| Comment Number: | 517683-00033 |
| Received: | 08/24/2005 03:45:25 PM |
| Organization: | Bernie Robbins Fine Jewelry |
| Commenter: | Harvey Rovinsky |
| State: | NJ |
| Agency: | Federal Trade Commission |
| Rule: | Guides for the Jewelry, Precious Metals, and Pewter Industries |
| Docket ID: | To Be Added |
| No Attachments |
Comments:
Re. Jewelry Guides, Matter No. G711001 I am writing in support of amending the FTC Guides for jewelry to prohibit the use of the word platinum or any abbreviation to describe any product composed of less than 850 parts per thousand pure platinum and no other platinum group metals. I believe that allowing the marking of platinum on a piece of jewelry that could potentially include any product composed of between 500 and 850 parts per thousand pure platinum and no other platinum group metals will be confusing to consumers and jewelry salespeople. Jewelry is an emotional purchase often used to celebrate important milestones in a person's life. Platinum has long been thought of as pure. Allowing the dilution of platinum will make comparison shopping much more difficult. I believe a further erosion of consumer confidence will result if this marketing tactic is given any legal credibility. Please exercise the authority given to you to clear this matter now, before problems are created. In conclusion, I believe Section 23.7(b)(3) of the Guides should be amended to provide the following: (b) The following are examples of markings or descriptions that may be misleading: (3) “Use of the word ‘Platinum’ or any abbreviation thereof, to mark or describe any product that: (1) is not composed throughout of at least 500 parts per thousand pure Platinum; or (2) is composed of between 500 and 850 parts per thousand pure Platinum and no other platinum group metals.” Sincerely, Harvey Rovinsky President Bernie Robbins Fine Jewelry