|Received:||8/23/2008 8:34:23 AM|
|Organization:||Brown Goldsmiths & Company|
|Commenter:||W. Stephen Brown|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Jewelry, Precious Metals, and Pewter Industries|
Comments:I am concerned about a provision of the Proposed FTC Guides for marketing platinum jewelry. As I understand it, for jewelry made from alloys containing less than 85% and at least 50% platinum, consumers must be told that the jewelry may not have the same attributes as traditional platinum jewelry made from platinum group metals UNLESS the company selling the product has "competent and reliable evidence that its plantinum/bass metal jewelry has the same attributes as traditional platinum jewelry." In that case it would not be required to include this disclosure. I strongly disagree with the idea that a such a disclosure is not ALWAYS warranted. As a bench jeweler and store owner for over 40 years I submit that there is virtually no likelihood that a non- traditional platinum alloy formulation will ever have the "same attributes" as an all platinum group alloy (traditional). My concern is simply that false claims not be allowed in the marketplace. For instance one familiar to the jewelery world might easily imagine an advertisement with the following claim: "14 karat platinum--same as traditional platinum but at only half the price!" In my view, the only thing conceiveably accurate about such a marketing claim might be the price. In truth it IS conceiveable that a metallurgist might develope platinum alloys that contain less than 850 parts per thousand (ppt) that could improve on CERTAIN characteristics of traditional alloys. These claims have actually been made in the tradtional platinum alloy world. A number of years back 950 platimum with Cobalt was introduced to improve castability and polish-ability and meet the world standard for being called "Platinum". But there were some downside issues. 1. The alloy is magnetic (not helpful, as iron filings at the bench can be attracted and melted into the alloy leading to degradation). 2. The alloy discolored (tarnished) when heated (very different from the traditioinal Platium-Iridium which does not discolor). This is an example of a 950 ppt alloy that would not meet the standard of having that same attributes as "traditional platinum jewelry." My recommendation: Make manditory the disclosure for all platimum alloys with less than 850 ppt that the "jewelry WILL not have the same attributes as traditional platinum jewelry made with platimum group metals." It is the most honest representatioin of reality. As one concerned with a fair and honest marketplace, a fair representation of the truth is critical. Thank you for your time and work on this matter. If you wish to talk with me further on this matter I can be reached at work at: W. Stephen Brown Brown Goldsmiths & Co.