16 CFR Part 23; Guides for the Jewelry, Precious Metals, and Pewter Industries: Public Roundtable; Project No. G711001 #00015 

Submission Number:
00015 
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
The FTC should closed all the loopholes that certain marketers of jewelry are trying to take advantage by using the world GOLD to designate jewelry that only contains one or two dollars worth of gold in jewelry retailing for $50 dollars and more. Regardless of how it is applied when the gold is used to only "color" the jewelry, and that gold is applied on top of a primary metal such as brass or silver , in a similar fashion that a shirt is dyed, the world gold should not be mark on the jewelry or in marketing materials. The world gold should only be used when : 1) the gold is mixed in the alloy and not just cover it. 2) that alloy contains a minimum of 41.7% of fine gold ( current FTC rules) Short of that the public will be deceived in believing that a gold jewelry "painted, plated,bonded,rolled.... has a value associated with solid gold, or buy it believing it is gold. The real issue is why this jewelry is not marked with the primary metal content ,such as brass...