Corporate report

British Hallmarking Council: corporate statement, 2023 (HTML version)

Published 5 June 2023

This corporate statement reviews the British Hallmarking Council’s (BHC) objectives and performance for 2022 and its planned objectives for 2023. It should be read in conjunction with the Framework Document signed by the BHC and its sponsor body the Department for Business and Trade (DBT), formerly the Department for Business, Energy and Industrial Strategy (BEIS).

Review of BHC objectives for 2022

In its Business Plan for 2022, the BHC set the following objectives.

1. Enterprise

Objectives were to:

• consider and make recommendations on how the BHC and Assay Offices can support growth in the precious metals sector
• promote hallmarking as the guarantee of the integrity of the precious metals industry, stimulating growth via education and protection of legitimate businesses and consumers
• encourage and support the expansion and reach of UK jewellery and UK hallmarks into the rest of the world through work with the International Hallmarking Convention
• promote point of sale promotion of the protection offered by hallmarking through the Dealers Notice for physical and online retailers and to run the HALO Award 2022 and the Touchstone Award 2022

Outcome

Building awareness of the importance of hallmarking and compliance supports growth in the jewellery industry and related businesses by strengthening consumer confidence.

The BHC promoted hallmarking as the guarantee of the integrity of the precious metals industry by organising the inaugural HALO Award with related publicity and by keeping the Touchstone Award visible to Trading Standards by presenting the Special Recognition Award to WRi.

The BHC liaised with the Lord Chamberlain’s Office and the Assay Offices and publicised the commemorative mark for the late Queen’s Platinum Jubilee. Discussions and reports at Council meetings kept the BHC updated on developments with the International Hallmarking Convention.

2. Improving the regulation of precious metals marketed online

Objectives were to:

• introduce and induct a new member to the Education and Enforcement (E&E) Committee
• review the possibilities for development of further guidance and assets relating to the online Dealer’s Notice and related publicity
• run the HALO Award for the first time
• continue partnership working with Trading Standards Primary Authorities for major online retail platforms to improve compliance with hallmarking law
• devise plans for similar approaches to other online retail platforms; to run the Touchstone Award 2022

Outcome

New members were introduced and inducted to the E&E Committee.

The E&E Committee reviewed possibilities for further guidance and assets relating to the online Dealer’s Notice and concluded that this should remain under review alongside the Assay Offices’ work on similar issues as part of Assay Assured.

The HALO Award provided opportunities to publicise the online version of the Dealer’s Notice, including via profiles of the winning entry.

The BHC ran the Touchstone Award, as described in item 3 below.

Encouraging progress was made in discussions with a major online retail platform. This provides a good foundation for further improvements, and future work with other retail platforms.

Assay Offices issued “cease and desist” letters to retailers found not to be complying with the law.

3. Encouraging risk-based and proportionate enforcement of hallmarking across trading standards

Objectives were to:

• run the Touchstone Award for Trading Standards in 2022 if coronavirus (COVID-19) constraints allow

Outcome

The Touchstone Award was run in 2022 but was ultimately not presented to a Trading Standards (TS) team owing to the constraints on TS resources and none of the current hallmarking project teams being ready to submit an entry. However the importance of hallmarking enforcement was publicised to Trading Standards by presenting a Special Recognition Award to WRi, a body affiliated to CTSI, who had carried out pro bono internet sweeps on behalf of the BHC to identify the potential scale of non-compliance in online retail settings.

4. Operational integrity

Objectives were to:

• complete the programme of 5-yearly revalidations of sub-offices
• implement new protocols for applications for any new sub-offices
• continue to maintain oversight of arrangements to ensure the continued integrity of Assay Office operations including sub-offices, and work with the Queen’s Assay Master (as then titled) to co-ordinate activities and avoid duplication of work

Outcome

The Applications Committee has now revalidated all but one of the UK sub-offices. The revalidation of the final one was delayed due to co-ordinating visit dates with the King’s Assay Master. The Applications Committee continued to liaise with the KAM to co-ordinate activities and avoid duplication but this was hampered by lack of KAM resources.

The Technical Committee produced an updated version of the Hallmarking Guidance Notes and this was launched simultaneously on the BHC and Assay Offices’ websites. The committee also continued with oversight of the shared wiki of hallmarking decisions; the ongoing review of the XRF protocol; and the schedule of items needing amendment in the Hallmarking Act.

5. Council members and Chair

Objectives were to:

• carry out induction of new Council members on 15 March 2022
• assist with the recruitment of 4 new SoS-appointed members for appointment on 1 January 2023
• conduct annual appraisals of Council members and Chair

Outcome

New Council members were inducted.

Three people joined the E&E Committee.

A new Governance Working Group was established as an advisory group. Joanna Hardy, Gay Penfold and Chris Sellors were all reappointed to the Council for a second term. Fakir Osman was confirmed as joining the BHC with effect from 1 January 2023.

A fully revised appraisal process was implemented and a Council Effectiveness Review (CER) process was established alongside the appraisals for collecting and reviewing feedback and informing future action.

6. Governance and administration

Objectives were to:

• work with National Audit Office (NAO) to issue the 2021 Annual Report and accounts in required timescales
• to review governance against requirements of the revised Framework Document

Outcome

The Annual Report and Accounts were issued in required timescales and laid before Parliament.

A governance review was undertaken and an ongoing project established to implement actions, with progress reports and items for approval taken to the Council.

Council meetings (which had been held virtually during the COVID-19 pandemic) are now held in person once again. Committee meetings continued to be held virtually in the interests of cost saving and maintaining momentum.

Sustainability and equality, diversity and inclusion were reviewed by the Council alongside the relevant BEIS priorities.

BHC Objectives for 2023

1. Enterprise and growth

Objectives are to:

• promote hallmarking as the guarantee of the integrity of the precious metals industry, thereby supporting growth via education and protection of legitimate businesses and consumers
• promote point of sale promotion of the protection offered by hallmarking through the Dealers Notice for physical and online retailers and to run the HALO Award 2023

2. Improving the regulation of precious metals marketed online

Objectives are to:

• run the HALO Award to promote hallmarking compliance within and across business
• continue partnership working with Trading Standards Primary Authorities for major online retail platforms to improve compliance with hallmarking law
• devise plans for similar approaches to other online retail platforms

3. Encouraging risk-based and proportionate enforcement of hallmarking across trading standards

Objectives are to:

• encourage awareness and competency in hallmarking enforcement by running the Touchstone Award for Trading Standards in 2023

4. Operational integrity

Objectives are to:

• complete the programme of 5-yearly revalidations of sub-offices
• implement new protocols for applications for any new sub-offices
• continue to maintain oversight of arrangements to ensure the continued integrity of Assay Office operations including sub-offices, and work with the King’s Assay Master (KAM) to co-ordinate activities and avoid duplication of work.

5. Technical consistency

Objectives are to:

• work with the Applications Committee on the application of current IHC work to the UK and recommendations to the BHC
• publish the new Hallmarking Guidance notes on the BHC’s website on GOV.UK and the Assay Offices’ websites
• to keep the shared wiki of hallmarking decisions under review
• to maintain oversight of the XRF protocol
• to maintain the schedule of potential amendments to the Hallmarking Act 1973 (as amended)

6. Governance and administration

Objectives are to:

• work with NAO to issue the 2022 Annual Report and Accounts in required timescales
• review governance against requirements of the revised Framework Document
• successfully complete the DBT Partner Organisation Review

Authors

Noel Hunter OBE

Chair of the British Hallmarking Council

Craig Watson

Deputy Director for Borders, Accreditation, Measurement and Standards

Office for Product Safety and Standards, Department for Business and Trade

April 2023