16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries; Project No. G711001 #00073

Submission Number:
00073
Commenter:
TERESA FRYE
State:
Oregon
Initiative Name:
16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries; Project No. G711001
I HAVE HAD MANY DISCUSSIONS WITH CONSUMERS OVER THE YEARS REGARDING PRECIOUS METALS FINENESS LEVELS AND THEIR PERCEPTIONS OF WHAT THESE ARE. I HAVE ALSO PARTICIPATED IN SEVERAL FORA ACROSS THE GLOBE WHERE FINENESS PERCEPTIONS BY THE CONSUMER HAVE BEEN A CENTRAL TOPIC. IT IS ABUNDANTLY CLEAR THAT OUR METHOD OF REFERRING TO METALS FINENESS IN KARAT TERMS IS OUTDATED AND A DIS-SERVICE TO THE CONSUMER. VERY FEW CONSUMERS KNOW WHAT A KARAT IS, OR THAT A 14K GOLD RING IS 58.5% PURE, OR LET ALONE WHAT 8K MIGHT REPRESENT. THE EUROPEAN SYSTEM TO SIMPLY HALLMARK THE FINENESS AS A CLEAR PERCENT OF TOTAL WEIGHT IS ELEGANT AND CAN BE UNDERSTOOD BY A CHILD IN ELEMENTARY SCHOOL. HALLMARKS SUCH AS 900 PT, 950 PD 750 AU, 585 AU, 10 AU, ETC ARE ABUNDANTLY CLEAR REGARDING WHAT PRECIOUS METAL PERCENTAGE OF THE WHOLE IS ACTUALLY BEING PURCHASED. UPON SALE TO A REFINER OR PAWN SHOP, THE CONSUMER CAN EASILY CALCULATE THE PRECIOUS METAL CONTENT AND ITS INTRINSIC VALUE BY SIMPLY LOOKING UP THE MARKET PRICE AND CALCULATING BASED ON PERCENT. ANYTHING LESS THAN THIS TIME-TESTED APPROACH WILL RESULT IN ONGOING CONFUSION. THIS BECOMES ESPECIALLY RELEVANT IF THE TRADE IS CONTEMPLATING LOWER FINENESS LEVELS THAN ARE CURRENTLY ACCEPTABLE ACCORDING TO THE GUIDES. FOR EXAMPLE, A 5% AU PRODUCT IS LIKELY TO PERFORM POORLY FOR THE CONSUMER. HOWEVER, IF THAT CONSUMER IS AWARE THAT THE PRODUCT IS 95% BASE METAL AND CLEARLY NOT "GOLD" JEWELRY AT SUCH A SMALL PERCENTAGE, THEN EXPECTATIONS FOR QUALITY AND LONGEVITY WITH BE LOWERED ACCORDINGLY. WE NEED A CLEAR TOOL TO KEEP RETAILERS HONEST IN THEIR ADVERTISING AND ALLOW THE CONSUMER TO KNOW WHAT THE INTRINSIC VALUE OF THEIR PRECIOUS METALS PURCHASES REALLY IS. LET'S FINALLY FIX OUR SYSTEM IN THE US TO A CLEAR AND LOGICAL ONE THAT PROTECTS THE CONSUMER AND PREVENTS OVERZEALOUS MARKETERS FROM TAKING ADVANTAGE OF WHAT IS INHERENTLY CONFUSING FOR THE PUBLIC!