FTC guidelines

Okay…first, I don’t see the problem with saying the piece was
hand-worked and designed/etc. by CAD. I have to say…if anyone else
used hand-carved wax and I did the rest and called it my own, no one
would see it as all my own work.

Who would get the credit for an original piece if another jeweler
used an amazing piece you carved in wax and created the piece of
jewelry doing all the rest of the work?

Certainly you would not expect to receive credit…the thief did all
the ‘real’ work.

And your disagreement regarding the disclosure that it was computer
generated…that would be lying through omission.

I will tell you that there are probably many pieces I can create
with CAD that I could not create without it. My skills are not so
evolved in some of these areas. It doesn’t mean I’m less of a
designer or fabricator, it only means that I am not as advanced in
technique as I am in design.

I like CAD…it has its uses. But I would never present it as
completely hand-wrought.

That said, the point is rather moot. It isn’t what artists,
designers and fabricators feel is ‘hand-made’, but what the law
decides. And I would bet there will be more than one opinion on that
score as well.

Ash well,


I spent some time (way too much) reading over the FTC guidelines, and
discovered that there is no direct prohibition against using any
method of constructing jewelry and legally calling it hand-made,
except for the use of pre-fabricated parts. The only requirement is
that the “ENTIRE PROCESS” be accomplished by “hand labor and
manually-controlled methods”. Nowhere did I see a prohibition of CAD
CAM, or casting, or even a prohibition of mass produced jewelry.
Nowhere did I see a prohibition of power tools, electric or
otherwise. I also saw no rule stating that only fabricated pieces
qualify as “hand-made”. Nor did I see any mention of the “80 - 20

On the other hand, it is pretty specific in it’s description of raw
materials, saying in part “… ‘raw materials’ include bulk sheet,
strip, wire and similar items that have not been cut, shaped or
formed into jewelry parts…” My interpretation would include casting
grain and seamless tubing as “similar items” as they “have not been
cut, shaped or formed into jewelry parts”. But I’m not a judge in a
court of law.

It is my humble opinion that just like any other law in the United
States, these guidelines are open to interpretation until they are
brought before a court and a judge makes a decision, thus providing a
legal precedent. I think it would probably be an easy case to
convince a judge that a computer numerically controlled mill or
computer controlled printer is not “manually controlled”, but until
it goes before a judge, it is not specifically prohibited. I think it
might be a tougher case to prove that a piece made using power tools
or a hand-carved wax constitutes "misuse of the term ‘hand-made’ “,
so until a lawsuit is brought, proven and won, I will continue to
call jewelry I create using a flex-shaft or a hand-carved wax
"hand-made”. I will not use this terminology for a wax from a mold,
or a CAD CAM piece, but this is based on my personal interpretation
of the FTC guidelines and my own sense of fair play, not that of a
court of law.

Please don’t anyone misinterpret what I am saying. The creativity,
knowledge and skill required to produce an original piece using a
computer program blows me away. The investment in both time and money
is astounding. If it is your interpretation that the use of CAD CAM
does not conflict with the FTC’s guidelines concerning the "misuse of
the term ‘hand-made’ ", by all means, drive on. Until a court decides
otherwise, there is no precedent or rule (that I could find) saying
that it is misleading to use the term. If anyone knows of such a
legal precedent, please let us all know. Also, if anyone has a beef
with someone selling their jewelry as “hand-made”, and in your
interpretation it’s not, please bring a lawsuit so we will all have
some clear guidance.

Maybe we can get the Jeweler’s Vigilance Committee (JVC) involved in
such a suit. From their website, “JVC can help the trade understand
complex regulatory and compliance rules governing the manufacture,
sale and marketing of fine jewelry.”

From the posts on this thread, I think the JVC should get involved,
this is clearly an issue falling within their stated objectives. The
government has given us wide latitude and our interpretations of the
guidelines are as varied as our experiences. The public needs to know
we are taking care of our own internal disagreements and public
misrepresentations. We need to constantly prove we are an industry
worthy of the trust of our government, our customers and the public
at large. It would be an embarrassment and a shame on our trade for
us to wait until one of our customers brings a lawsuit forcing a
court to determine for us what does and what does not constitute

That would be a precedent we could live without.


Hello all,

I have been reading the comments about what is considered handmade
and what is not. Although some of the comments have been a little
extreme. Recently when talking to my publisher about my imminent
book, he asked me to define what I meant by hand made when I referred
to the term. Of course all of us goldsmi ths will use tools that can
make a job simpler, but I think there are limits. I told the
publisher about the times in the UK when we had regular power cuts.
The workshop that I was in at the time, worked normally as long as
there was natural light, we were all handworking goldsmiths. In short
I would say that if you can produce your work without the need of
electricity then it is most surely HANDWORK. In my workshop along
with my workbench,I have a lathe, two pendant drills, a polishing
motor and lights, these all need electricity but if I have no
electricity I can still work. 99% of my work is done with a hammer, a
hand piercing saw, gravers, chasing tools, and files. The only power
these tools need is my hands. I am sad that so much of my trade has
adopted the machine made route. I know that the customer doesn’t
really care how a piece is made, for the most part all that is
important these days is the designer name on the piece. I only hope
that in the future customers will treat their jewellery and objects
like art and appreciate the skills and handwork that goes into the
piece. We all know the skills of past artists and craftsmen. I know
that I like to own originals rather than copies of any art or craft.
Thats enough of my preaching, as you might now be aware I am not a
fan of CAD/CAM manufacturing. I think it will kill off many of the
hand skills of the goldsmith. Skills that have been passed down
through the ages. When I was apprenticed 47 years ago, there were
about thirty gold and silversmith apprentices finishing their
apprenticeships each year at ceremonies held at the Goldsmith’s Hall
in London. I checked my records and last year there were only three
apprentices gaining their freedom through service, which means via an
indentured apprenticeship.

Peace and good health to all
James Miller in the UK.


Personally I do not think a wax is handmade, I tell my customers that
the wax was hand carved and then cast, if it is reproduced I call it
a production piece and tell the customers more will be made. You and
others who support cad or whatever is next will be screaming about
how bad business is in a few years. If the buying public is led to
believe that all jewelry is handmade no matter how, we will loose in
the end. People are now finding out that all the big name designers
(ie yurman) are manufacturing overseas and they are very unhappy, and
most believe that all designers are doing the same. Until we stand
up, educate and draw lines we will continue to loose to the chinese
and others.

My rant for the day

Bill Wismar

Forget CAD/CAM for a moment.

Has anyone ever considered a milled or lathe turned object hand
made? I have always thought that was ridiculous.

Perhaps someone could call such objects hand crafted, but certainly
not hand made.

Bruce D. Holmgrain
JA Certified Master Benchjeweler

The words hand labor and manually controlled are the prohibition
against CAD/CAM. In CAD/CAM the computer is the controller for the
tool so therefore it is not a hand controlled process.

James Binnion
James Binnion Metal Arts


But who doesn't consider a piece that is cast, hand finished, with
set stones as handmade regardless if the original was wrought by
CAD or hand carved wax? 

Me for one. It is absurd to consider a machined wax part of the
process of hand making an object. That part is still machined. The
FTC has a category for this object. They call it “hand crafted”.

Bruce D. Holmgrain
JA Certified Master Benchjeweler

The FTC has a category for this object. They call it "hand

Can you point out where in the FTC guidelines where “handcrafted” is
defined? I always assumed that handcrafted is another word for


Bill and I had this discussion on the phone last night and although I
do not agree with wax not being hand made (we have agreed to disagree
about this) I have to support him on the rest of his rant. It is past
time for those of us who have spent decades of our lives developing
our skills and craftsmanship to allow our work to be thrown in with
work that has been mass produced and machine manufactured. I
personally carve a lot of wax and cast with a centrifucal casting
machine. I melt with a torch and release my casting machine by hand.
Nothing is automatic and the only machine involved is the force of a
wound spring in the casting machine. I also fabricate and forge as
well as pressure form. All of my systems are controlled by hand the
experience of my years at the bench. I will go to the mat with any
and all that my work is had made. My hands control all the tools
regardless of the power source. I and I alone control the cutting
edge, the hammer blow, and the heat source. If this is not hand made
I do not know what is. I resent and take exception to any automatic
machining such as CAM work being labeled hand made. Design on a
computer all you want but if you don’t manufacture with the power
tool in your hand or the cutting tool controlled by your hand you are
not making it by hand a machine is doing it for you. My rant… and
Bill I still say my cast pieces are hand made.

Frank Goss

As is often the case with very long threads, after awhile you start
to see something else, something between the lines.

I’m beginning to wonder if this subject is at least subconciously
also about self validation. Like, “OK, I’m officially a great jeweler
because I hand make everything, ergo that person over there is not
because he uses cadcam or whatever”.

Imho, what matters is the product. The purpose of the product is to

From that sale one would hopefully gain whatever self satisfaction
one might require. Van Gogh didn’t sell much in his lifetime and you
know what happened there. Sure, its very valuable now, but didn’t do
Vinnie a lick of good back then.

Machines can often do things hands can’t. If that something makes
the product sell, sounds like a recipe for success to me. Cadcam (for
example) is not just push a button and POP out comes a ring. It still
requires the skill of the operator. I’ve seen the most atrocious
cadcam pieces as I have seen the most atrocious handmade stuff. The
machine does not have a mind of its own so while the product may not
be legally called handmade, a fine specimen is just as much worthy of
praise as the exemplary handmade piece. Its just a different canvas.

It can be both inspiring and intimidating to converse on this forum.
But I think every craftsperson might be better served to seek the
approval of their clients first rather than their peers. Which is
not to say they are mutually exclusive, but your peers don’t buy your

My apologies to anyone who may have been offended.


It has been interesting reading all of the posts in response to my
reply to James Binnion concerning CAD/CAM in this thread on FTC
guidelines. I have enjoyed the banter (and my roasting). There are a
number of posts I feel I need to respond to and a array of topics
brought up which I should address. I hope I do justice to them all
with my response; and I apologize for what will no doubt be a very
lengthy response.

To put some perspective on my response, let me say that most of my
CAD creations have been in the one-of-a-kind category (the same as
my other jewelry work and the same as, the apparent majority, of
people on this forum); I do very little in the way of mass
production. If I am asked for production work, I send that work to
Dan Grandi ( Racecar Jewelry) because that is his specialty; some of
my clients send to China for their mass production (sorry, Mr. Wismar
and Mr. Grandi! I don’t like that much, either). Fact of life, for
the time being, is Chinese production helps some people’s bottom line
so they will use that inexpensive production method and I have no
control over that (I’ve tried). This too will pass, as the Chinese
economy is now experiencing inflation at a significant rate.

That said, please take note that I never stated that CAD/CAM created
jewelry objects should be called handmade. What I did say is: “I
don’t think most of my CAD creations could be differentiated from one
of my hand carved/fabricated pieces…”; to which Jon Donivan
responded: “…I’d have to say that this is the reason we have an
FTC it’s regulations. Handmade=made by hand. Machine made=made by
machine. Why does it need to be said?”

It doesn’t need to be said, John; that would be a horrible ethical
precedent if it was assumed that no disclosure need be made about
the about how a piece of jewelry is made or to misinform clients
about how their piece came to fruition. There is a lot of handwork
that goes into taking a CNC machined wax or printed model forward to
a finished piece of jewelry; still, I don’t know that I would have
addressed my work on a “handmade vs machine made” basis without the
prodding from all of these posts. I do distinguish for my clientele
between the different methods I use to create all of my jewelry. My
clients all know if I am machining, hand carving a wax, building from
stock metals (whatever) their piece of jewelry. They also know that
the design I sell to them is theirs and theirs alone…the design
sells along with the object unless the piece is from one of my
previously-designed lines or they prefer a discount by not purchasing
the design rights along with the objects That is for my retail
clients. My wholesale clients always own their designs and usually
determine for me the way they want the object produced. Anything else
would be unethical.

Not trying to remain humble, perhaps the difficulty distinguishing
my CAD from my fabricated work is because my bench skills have
evolved over the past 34 years to be on par with with what today’s
CNC machines can produce for the independent jewelry sector (or maybe
it’s just that my eyes are failing me as badly as my arthritic
fingers are…yet, still, I only have a mild reading glasses
prescription, and that is very recent).

All kidding aside though, I responded to the expressed thought that
"CAD/CAM to finished jewelry" requires less skill and attention
throughout the process than does bench work as we traditionally know
it. I said: (now in condensed form) that the CAD creator needs to
supply as much skill and attention to make the virtual design
flourish as an actual object as does any person carving a design from
a solid block of metal or fabricating from standard stock forms (I’ll
touch on wax carving/casting in a later post). My original post in
this thread was in reference to (or in deference to) Jim Binnion’s
post where he stated (now in paraphrased form) that hand work
(whether it be with non-mechanized tools or with power equipment such
as watch makers lathes or hand mills) requires a higher level of
skill and attention to detail than does producing the same item via
computer aided design and machining. It’s not higher skill, it is
just different skill. Jim does go on to say in another response to my
post that “Programming and setting up CAD/CAM systems require
significant knowledge and skill and yes it is very possible to screw
up and ruin a piece with them but once the program is debugged I can
set up my CNC lathe and walk away from it and it will cut a perfect
rendition of what I programmed into it 999 times out of a thousand.”

Jim, thank you for acknowledging that there is some skill and
knowledge involved in CAD work. It wasn’t easy getting up and
running at the beginning of designi with CAD (I use Rhinoceros); it
took me a full year (working 3 to 4 hours per night) to feel
confident enough with the program to use it for customer jobs; while
it took me only about 4 months of practice to feel confident enough
to hand engrave my first shotgun for a customer. It took even less
time to feel proficient doing a bead and bright cut setting, forging
a wire, or doing raisings for sale.

Referring to the “999 times…”, I’d like to point out again that we
are not referring to manufacturing in this thread, but rather to
single piece work done by an individual artist. Just because it CAN
be used that way doesn’t mean it WILL be used that way. As an
example: anyone can rubber mold a cast piece, a hand fabricated
piece, or a solid-block-carved piece to go into manufacturing just as
quickly and easily (and often more cheaply) as re-machining or
printing pieces from a computer file, so your point is moot, IMHO, in
this thread because no matter the method used to create the original
work, the work can be used to mass produce a facsimile of the 1st
item, if the original is of sufficient quality. Now to split hairs
here, we’re not programing the computer when we do the CAD portion of
CAD/CAM; what we are doing is taking a a computer and the resident
design program and using their abilities to do the background math to
define the surfaces of the object we are visualizing. We draw the
piece (in 3 dimensions) the same as we would for a working drawing
done by pencil. When our drawing is completed to our satisfaction
(and if the design program we are using to draw with doesn’t have too
many bugs) our design file has the mathematical surface information
in it to export to another program with which we then DO program the
tool path to cut or print the piece our hands created on the screen.
In manufacturing, it can then be reproduced at the 99.9 percentile of
accuracy. But I digress, because we are still talking one-offs.

Bill Wismar suggests: “Personally I think it should be disclosed that
it was computer generated and cut.”

Bill, I do let my clients (wholesale or retail) know when I intend
to create for them using CAD/CAM, its a great selling point. Bill,
you say in a later post: “…You and others who support cad or
whatever is next will be screaming about how bad business is in a few
years. If the buying public is led to believe that all jewelry is
handmade no matter how, we will loose in the end…”. Bill, just let
me say that I find that the vast majority of my clients are in awe
that their jewelry is going to be made by a computer because they
have a hard time imagining how it can be done. When they see the
rendering of the proposed jewelry in near photo-realistic form they
are awed even further. Then, finally, when the finished object looks
exactly like the picture, and it fits, and has all of the elements
they desired, they are very impressed that all of this was done
through the use of a computer. (little do they know of all the hand
work that went into the piece after the computer did its handiwork).
A few have a difficult time seeing the enlarged version on the screen
and imagining it small enough on their hands (“Wow! that’s really big
and heavy, isn’t it?!”), or are disappointed when the actual object
looks so much smaller than they imagined (“I thought it would be
bigger than that!”), but I find those are the same people who
couldn’t look at a hand rendering and imagine it in 3D to begin with.
Most are thrilled that I could get a computer to do all of that, when
they have a hard time downloading or uploading email. By and large my
clients are thrilled to have their work done in whatever manner I
choose to use to make their dreams come true for them to wear. My
business’s profit nearly doubled (up 47% in two years)once I started
using CAD/CAM. It is still producing about 45% of my sales. I’m
afraid those who fear CAD/CAM may be the ones “screaming” in a few

I still fabricate a large number of my custom pendants and rings, I
still do a lot of hand carved waxes and casting; I still hand
engrave (without a GraverMax or any power assist), and I will
continue to move metal until I’m unable to use my hands. I still
thrill about metal as much as I did when I first started learning
this trade in 1974. My biggest thrill is still:- though metal seems
so inherently hard, it can also be so plastic. I don’t fear the
future of either my hand skills or my CAD/CAM. When your hands and
mine are useless for moving metal, I’ll still be able to design on my
computer and have one of my skilled apprentices finish the metal work
for me. I’m 53 years old now, and I plan to be working metal and CAD
well into my 70’s; arthritis willing. I’ll pass along my metal skills
to anyone who asks, because I enjoy sharing my trade.

James Miller, a most respected goldsmith from the U.K. worries “I
think (CAD/CAM) will kill off many of the hand skills of the
goldsmith. Skills that have been passed down through the ages…”

James, not to worry. There is not any viable computer replication
for hand chasing or repousse, nor for granulation (even though the
mimic can be construed as close), nor for mokume-gane, Mr. Binnion’s
forte. CAD/CAM can’t yet assemble, finish, or set stones as well as a
skilled craftsman. It can’t reticulate a sheet or choose the best
part of a reticulated sheet to use for the design. CAD/CAM can’t yet
enamel. Stamping machines used for over a century to mass produce
silver service sets haven’t yet totally replaced hand craftsmen
raising teapots, chalices, or pitchers. How is it that you perceive
that CAD/CAM will then? There is so much CAD/CAM can’t do, that I
don’t fear that goldsmithing talents will get lost, we will need
smithing skills far into the foreseeable future. The sky’s not
falling; it’s actually getting higher as we raise the ceiling of
things we can accomplish in jewelry and metalsmithing in ways never
before dreamed of.

Kevin P Kelly wrote in that “If we’re doing it right, our work that
is, the process changes us. I don’t see how CNC contributes to that
experience. My underlying assumption is that we attempting to carry
on a tradition of handwork; not faster and more cost effective.” I’m
sorry Kevin, but I am in business to stay in business and the goal of
my business is not only to produce happy customers and to practice
the art and craft which I’ve learned; BUT I also have a goal to
provide a good enough living to support myself and my wife in the
best way and to the best standard of living which I can achieve. Long
before I learned CAD, I learned ways to speed up my hand work so I
could produce up to 5 custom pieces of jewelry each week, all in the
middle to high end category ($1000.00 to $80,00.00 wholesale). On top
of that was all the standard repairs and some restoration work I
needed to accomplish to assist my clients and keep a good working
relationship going with them. I needed to be fast and efficient; and
because I was performing for jewelers from all around the country, I
also need to be better than just “good” at what I did. They know what
is quality and what isn’t, so my work had to be excellent enough to
pass muster for at least 23 jewelers at anyone time. I’m a realist
and I like to eat well while living in a nice house in a nice
neighborhood. Sorry.

I like to keep the tradition of handwork going, too. I also realize
there are sometimes better ways to spend my time that beating a dead
horse. If a methodology has the potential to make my life easier
while still putting out quality work for my clients, I WILL use it
once I learn it. CNC has changed me in the process, Kevin. It has
broadened my horizons at a late stage in my life. It has kept me open
to new ways of thinking about problems. I now have time to write this
lengthy treatise!! I also have had the great opportunity of meeting a
number of other fine pioneers in the jewelry CAD/CAM field and have
had the mind broadening experiences of learning numerous programs and
getting my feet wet about how they work in the background to help
create what we see on our screens or machine out of wax or metal. I
have seen the directions that are proposed for future methods of
depositing metal rather than cutting it. The CNC learning process has
opened me up at least as much as my college experiences did. That’s
quite a contribution!

Bruce Holgrain posted: "Me for one. It is absurd to consider a
machined wax part of the process of hand making an object. That part
is still machined. The FTC has a category for this object. They call
it “hand crafted”. "

Bruce, it is absurd, isn’t it!? How can one cast some components,
lathe others, pick up found objects, clip out pieces from papers and
magazines to use as collages in portions of their jewelry creations,
or even (god forbid) use CAD/CAM components in their work and still
call it hand made. Look at Richard Mawdsley’s work; assembling all
those components that he cut with guides and his lathe turned tubing
pieces that create images of bottles, buckets, a calliope. How can
that be called hand made not just hand crafted? Bruce, if I do an
entire piece by CAD; there is no way to call it hand made. If I CAD a
part and machine it, then use it as a component in a fabricated
piece; I think that qualifies as hand made as nicely as any other
assemblage of non-mass produced parts. I CAD a number of pieces and
after finishing the metal product I’ll hand engrave it for total
coverage because the machined imitation of engraving does not come
close to the look or feel of a hand engraving job. Should I not note
the hand work involved? In a post from you today you asked: “Has
anyone ever considered a milled or lathe turned object handmade? I
have always thought that was ridiculous.” Yes, as a matter of fact,
James Binnion (whose post got me to write in this thread) did just
last Friday: “If I make that same part on my watchmakers lathe with
hand held gravers and a “T” rest it will require my total attention
and skill to get the part made and if that attention wavers or my
skills are not up to the job it will be ruined or of less than
desirable quality so making that part has a high degree of risk
involved and is definitely handmade.” while comparing CAD generated
work to his lathe generated work. Take that question up with Jim;
I’ve found it very rewarding getting into this discussion with him.

Rick Hamilton wrote: " I think that the FTC guidelines are fairly
clear, CNC is out of the realm of “handmade”. A keyboard is not a
hand tool in the way that a hammer or engraving burin (SP) is.
CAD/CAM is a manufacturing process even when one piece is the end
result. It is nice that the FTC has a 80/20 % rule about manufactured
findings, but really, soldering a few die struck pieces together
isn’t handmade, and neither is a jewelry item made from a computer
controlled machine…"

David Phelps wrote in today that with extensive research into this
topic in the FTC regulations "Nowhere did I see a prohibition of CAD
CAM, or casting, or even a prohibition of mass produced jewelry.
Nowhere did I see a prohibition of power tools, electric or
otherwise. I also saw no rule stating that only fabricated pieces
qualify as “hand-made”. Nor did I see any mention of the “80 - 20

Thanks for the research David!

I fully agree with you that we are not legal beagles and that this
discussion should be between attorneys and a judge in a court of
law; where the emotions of the involved parties are ignored and the
realities of the processes involved could be deciphered.

As with the casting vs fabrication issue, this one on CAD/CAM will
be on going for quite some time. I for one am very glad that I took
the plunge and started to discover what CAD/CAM has to offer. I am
very glad I am able to combine it with my traditional skills and am
open enough to try. I am grateful for CAD/CAM helping me for less
expense than an employee. Having arthritis as bad as I do now, and
having nagging tendinitis, it has been a godsend to me; helping
produce my “waxes”.

I’m also very glad that I didn’t invest in the buggy whip business!

Paul D. Reilly

Hi Paul,

Thanks for the long post, I understand and agree with many of your
points. I have been using CAD for twenty years now but have just in
the past 5 or 6 started to use CAM. My posts about handmade items
have nothing to do with CAD/CAM being good or bad better or worse
than a handmade item. As has been observed in the posts on this
subject there is good work and crap being done with any given
tool(s). And I agree that CAD/CAM is just another tool and that is a
good one to add to the arsenal.

But where we differ is I firmly believe computer controlled tools are
not hand tools and the product from them whether one piece or
thousands cannot qualify as hand made. Even though every CAD/CAM
part I have ever seen required extensive and often ridiculous amounts
of hand work to turn it into a finished piece suitable to be
presented as jewelry There is not the same level of skill required to
make a CAD/ CAM part. The reason I say this is that with CAD/CAM you
get an unlimited amount of “do overs” if it doesn’t look right or
needs to be tweaked to get it right, no problem just edit the fie and
run the simulation again or cut/grow the part again no big deal it is
just more machine time. Where as if it is a hand made part and you
need a “do over” it is going to require the same amount or more skill
and your time get the new piece. This is what I am talking about when
I say the CAD/CAM is a low risk method and hand work is high risk,
and this is why I think hand made work should demand a premium over
CAD/ CAM or other less risky means of production.

I do not expect to change your opinion on this but again I suggest
you read David Pye’s book (it is a short quick read) as he does a
good job of discussing the subject.



James Binnion
James Binnion Metal Arts


I'm beginning to wonder if this subject is at least subconciously
also about self validation. Like, "OK, I'm officially a great
jeweler because I hand make everything, ergo that person over there
is not because he uses cadcam or whatever". 

As one of the few who originally contributed to this thread, may I
remind people that the whole thing started with a few of us talking
about selling via Etsy, where you can sell your handmade goods.
Somebody then brought up the FTC guidelines with regard to what
constitutes handmade.

As someone pointed out, unless such a thing is actually heard in a
court of law and a precedent set, it is all rather subjective as to
whether this process or that process can be classed as handmade.

With all the back and forth that has gone on in this thread and
reading everyone’s opinions, I am 100% happy that what I make and am
planning to sell (probably mostly to American customers - therefore
must comply) falls very well within the FTC guidelines, and I can
say that for me personally it is certainly nothing whatsoever to do
with self validation. I was merely worried that the guidelines may
have skuppered my plans, but happily they’ve not.

It certainly has been interesting though.


Can you point out where in the FTC guidelines where "handcrafted"
is defined? I always assumed that handcrafted is another word for

I haven’t read the FTC guidelines recently but I think Bruce and I
have taken some of the same appraisal courses and that in those it is
mentioned that for a piece that does not meet the FTC guidelines for
“handmade” but has some handwork in it the term “handcrafted” can be
used. When writing my appraisals this is a distinction I always make.
In a piece of my own (this is for insurance valuations) if some part
of it is cast (many of my pieces are a combination of casting and
construction) I will apply the term “handcrafted”. If it is
completely hand built then it gets the term “handmade”.

And this brings up a point a few of us have been making. What is so
denigrating about calling a piece “handcrafted”? As long as you tell
the customer what is being done to make their piece who cares
ultimately what it’s called? For that matter as long as the piece is
well made and beautiful who cares what processes were used to make

Daniel R. Spirer, G.G.
Daniel R. Spirer Jewelers, LLC
1780 Massachusetts Ave.
Cambridge, MA 02140

If I CAD a part and machine it, then use it as a component in a
fabricated piece; I think that qualifies as hand made as nicely as
any other assemblage of non-mass produced parts. 

Paul, as I have said, I don’t agree that using any mass produced
parts qualifies as handmade. As I’ve also said, it doesn’t matter to
me enough to get into it with anyone. I did enjoy your (looooooooong
;} essay though, and I for one agree with all you say except for any
notion that CNC has anything to do with “handmade” jewelry, which I
believe you also understand, from your essay. I also have always said
and thought that CNC is good for what it’s good for, and although I’m
big on bench skills for all, I’ve been considering taking the plunge
into CNC, too. It’s good for what it’s good for - and I’ve got a
couple of years on you, too. The eyes aren’t what they once were…


...Who would get the credit for an original piece if another
jeweler used an amazing piece you carved in wax and created the
piece of jewelry doing all the rest of the work?... 

I read your post a few times and like your thinking. I would like to
ask you this:

Who should receive the credit when another jeweler send you a very
rough sketch of a design idea and has you refine the design, hand
carve a wax (or CAD/Cam it), cast, finish, set the stone(s), and
final polish the piece; then you send the finished work back to the
original jeweler for it to be photographed and used in advertising
and publishing?

This is what my normal business entails.

Below are the complete and total paragraphs from the FTC guides for
jewelry about hand-made. Nowhere does it differentiate a class of
goods that are hand crafted rather than hand made nor are there
80-20 policies. It is very simple it is either hand made or not. If
you were to use hand crafted to describe an item it would have to
meet the standards listed below in paragraph (a). If you have a
CAD/CAM model that is then cast and hand finished then you could say
hand-finished or hand-polished as per paragraph (b) but hand crafted
would tend to imply hand-made which would be misuse of the term.

23.3 Misuse of the terms "hand-made," "hand-polished," etc. 

(a) It is unfair or deceptive to represent, directly or by
implication, that any industry product is hand-made or
hand-wrought unless the entire shaping and forming of such
product from raw materials and its finishing and decoration were
accomplished by hand labor and manually-controlled methods which
permit the maker to control and vary the construction, shape,
design, and finish of each part of each individual product. 

Note to paragraph (a): As used herein, "raw materials" include
bulk sheet, strip, wire, and similar items that have not been
cut, shaped, or formed into jewelry parts, semi-finished parts,
or blanks. 

(b) It is unfair or deceptive to represent, directly or by
implication, that any industry product is hand-forged, hand-
engraved, hand-finished, or hand-polished, or has been otherwise
hand-processed, unless the operation described was accomplished
by hand labor and manually-controlled methods which permit the
maker to control and vary the type, amount, and effect of such
operation on each part of each individual product. 

James Binnion
James Binnion Metal Arts


A jeweller buys a casting from the casting house and a stone from the
gem merchant, finishes the casting, sets the stone and calls it hand
made. Another jeweller buys a head and a shank from the casting
house, assembles and finishes them, sets a stone and calls it hand
made. Another buys a complete ring from the catalogue of a
production company… Then there are those who make moulds of
anything interesting that passes through their hands. They have a
huge collection of ‘designer’ designs all ready to be ‘hand made’ at
a moments notice. I think these people are amongst those that the FTC
guidelines are addressing.

Carve your own wax and cast it yourself, or carve your own wax and
send it to the casting house? Small difference and the latter may be
a better product. Simply give credit where credit is due and tell it
like it is.

Compare CAD-CAM to computer generated music (which is maturing
nicely these days). The music is clearly something that is impossible
to make by any other means. It is greatly appreciated for what it is.
Do not be ashamed to call it CAD-CAM!

Then there are self-proclaimed ‘master jewellers’, but that is
another topic.

Some of the people can be fooled some of the time, but honesty and
integrity are much easier and more rewarding in the long haul.

Cheers, Alastair

I just finished jewelry essentials (gia) and handmade only allows the
use of hand tools and maybe things like a flex shaft. Mass produced
pieces being assembled is not considered hand-made to the ftc. Go to
the ftc website and do some searching you will find it rather


Since so much of the B/S stuff is ‘handmade’, I’ve been using the
term Artisan made or crafted, a lot. I do this to emphasis that an
artist (me)

designed and made it.
Cairenn, the Howling Artist