provisions)

Related page: Jewellers, Jewellery and Precious Stones