|Received:||3/28/2008 2:26:56 PM|
|Organization:||Hoover & Strong Inc|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Jewelry, Precious Metals, and Pewter Industries|
Comments:The first and most important comment I would like to make is that karat gold alloys do not require a disclosure of other precious or non precious alloying elements present, so why should platinum alloys? Fourteen karat gold jewelry only needs to be marked 14K or 585, so why not platinum also? Why would non-discloure of other elements present be classed as deceptive for platinum jewelry but non-deceptive for gold jewelry? A mark of 585 plat tells the consumer what they need to know, that the item consists of 585 parts per thousand platinum. Why is not disclosing other non-precious elements present deceptive? Various jewelry trade organizations state it is deceiving the consumer not to disclose all elements in the alloy, but I do not believe this is a concern of the consumer - it is a concern for these trade organizations only. Secondly it will be impractical for manufacturers to mark all of the alloy constituents on a ring or item of jewelry. In some cases it may be impossible. Again, this is not the case for gold alloys, so why platinum? This also brings about the necessary disclosure of proprietory formulas this requirement would mean. Jewelery alloy designers need to keep their compositions secure to prevent copycat alloys, and having to disclose alloying elements and percentages present would not allow them to do this. To take it to an extreme, I'm sure Coca-Cola or Kentucky Fried Chicken would have big problems disclosing their recipes on every container their products were sold in. They do not have to so why should the jewelry industry. There is also very sound evidence to show that some lower karat platinum alloys have superior mechanical properties to those made up of 950 parts per thousand platinum group metals or precious metals only. By making the marking of alloys unrealistic and impossible to comply to, thus forcing the manufacturer into an all preciuos metal alloy or even all platinum group metals alloy, the consumer may be getting an mechanically inferior alloy. The above is also true for expense. The cost of precious metals is high, so by using suitable base metals, the cost to the consumer is kept to a minimum. Finally, the ideal way to inform the consumer would be to have disclosure of what the alloys are at point of sale. Retail conterspace could be used to carry documents or leaflets explaining what a lower karatage platinum alloy is, how it is similar to a gold alloy, and that just because it has some base metalspresent does not make it bad. Regards Stewart Grice BSc MPhil CEng MIM Mill Procucts and Refining Director Hoover & Strong Inc.