| Comment Number: | 517683-00030 |
| Received: | 08/22/2005 06:52:52 PM |
| Organization: | coge design group |
| Commenter: | gerwin r. platz |
| State: | TX |
| Agency: | Federal Trade Commission |
| Rule: | Guides for the Jewelry, Precious Metals, and Pewter Industries |
| Docket ID: | To Be Added |
| No Attachments |
Comments:
August 21, 2005 Federal Trade Commission/Office of the Secretary Room 135-H (Annex Y) 600 Pennsylvania Avenue, N.W. Washington D.C. 20580 Re.: Jewelry Guides, Matter No. G711001 To Whom it may concern: We are writing to support the amendment of the FTC Guides for the Jewelry, Precious Metals, and Pewter Industries (Guides), 16 C.F.R. Part 23, to prohibit the use of the word “Platinum” or any abbreviation thereof, to mark or describe any product that is composed of between 500 and 850 parts per thousand pure platinum and no other platinum group metals. We believe such products present a significant risk of consumer confusion and deception and are contrary to consumer and business expectations as established over the many years of marketing platinum jewelry in the United States. Our Company is selling on a worldwide basis. All of our other export countries consider Platinum to be at least 900 parts pure. It is a standard that stands for quality and purity. Any deviation from that would confuse the consumer and their expectations would not be met. To allow a lower alloy content then 900 parts pure Platinum, would be like allowing to sell a Volkswagen Jetta for a Cadillac Seville. Due to the international nature of the jewelry market, the FTC should also ensure that the Guides are consistent with the International ISO standard that covers platinum alloys and does not authorize the marking or describing of platinum products containing between 500 and 850 parts per thousand pure platinum as platinum. Platinum Guild International is a strong international partner to market Platinum consumer products throughout the world and thus in conclusion, we believe Section 23.7(b)(3) of the Guides should be amended to provide the following: (b) The following are examples of markings or descriptions that may be misleading: (3) “Use of the word ‘Platinum’ or any abbreviation thereof, to mark or describe any product that: ( (A) is not composed throughout of at least 500 parts per thousand pure Platinum; or (B) is composed of between 500 and 850 parts per thousand pure Platinum and no other platinum group metals.” Sincerely, Gerwin R. Platz COGE Design Group Dallas, TX