16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries, Project No. G711001 #560895-00010 

Submission Number:
Susan Eisen, GG, MGA, ASA
Susan Eisen Inc.
Initiative Name:
16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries, Project No. G711001
1) The industry looks to the guides for guidance as the information is important for those of us who feel it is important to stay in compliance. Constant updating is essential as things are changing rapidly throughout the world and their effects wind up in the US. 3) More marketing of the guides to consumers would make it more valuable to them. Having some type of program whereby those jewelry industry people who are willing to have it listed on their marketing materials would be beneficial. 4) The Guides have helped me as a jewelry store owner advise customers about the issues discussed there. New issues such as the mass supply of lead filled rubies when they are noted in the guide help those currently buying them in the US and overseas. Also, the guides should be made available and marketed to the deployed military as they are buying thousands of gemstones without knowing what they are really buying. 7) Ethical jewelers who wish to follow the highest professional standards comply with the guides. As in any industry there are those that do and those that don't. Not having them available would be detrimental, and having them is only creating a higher standard for both businesses and consumers. 9) Policing the internet for accuracy in describing items for sale is very necessary. As internet sales grow without monitoring of gemstone information more deception will occur. 9a) Yes there should be some kind of reporting procedure to the FTC when something deceptive occurs either in a store or on line. Something like a complaint form provided by the BBB. 11b) It is my perception that those who would like to deceive think twice before they do because of the guides. There is no real way of knowing how the guides are being used without survey or some reporting procedures, however, having them is a way to keep tabs on what is happening both domestically and worldwide. 15) There should be some type of word before "ruby" if it is filled with either glass or lead to alert the consumer. Most consumers do not think about treatments when they hear the word "ruby" unless it has a descriptive title that would connote heavy treatment such as "composite" or "assembled". The military is a perfect example of this. In Afghanistan they are being sold "rubies" that are more filling than natural gemstone and yet they think they are getting the real thing at an incredible price when actually they are not. This is becoming more and more of a problem as I encounter it weekly in my professional jewelry appraisal practice living in a military town. 17) Yes the guides should be amended to list any kind of filled rubies to make the public aware they exist. 19) "Cultured" connotes a process facilitated by man but completed by nature to most industry professionals and consumers. "Cultured" should not be used at all if the item is manufactured totally by man, in a laboratory or other place where nature was not responsible for the final outcome at its own pace. 22c) There is a great deal of difference in value between a permanently treated pearl and one that is natural all the way. Treatments in a way are deceptive in comparison to the natural form of a gemstone and they should be disclosed to the consumer whether permanent or not in order to make it easier for a consumer to shop and compare.