16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries; Project No. G711001 #00060

Submission Number:
00060
Commenter:
Tricia LaBiche
Organization:
LaBiche Jewelers
State:
Mississippi
Initiative Name:
16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries; Project No. G711001
Use of the term "cultured" to describe synthetic diamonds LaBiche Jewelers Position Use of the term "cultured" to describe synthetic diamonds is confusing for the consumer and will lead to deceptive trade practices. The term "cultured" should be limited to organic processes only and should not be used to describe laboratory-created or imitation stones. Use of the word "cultured" is also inconsistent with international standards, such as one adopted by the International Organization for Standardization (ISO) in 2015. Lead-Glass Filled Stones Current FTC Guidelines Not addressed LaBiche Jewelers Position The terms "composite" and "manufactured composite" should be used to describe all gemstones filled with lead glass or any other binding material, whether or not the stone is one piece or small bits. The FTC proposal is inconsistent with the dictionary and industry definition of "composite," which describes a manufactured product made up of gemstone material that is combined with another product to create a single stone. Sellers can't differentiate between products with one piece versus bits of precious or semi-precious stones bound together since it is currently impossible for marketers to know this information without destroying the product. The word "substantial" should be removed in describing amounts of lead glass filling or other binding material in a product the word is ambiguous. Any amount of filling -- not just "substantial" levels -- should be disclosed. Use of the terms "gold" or "sterling silver" FTC Proposed Change FTC would revise their guidelines to allow jewelry product to be described and stamped as gold or silver, even below the current thresholds, as long as the fineness is indicated and the marketer has evidence of no material difference. Industry Coalition Status Allowing sellers to stamp product as "gold" or "silver" below current thresholds without additional disclosures will confuse consumers and reverse long-standing jewelry education and practices.