What exactly is covered (and HS codes)
- Silver jewelry: finished jewelry and parts of silver typically ship under HS 7113.11 (“Jewellery and parts thereof, of silver”).
- Henna products (Lawsonia inermis), depending on form:
- Raw/leaf powder often as HS 1404.90 (“Vegetable products n.e.s.”).
- Vegetable colourants (henna extracts) as HS 3203.00 (“Colouring matter of vegetable or animal origin”).
- Finished hair-dye preparations using henna typically under HS 3305 (“Hair preparations”). (Heading description; used when exported as ready-to-use cosmetic.)
- Raw/leaf powder often as HS 1404.90 (“Vegetable products n.e.s.”).
HS use varies by processing stage and destination’s customs practice. Ask suppliers which HS line they use and why; keep paperwork consistent with product form.
Export snapshot
Silver jewelry (HS 7113.11)
Henna & other vegetable colorants (HS 3203)
- Under HS 3203.00, India exported US$26.3 m in 2023 (6,300 t). (Note: HS 3203 includes non-henna vegetable dyes, so treat as a lower-bound proxy for henna extracts.)
For henna hair dyes shipped as cosmetics (HS 3305) or raw leaf powder (HS 1404.90), values are not isolated globally; expect supplier-level data rather than clean, single-code country totals.
Quality, compliance & testing
A) Silver jewelry
- Indian hallmarking / fineness: BIS standard IS 2112:2014 governs silver jewelry fineness & marking; commonly used fineness grades are 990, 970, 925, 900, 835, 800. (Hallmarking for silver has been voluntary; the standard and grading are active.)
- EU market access (REACH):
- Nickel release from items in prolonged skin contact must be ≤ 0.5 µg/cm²/week per EN 1811; interpretation updated in EN 1811:2023.
- Cadmium in jewelry is restricted to ≤0.01% by weight (Annex XVII Entry 23).
- Lead in consumer articles (including jewelry) is restricted under Annex XVII Entry 63 (general lead limits apply).
- Nickel release from items in prolonged skin contact must be ≤ 0.5 µg/cm²/week per EN 1811; interpretation updated in EN 1811:2023.
Practical QC ask (silver):
- BIS hallmark or assay certificate confirming fineness per IS 2112.
- EN 1811 nickel-release test reports (especially for ear/body jewelry), plus Cd/Pb screening via XRF + confirmation by ICP if needed.
- Plating/coating specs (e.g., rhodium or anti-tarnish) with thickness verification—helps durability and REACH compliance (nickel barrier).
B) Henna products
- Indian specification (BIS): IS 11142:2023 defines cosmetic-grade henna powder and Type variants. Key limits for Type 1 (pure henna) include:
- EU scientific view: Lawsone (active dye) typically ~1–2% in dried leaves; the SCCS has repeatedly evaluated henna/lawsone safety for cosmetics.
- US compliance: FDA approves henna as a hair-dye color additive only—not for direct skin application (so “henna body art” is not an FDA-approved use; “black henna” with PPD is illegal for skin).
Practical QC ask (henna):
- BIS-aligned CoA showing lawsone %, moisture, ash/acid-insoluble ash, no synthetic dyes/PPD; microbiology & heavy-metals panel.
- If sold as organic, insist on NPOP certification (India’s scheme administered by APEDA) and, where needed, USDA-NOP or EU organic acceptance (NPOP is recognised by the EU/Switzerland for unprocessed plant products; GB accepts NPOP; the US requires separate NOP certification).
Why India—and which regions—have an edge
Silver jewelry: Jaipur (Rajasthan) & allied hubs
- Jaipur is a long-standing manufacturing hub for colored-stone jewelry and silver work, with integrated cutting, setting, and fabrication—documented by GIA and state/industry sources.
- Rajasthan contributes materially to India’s gems & jewelry exports and is dominant in traditional techniques (e.g., meenakari, kundan), underpinning a deep artisan base that also services modern silver lines.
- The Sitapura industrial area hosts SEZs and export-focused units, easing logistics and compliance.
What this means for buyers: concentrated skills, predictable scaling, and access to assay/hallmark centres make Jaipur-area suppliers strong for 925 sterling collections, oxidised/hand-finished looks, and stone-set silver lines.
Henna: Sojat (Pali district, Rajasthan)
- Sojat Mehndi holds an Indian GI (Geographical Indication)—application no. 628; registered on 14-Sep-2021—recognising the region’s distinct quality.
- Agronomic studies show Sojat crops deliver higher lawsone than other Rajasthan sites under comparable conditions—supporting the area’s reputation for deeper stain.
What this means for buyers: consistent raw material with strong dye content and a recognised origin story (GI)—useful for premium branding and repeatable colour performance.
Product/pack specifics to request
Silver jewelry
- Fineness: Sterling 925 (or chosen grade per IS 2112); source hallmark stamp files + BIS hallmarking records.
- REACH: Supplier test pack including EN 1811 nickel release, cadmium/lead screening; agree remediation if any batch fails.
- Finish & tarnish resistance specs (e.g., silver-oxide finish, rhodium flash incl. thickness).
Henna
- Grade: BIS IS 11142:2023, Type 1 (pure) unless a blend is specified; lawsone ≥1.0% target
- Adulterants: Written guarantee “No PPD or synthetic dyes”, plus method-based test results.
- Labelling: warning text and ingredient list per the standard; if selling in the US/EU, ensure claims and directions follow local cosmetic regs (and no skin-application marketing in the US).
- Organic (if applicable): NPOP certificate + transaction certificate (TraceNet); add USDA-NOP certificate when exporting to the US.
Market context & risks to watch
- Jewelry trade conditions: Jaipur’s SEZ-based exporters have flagged pressure from recent US tariff actions on jewelry exports; SEZ units can’t offset with domestic sales, so monitor landed-cost impacts in the US.
- Organic claims: India’s NPOP is recognised by the EU/Switzerland and accepted by GB, but the US ended mutual recognition with APEDA—US-bound “organic henna” must carry USDA-NOP certification.
- Henna safety: “Black henna” (PPD-spiked) is not legal for skin use in the US; even natural henna for skin is not FDA-approved—position US-bound products as hair dyes only.
One-slide talking points
- Silver jewelry: India exported US$2.22 bn (2024); Jaipur/Rajasthan offers deep craftsmanship + SEZ logistics; buy to IS 2112 fineness and REACH nickel/cadmium/lead compliance.
Henna: Source from Sojat (GI-tag) for dye strength; enforce IS 11142:2023 specs (lawsone %, no synthetic dyes), and align organic claims with NPOP/USDA-NOP as destination requires. US: hair-dye only; no skin-use marketing.