16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries, Project No. G711001 #560895-00021 

Submission Number:
560895-00021 
Commenter:
Mark Hanna
Organization:
Richline Group, Inc.
State:
New York
Initiative Name:
16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries, Project No. G711001

See Attached. This is a joint communication from Sterling Jewelers, Inc. and Richline Group, Inc. As signatories of the official comments prepared by the Jewelers Vigilance Committee on behalf of the jewelry industry, we applaud their determination, diligence and efforts, and agree with the vast majority of the comments submitted. However, on behalf of our firms, Sterling Jewelers Inc. and Richline Group Inc., we believe it is imperative to additionally comment in more detail on a few areas of continuing concern in order to bring further clarity with regard to plating practices, as seen in our additional comments.