2018 FTC Jewelry Guides — Final Revision
2018 FTC Jewelry Guides — Final Revision
The most consequential rewrite of American jewellery disclosure rules since 1996
On 24 July 2018 the United States Federal Trade Commission published its long-anticipated final revision to the Guides for the Jewelry, Precious Metals, and Pewter Industries, codified at 16 C.F.R. Part 23. The 2018 revision was the first comprehensive update since 1996 and introduced several positions that continue to shape how American retailers, manufacturers, and certifiers describe their merchandise. For the international trade, the revision is significant because the United States remains the largest single market for finished jewellery and because compliance language drafted for the FTC tends to migrate, voluntarily, into Canadian and Mexican retail practice.
Background and scope
The Jewelry Guides are not statutes. They are administrative interpretations under Section 5 of the FTC Act, advising businesses on what the Commission considers to be unfair or deceptive practices in the marketing of precious metals, gemstones, pearls, and treated materials. The guides themselves do not carry penalties, but conduct contrary to them can be cited by the Commission as evidence of deception in an enforcement action. In practice, the trade treats them as binding.
The 2018 revision followed a multi-year proceeding initiated in 2012, with rounds of public comment, industry workshops, and engagement with bodies including Jewelers of America, the AGTA, MJSA, and the Jewelers Vigilance Committee. The final guides retained the core architecture of the 1996 document while modernising provisions on laboratory-grown materials, alloy disclosures, and certain treatment terminology.
Laboratory-grown diamonds
The most widely discussed change concerned diamonds produced by chemical vapour deposition or high-pressure high-temperature synthesis. The 1996 guides had limited the unqualified word diamond to natural stones. The 2018 revision removed the word natural from the definition of diamond, recognising that synthesised material is chemically and optically the same substance. The Commission was careful to note that this did not authorise unqualified use of diamond for laboratory-grown stones; descriptions must still make the origin clear, using terms such as laboratory-grown, laboratory-created, or a manufacturer's name with the qualifier created. The Commission specifically cautioned that the word cultured, used alone, was likely to deceive.
Precious metal thresholds
The revision retained the long-standing fineness thresholds for gold (no marking below 10 karat) and silver (the 925 standard for sterling) but updated provisions on alloyed and coated metals. The phrase solid gold remained restricted to articles of consistent karat throughout. Tolerances for plumb gold and silver were brought into closer alignment with international practice. New language addressed palladium and tungsten, which had grown significantly in the bridal market between 1996 and 2018.
Vermeil, gold-filled, and surface treatments
The treatment of vermeil received its own revision in 2018, raising the minimum gold thickness requirement and clarifying base-metal substrate language. Gold-filled, gold overlay, and rolled-gold-plate definitions were retained with minor refinements. The guides reaffirmed that plated articles must disclose the underlying metal and the karat of the surface layer.
Gemstone treatments
The 2018 guides expanded disclosure requirements for treatments that are not permanent or that require special care. Sellers must disclose any treatment that significantly affects value, that is not permanent, or that creates special care requirements, in immediate proximity to any description of the stone. The Commission declined to enumerate every treatment by name, preferring a principles-based standard, but it explicitly addressed lead-glass-filled rubies, beryllium-diffused corundum, and clarity-enhanced emeralds in commentary.
Pearls
The pearl section retained the requirement that the unqualified word pearl means a natural pearl, and that cultured, imitation, and assembled pearls be clearly described. New language addressed bead-nucleated and tissue-nucleated freshwater cultured pearls produced in volume from the late 1990s onward.
Industry response
The trade response to the 2018 revision was mixed. The Jewelers Vigilance Committee welcomed the principles-based approach. The Diamond Producers Association — now the Natural Diamond Council — expressed concern that the removal of natural from the diamond definition could mislead consumers, while the laboratory-grown sector welcomed the recognition. AGTA and ICA praised the gemstone treatment provisions for affirming that meaningful disclosure remains the cornerstone of trust in coloured stones.
In the trade
For practitioners working across borders, the 2018 guides set the de facto disclosure floor for any gemstone or precious metal article entering the United States retail channel. Canadian retailers, who are governed primarily by the Competition Bureau's Precious Metals Marking Act and provincial consumer protection law, generally adopt FTC-aligned disclosure language to streamline cross-border supply.