‘Synthetic’ and the FTC:
How an untested industry claim became guidance
‘The record from 30 years ago shows how a claim first made by producers and sellers of synthetic gemstones, without supporting evidence, became the basis for taking “synthetic” off the FTC’s list of recommended qualifiers for diamonds.’
A former president of the London Diamond Bourse, at whose head he served from 2018 through 2024, Alan Cohen is a member of the World Diamond Council’s Board of Directors and also of its Kimberley Process Task Force.
South African-born, he left the country as a young diamantaire, settling in London and becoming part of United Kingdom’s diamond sector. When the Russian diamond industry opened to the international trade in 1990, he relocated to Moscow, where he lived and worked for 16 years.
After returning to London he became active in the public life of the industry, first at the London Diamond Bourse, and later at the World Federation of Diamond Bourses and the World Diamond Council.
OCTOBER 1, 2026
As a reflection of how much the world has changed, I feel compelled to make the following clarification before going any further.
When I recently received copies of the 1996 and 2018 FTC Jewelry Guides, I planned on writing this piece entirely on my own. Until then, I had not even known that the 1996 Guide existed.
I read as much of the Guides as I could, searched through archives I could find and began writing. As a fact-checking exercise, I then put my rough draft into an AI agent.
It was at that point that I realized I could not properly complete this work without using AI to verify my findings and provide the necessary references and footnotes. It also showed me how much I had initially missed — not only errors in my own perception and understanding of the Guides, but apparent errors and inconsistencies within the Guides themselves.
So, before anyone shouts, “You are biased and this is AI!” let me state it loudly and clearly from the outset: Yes, I have a personal view, and yes, I used AI. The conclusions, however, are mine.
— Alan Cohen, London, October 2026
The Federal Trade Commission headquarters in Washington, D.C. (Photo: Wikimedia Commons)
In 1996, a claim is accepted without evidence
The record from 30 years ago shows how a claim first made by producers and sellers of synthetic gemstones, without supporting evidence, became the basis for taking “synthetic” off the FTC’s list of recommended qualifiers for diamonds. The word then disappeared from the list for colored stones as well, even though the FTC’s own reasoning said it should stay.
The FTC’s 1996 review of the Guides, which cover precious metals, pearls, pewter, watches and gemstones, followed a petition by the Jewelers Vigilance Committee. Some 263 comments were received during the entire process, and by the FTC’s own count, only 10 came from synthetic gemstone manufacturers. The only consumer body commenting among the 263 submissions was the National Association of Consumer Agency Administrators.
Importantly, the Commission’s published discussion in 1996 cites no consumer-perception evidence or data on the word “synthetic.”
At that time, commercial synthetic diamonds for jewelry were very rare indeed. The debate was entirely about colored stones: created emeralds and rubies, and whether flux-grown and melt-grown products deserved different names. The arguments against the term “synthetic” came almost entirely from producers and sellers of synthetic colored gemstones.
Examples included Chatham Created Gems, which argued that most consumers understand “synthetic” to mean fake, artificial and low quality. River Gems & Findings maintained that consumers associate the word with synthetic fabrics and do not understand its gemological meaning. Manning International, a producer of melt-grown rubies, claimed the public misunderstanding could not be changed.
Alternative opinions were expressed by laboratories, such as American Gemological Laboratories, which supported use of the term “Laboratory Grown (Synthetic),” which it said was easier for retailers to explain. AGTA, representing the natural-colored-stone trade, argued that there should be no substitute for “synthetic” at all.
But ultimately the FTC said it was “persuaded” that some consumers misunderstood “synthetic” to mean something fake or artificial, and added “laboratory-grown,” “laboratory-created” and “[manufacturer name] created” to the Guides.
What was remarkable then was the FTC’s double standard. It refused to endorse “cultured” or “created” as acceptable descriptors on their own because no consumer-perception evidence had been submitted. Yet it accepted the producers’ and sellers’ claim about “synthetic” being associated with “fake” with no survey and no data. In that instance, a commercial assertion apparently was enough for a ruling.
Two further points are often overlooked. First, the 1996 edition of the Guide did not remove “synthetic.” The final version kept the descriptor alongside the new terms, and the FTC confirmed that sellers could still use it. Second, the FTC acknowledged that some consumers appreciated the technical meaning of the word “synthetic,” which had been used in the gemstone sector for many years.
To be clear, use of the adjective “synthetic” is still permitted, and it remains in the Guides. But it is no longer listed as an example of an acceptable qualifier for any gemstone in Section 23.25(b) of the document.
In 2018, the 1996 Assumption Is Reinforced
The 2018 revision built on what had been accepted in 1996. By then, synthetic polished diamonds were entering the market in force, and diamond growers had an eight-year-old precedent. The FTC had agreed that “synthetic” confused consumers. What remained was to finish the job.
A central piece of evidence for the 2018 revision was supplied by the International Grown Diamond Association (IGDA), which had been established in 2016. According to reporting by JCK, IGDA’s original board was made up of people associated with IIa Technologies, a diamond grower.
IGDA submitted to the FTC a 2016 survey conducted by Opinions Ltd. Among its claims were the following :
- 77 percent of respondents understood “lab-grown diamonds” to mean stones created in above-ground facilities.
- 72 percent understood “cultured diamonds” in the same way.
- 56 percent thought a “synthetic diamond” was “an imitation or fake that looks like a mined diamond.”
- The words respondents most often used to describe a “synthetic diamond” were “fake,” “man-made,” “cubic zirconia,” “cheap” and “artificial.”
The survey was filed as evidence for IGDA’s own comments. It had never been independently published, and the record does not disclose who designed its questionnaire. What it does is repeat the claims of the 1996 synthetic producers and sellers, this time with numbers attached.
The Opinions Ltd. survey was the only evidence the FTC cited when it dropped “synthetic” from its examples of recommended qualifiers for diamonds.
The 1996 edition of the FTC Guides did not remove “synthetic.” It kept the term alongside the new descriptors, and the FTC reiterated that sellers could use it.
Questions about the survey’s methodology
The FTC’s own description of the Opinions Ltd. survey’s methodology raises questions about its validity. This is because the polling organization did not test the terms “synthetic,” “laboratory-grown” and “cultured” in the same way.
Respondents in the survey, when considering the descriptors “laboratory-grown” and “cultured,” were shown nearly identical advertisements containing images of diamond rings and favorable explanatory language, describing them as “high-quality beautiful diamonds” grown under carefully controlled conditions. But the 56 percent who were reported as associating “synthetic diamond” with an imitation or fake were responding to a different question, without an equivalent synthetic-diamond advertisement or explanation.
The survey therefore recorded reactions to differently framed stimuli. It did not establish that “synthetic” was inherently more confusing than the alternative terms. A fairer comparison would have tested “synthetic diamond,” “laboratory-grown diamond,” “cultured diamond” and a mined-diamond control in otherwise identical advertisements, either with no explanation for any term or with precisely the same neutral explanation for all.
And even then, according to IGDA’s own data, one of the words respondents most often associated with “synthetic diamond” was “man-made,” which is exactly what it means.
IGDA also cited research conducted by Frost & Sullivan in 2014, which reportedly showed that 74 percent of respondents still thought a “synthetic diamond” was fake or artificial even after being “educated.” JCK reported that Frost & Sullivan was a business strategy consultant that apparently had helped establish IGDA when it produced its research on lab-grown diamonds.
How ‘cultured’ came to trump ‘synthetic’
When the FTC published its draft revisions in January 2016, it proposed allowing “cultured” for diamonds if qualified by terms including “synthetic.” JVC, the Diamond Producers Association (the forerunner of the Natural Diamond Council) and others objected to that draft, arguing that it conflicted with the pearl guidance, which advises against using “synthetic” for cultured pearls.
In JVC’s and DPA’s opinion, this conflict was sufficient to disallow use of the descriptor “cultured” completely. But the FTC did not accept that line of reasoning. It ordered that “cultured” could be used as a descriptor for diamonds, provided it is qualified to show the stone is not mined.
But at the same time, the FTC took “synthetic” off its list of recommended qualifiers, saying many consumers wrongly believe “synthetic” means an imitation such as cubic zirconia.
And, whether by design or drafting error, the term “synthetic” disappeared from the recommended qualifiers for colored stones as well, with no evidence and no explanation.
It was a move that seemed to have gone beyond the FTC’s own reasoning. The organization had earlier stated on two occasions that, because there was no evidence on how consumers understand qualifiers for other laboratory-created gemstones, “synthetic” would remain among the recommended qualifiers for rubies, sapphires, emeralds and other stones. Yet the published text of §23.25(b) listed only “laboratory-grown,” “laboratory-created” and “[manufacturer name]-created” as recommended descriptors for all man-made stones.
While the diamond growers did not get everything they wanted — the FTC refused to allow use of the word “cultured” without qualification — most things went their way. The word “synthetic” left the recommended list, and the term “natural” was dropped as the necessary definition of a diamond without qualification. Marketers essentially were given the freedom to use any qualifier that conveys the stone is not mined.
The irony is that “laboratory-grown,” the term the FTC now recommends, describes what is in reality an industrial manufacturing process. During the FTC hearings, only Diamond Foundry, among all the growers, was candid enough to describe its process accurately. It said that its products are “made in a foundry, not a laboratory.”
The organization that submitted the evidence for the 2018 review no longer exists. IGDA was dissolved in July 2025, citing financial and operational constraints. Its website no longer operates.
Changing times and linguistic constraints
What the entire process has indicated is the evolutionary nature of language usage. Indeed, the consumers who supposedly mistook “synthetic” for fake may well be the same consumers who now mistake “laboratory-grown” for natural. That question has never been tested.
But let’s be clear: “synthetic” is not a dirty word. It is simply an accurate description of a diamond that has essentially the same chemical composition, crystal structure and properties as a natural diamond, but is made by man rather than by nature. Even in 1996, the FTC itself recognized that the word has a long-established technical meaning in gemology.
And use of the word is not confined to jewelry. Synthetic diamonds play an important part in industry and new technology, and in those fields the term is widely used to describe the material.
Natural and synthetic diamonds are two different products. Consumers need a clear and accurate name for each, not terminology chosen for marketing advantage.
The Jewelry Guides are currently scheduled for review in 2028, although the FTC reserves the right to alter its review timetable.
In natural-diamond-industry circles and elsewhere, a degree of consensus is apparently developing about the type of change that people believe should take place.
The World Federation of Diamond Bourses (WFDB) has agreed on a Best Practice regarding “Synthetic Diamonds.” For its part, the World Jewellery Confederation (CIBJO) has now ruled that “synthetic” will be the sole descriptor in its Blue Books, and this should strengthen the case for a review of ISO standard 18323, the International Organization for Standardization’s protocol for describing natural diamonds, synthetic diamonds and diamond simulants.
National and regional bodies are also making their opinions felt. The African Diamond Producers Association has called for “synthetic” to become the exclusive international descriptor, and Botswana has likewise pressed for a clear terminological distinction between natural diamonds and manufactured alternatives. France and Russia have legislated that only the term “synthetic” be used to describe a man-made product.
Belgium has taken a different approach: It requires sellers to provide consumers with written confirmation of whether a diamond is natural or synthetic, although “laboratory-grown” and “laboratory-created” remain permitted trade descriptions.
This will not necessarily sway the FTC’s position. In 2018, it declined to align generally with international standards on the grounds that they reflect industry consensus rather than consumer protection law.
Indeed, alignment alone will not change the FTC’s position. But what could is properly designed, independently conducted and published consumer research testing “synthetic diamond” and “laboratory-grown diamond” side by side against a natural-diamond control. Each term should be presented using identical images, information and neutral explanations, with the order randomized. The complete questionnaire, methodology and underlying data should be published.
The FTC says it revises existing guidance only when there is a “firm record supporting revision.” Such research would provide a far stronger and more transparent evidentiary basis than the material cited in either 1996 or 2018.
If consumer protection is genuinely the test, consumers should at last be asked the right question.
NOTES
- FTC, Guides for the Metallic Watch Band Industry and Guides for the Jewelry Industry, Final Guides, 61 FR 27178 (May 30, 1996). Commenter breakdown at 27178 (footnote 4). Discussion of “synthetic,” “cultured” and “created” at 27207-27208, footnotes 318-327. Final text of §23.23 at 27217-27218.
- FTC, Guides for the Jewelry, Precious Metals, and Pewter Industries, Final Guides, 83 FR 40665 (Aug. 16, 2018), §§23.12 and 23.25.
- FTC, Statement of Basis and Purpose: Final Revisions to the Jewelry Guides (July 2018). Page numbers are the printed page numbers. International standards at pp. 5 and 91. IGDA’s Opinions Ltd. survey at pp. 82-83 (footnotes 316, 322 and 323) and p. 88. Frost & Sullivan research at p. 83 (footnote 324). Diamond Foundry statement at pp. 82-83 (footnote 318, citing Diamond Foundry comment 74 at 3). 2016 proposal on “cultured” at p. 80. Pearl guidance objection at p. 87 (footnote 339). Removal of “synthetic” at pp. 91-92 (footnote 352). Other laboratory-created gemstones at p. 93 (footnote 356) and pp. 94-95 (Section J).
- JCK, “The International Grown Diamond Association Is Sprouting Again” (December 2021).
- JNA (JewelleryNet), “Lab-grown diamond org shuts down” (July 2025).
- National Jeweler, “8 Key Changes the FTC Made to the Jewelry Guides: A Refresher” (updated Sept. 9, 2026).