Peter & Co. Jewelers
16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries; Project No. G711001
Regarding the use of the word "cultured" to the description of lab created diamonds is blatantly deceptive. I agree with the Jewelers of America 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 Regarding the issue of Lead-Glass Filled Stones, this is another area where a consumer can be easily mislead. Why complicate the issue. It is either glass-filled, or it's not. The amount of filling should have no bearing to the consumer. I agree again with the Jewelers of America 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. any amount of filling - not just "substantial" levels - should be disclosed. Regarding the use of terms "gold" or Sterling silver", how will consumers know what they are buying if the definition for Sterling is changed? Sterling can only mean 925 ppt. this value for the description of Sterling has been in use since the 13th century. Anything other than Sterling, then has to be further described, but Sterling is what it is. Why confuse the consumer? Regarding "gold", it is identified with what it is, and that is also historic. Why do you have to change? thank you for the opportunity to add my comments.