|Received:||8/14/2008 9:30:52 AM|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Jewelry, Precious Metals, and Pewter Industries|
|Attachments:||534660-00036.pdf Download Adobe Reader|
Comments:I prefer that no change is made at this time until a better solution in how to address the Platinum Base metal issue. But, if it "Platinum" ends up being allowed to be used to describe base metal alloy . . ***The current guidelines that companies would have to tell consumers is VERY MUCH unrealistic!. And very confusing, creating an atmosphere of intentional and unintentional misinformation and down right deceit. Here is my thoughts, IF "platinum" ends up being allowed in describing base metal alloys, it needs to be more simple. An item stamped "Plat" 900 indicates past standard that it is plat with plat family alloy. If stamped PlatX 800 or whatever purity percentage . . . the "X" indicates a non plat base metal. The consumer has to be told that plat alloyed with non plat base metals does not have the same attributes as traditional alloy. It is not required to give exact alloy, but recommended to disclose. But, there can be no claim that any base metal alloy has same attributes, even if there is "reliable" EVIDENCE. This is where problems will occur such as misrepresentation and deceit. What does "reliable evidence" mean? Simply, PlatX alloy must have disclosed "Jewelry made with Platinum alloyed withy non-platinum base metals may not have the same attributes as traditional platinum jewelry made with platinum group metals (such as purity, durability, luster, hypoallergenicity, tarnish/scratch resistance, resize/repair issues, ability to maintain precious metal content). " Again, this disclosure MUST be made with ANY Base metal alloy, REGARDLESS of any "Evidence". If the FTC does not address this issue properly, I guarantee that there will be confusion, there will be misrepresentations, and there will be deceit. If FTC does not address these issues, I would HIGHLY recommend that "Platinum" not be allowed to be used in non traditional base alloys. There are entities that know they can profit from the confusion, if the FTC does not approach this correctly.