Calvin Broyles Jewelers
Guides for the Jewelry, Precious Metals, and Pewter Industries
Dear Secretary, I am writing in opposition to the proposed changes to the FTC Guides for the Jewelry, Precious Metals and Pewter Industries as relating to the definition of “Platinum”. The following indicates a few of the negative effects that would or could result upon implementation of the proposed changes: Including materials in the definition that are alloyed with metals that are not a part of the platinum group, or in proportions that are not currently accepted in the worldwide trade, would degrade the perceived value of the material both domestically and in international trade. The requirement for sellers of fine jewelry to describe the different materials contained within a piece of platinum, including the attributes, or lack thereof, would impose an undue burden that would not be workable or enforceable. Consumers of “platinum” would lack the understanding of the difference in one platinum material versus another that has been alloyed with alternative base materials in terms of value, durability, maintenance and/or care, as well as historical significance. Optional descriptors for the "non-platinum/partial-platinum content" alloys should be put in place that would designate the material as other than pure or near pure platinum. These descriptors should apply to plated, filled, rolled, and any other form that is not complete or near complete of platinum content. Please reconsider the proposed matter and do not implement the changes as described in Matter No.G711001.