16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries; Project No. G711001
I would like to propose a refining of the use of handmade in describing jewelry as it is defined in section 23.3(a) of the jewelry guidelines. I move that the use of handmade to describe pieces of jewelry produced by means of investment casting be explicitly precluded in future drafts of the commission's guidelines for the jewelry industry. Craftsmen that use traditional techniques to make jewelry from wrough sheet and wire should have the right to legally differentiate their products from products created from castings, even if those castings were made from wax models completely shaped by hand. Should investment cast jewelry be considered handmade in future FTC guidelines for jewelry, I feel it would only be fair to traditional jewelers to create a new classification for jewelry that is created completely by hand from cast wire and sheet ingot or raw bulk sheet, strip, wire, or tubing--I might even be tempted to preclude machine cut lapidary. Thank you for your time.