16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries; Project No. G711001 #00041

Submission Number:
Michael Zibman
Initiative Name:
16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries; Project No. G711001
I do not see any good reason to change the standard for calling an item gold down to 6 karat gold. The US already has a lower threshold than much of the world at 10 karat (with no other country below 9 karat). Having been in the retail jewelry industry for more than thirty-five years this is not a problem that needs to be fixed, it will only create confusion. Lead glass filled corrundum has already become a problem in our industry due to no regulation and unethical behavior and should not be called ruby or sapphire but should be called what it is; a composite stone. We already have requirements to disclose treatments for corrundum and can call an item that has been treated a sapphire or ruby but then qualify it further by describing the treatment and necessary care. But these glass filled stones are not a single stone and will not hold up under normal wear and need special care when being cleaned and repaired. If this is not addressed properly this will lead to many retail jewelers being responsible for "damaging" a ruby or sapphire during simple cleaning since the customer was not made aware of what they purchased. The term cultured has been associated with pearls for more than 100 years and is understood to be a natural process, in a natural environment that is instigated by man, this process takes a lengthy period of time to accomplish. To apply that to a synthetic diamond is poor judgement as this is re-creating the effects of nature in a short period of time in a factory or lab. Those that want to use something other than synthetic, lab created or any other reality term is just trying to present a new product in a favorable light. Again having been in the retail jewelry industry as long as I have been, I have seen the synthetic emerald, ruby and sapphire market become a part of our industry without sugar coating what they are. These are lab created synthetics and there is a place for them. They do not need to be described as something they are not; if this is allowed it will create great confusion to the public and allow opportunity for unscrupulous manufacturers and retailers.