Recycled gold still needs an origin trail

A sourcing claim needs a defined boundary

A recycled label can sound like a complete answer to a difficult sourcing question. In practice it is the beginning of a more specific inquiry. Which material entered the chain? At what point was it classified as recycled? Which records connect that classification to the supplier and the finished product? This analysis, checked on 6 November 2026, examines those questions through LBMA’s published guidance. It does not authenticate any dealer, refiner or individual bar.

What recycled means in the published guidance

LBMA’s Responsible Gold Guidance V9 includes more than discarded jewellery in its recycled category. It covers material returned for a new lifecycle, including previously refined investment products and manufacturing material. Its definition places recycled origin at the point where material returns to a refiner, recycler or downstream intermediate processor. That differs from the mine location used for newly mined gold.

The distinction matters when reading an origin statement. A named recycling location does not, by itself, claim to identify the mine from which every atom originally came. I would ask a seller to specify the boundary of its assertion before judging whether the supporting evidence is adequate. A narrower, documented claim is more useful than an expansive claim whose meaning shifts when questioned.

Source notes: [1] LBMA — Responsible Gold Guidance V9: Definitions

Traceability is a system of records

Step 1 of V9 calls for controls connecting incoming lots, their upstream partners and the first destination of outgoing shipments. The listed information includes origin evidence, unique references, weights and assays, material categories and transport documentation. It also states that material segregation is not required.

My reading is that an audited process and physically isolated metal are separate propositions. If a product is marketed as containing only a particular source stream, I would look for evidence that supports that additional claim. A general traceability programme should not silently become proof of product-level segregation. The relevant question is what the records can actually connect, rather than how reassuring the programme’s name sounds.

Source notes: [2] LBMA — RGG9 Step 1: Management systems

A recycling label does not end risk assessment

Step 2 requires risk-based due diligence before a supplier relationship and throughout it. For recycled material, relevant inquiries include the counterparty’s activities, suppliers, facilities and anti-money-laundering practices. The guidance identifies documentation inconsistencies, unusual routing and higher-risk intermediate supply chains among issues requiring attention. High-risk classification calls for enhanced due diligence.

These requirements make sense as a method of resisting a shortcut: accepting a description of the material as a substitute for understanding the people and transactions behind it. An invoice can establish that a transaction occurred while leaving other questions unanswered. Evidence becomes stronger when independent records agree about the same transaction, dates and counterparties.

Source notes: [3] LBMA — RGG9 Step 2: Supply-chain risks

Read the assurance scope as carefully as the headline

LBMA’s FAQ adds a useful current distinction. For newly commissioned assurances from 1 January 2026, it identifies accepted OECD-aligned assurance routes for high-risk recycled material from intermediate refiners. It also explains that certain first-year Refiner’s Transparency Roadmap disclosures for FY2025, submitted in 2026, are outside the independent assurance scope, while the existing RGG9 high-risk classifications and enhanced-diligence outcomes remain within scope.

The analytical point is simple: a report can contain both assured and unassured information. A buyer should identify the relevant reporting year, named assurance provider, scope and exceptions. The presence of an assurance report does not mean every sentence in an accompanying disclosure received the same examination.

Source notes: [4] LBMA — Responsible Sourcing FAQs

Turn the claim into a reproducible purchase record

For a practical review, I would retain the exact sourcing statement offered at purchase, the product description, supplier identity and dated documents. Then I would write the unanswered question beside each claim. Does the evidence concern the refiner’s process, a particular lot or the individual product? Does the period reviewed include the transaction? Were exceptions resolved, merely disclosed or outside scope?

This is distinct from checking purity, comparing a Dubai premium or confirming storage ownership. Those checks answer other important questions and belong in their own records. Strong evidence in one area should not be borrowed to fill a gap in another. No finding of misconduct follows merely because a public document lacks detail; it means the public evidence has limits.

My conclusion is that recycled gold deserves precise descriptions, not automatic suspicion or automatic reassurance. The useful standard is a claim with a defined boundary, a traceable set of records and a clearly stated assurance scope. The illustration accompanying this article is conceptual and makes no product-certification claim.