| Comment Number: | 517683-00035 |
| Received: | 8/24/2005 4:14:10 PM |
| Organization: | Bernie Robbins Fine Jewelry |
| Commenter: | Joseph Barnard |
| 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 jewelry as platinum when it contains less than 850 parts per thousand of 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. Consumers have long thought of platinum as pure. Allowing the dilution of platinum will make comparison shopping much more difficult. I believe that there will be a huge potential for miscommunication and misunderstanding. This could lead to charges of fraud or misrepresentation resulting in a further erosion of consumer confidence if this marketing tactic is given any legal credibility. Please exercise the authority given to you to clear this matter now, before the 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, Joseph W. Barnard Director of Stores Bernie Robbins Fine Jewelry