16 CFR Part 23; Guides for the Jewelry, Precious Metals, and Pewter Industries: Public Roundtable; Project No. G711001 #00014 

Submission Number:
00014 
Commenter:
guy benhamou
Organization:
gold brand holding
State:
California
Initiative Name:
16 CFR Part 23; Guides for the Jewelry, Precious Metals, and Pewter Industries: Public Roundtable; Project No. G711001
It is deceiving to the consumer to buy an article of jewelry with the world GOLD as in" Rolled Gold plate", the consumer will think that he is buying a gold article when in fact that article is 97.5% Brass as in most rolled gold plate product or 97.5% silver in certain case.This type of jewelry is simply Brass or Silver and should be marked as such . The world GOLD will have the consumer believe they are buying gold when they are buying brass or silver, especially that this type of product is sold mostly in department store and discounters that have untrained personnel at the jewelry counter or no personnel at all .It is very frequent that the employees of those retailers tell the consumer that the product is gold simply because they read the world : rolled gold plate. The public is deceived . A class action lawsuit is currently in court with Macy's as the defendant, that is alleged to have deceived costumers in jewelry marking. If rolled gold plated has 1/40th or 1/ 20th parts of gold ,then 39 out of 40 parts or 19 parts out of 20th are brass or silver, therefore the jewelry should be marked brass or silver. The clothing industry does not mark a shirt 2.5% cotton without disclosing that 97.5 % is polyester. Rolled gold plated ,bonded gold or plated gold simply add a layer of gold to give a gold color appearance , the rolled gold plated add a thin layer of gold to another metal like brass or silver in most instance, so is the bonded method and the plated method by the electrolyte method. All the methods can add the same percentage and a consumer can not tell the difference from one method to the other, and it has never been proven which method will last longer given the same thickness. Gold is a powerful world , a precious metal that is very expensive and should be used only when the majority of the metal is gold. Current legislation prohibit the world gold when the content is under 10 karat or 41.7 %, then why used the world gold in a disguise sentence such as" rolled gold plate ". Regarding the use of karat versus percentage, it is a more transparent and less deceiving to use percentage for Karat gold: examples, instead of 14 karat, the jewelry will be mark 585 or 58.5 %, 10 karat will be marked 417 or 41.7 % . France, Italy and many others countries marked jewelry with the gold nominated in 1000th such as 585 for 14 kt. The public will certainly understand better 58.5% gold rather than 14kt .