Submission Number: 560895-00005
Received: 7/24/2012 5:04:28 PM
Commenter: Stephen Walker
Organization: Walker Metalsmiths
State: New York
Agency: Federal Trade Commission
Initiative: 16 CFR Part 23; Guides for the Jewelry, Precious Metals, and Pewter Industries; Project No. G711001
Attachments: No Attachments
§ 23.3 Misuse of the terms "hand-made," "hand-polished," etc.
Reading the language in this section it is easy to presume that "hand-made" is only a valid description of items that are "hand-wrought" from wire, sheet or bar stock. I believe that items cast from hand carved or hand-modeled wax or cast in hand-made molds, such as cuttle fish bone, tufa stone or carved plaster molds, should also be specifically included as items which may be called "hand-made". Precious metal clays, ingots and casting grain should be included in the list of "raw materials" in the Note to paragraph (a).
It should be clarified in the language of the rules that incidental findings that are machine made should not invalidate the description of a piece as "handmade" as long as the main creative content of the item is created according to these guidelines.