Do I need to give a client a treatment and origin disclosure on a custom diamond commission?

Yes. If the stone you set has been treated, or it was grown in a lab rather than pulled out of the ground, that fact has to be disclosed to your client clearly and in plain language before she buys. Origin is not optional courtesy in the United States. It is the baseline expectation of the Federal Trade Commission's Guides for the Jewelry, Precious Metals, and Pewter Industries, and it applies to a one person studio taking four commissions a month exactly as it applies to a chain with three hundred doors.

The narrower question is where that disclosure has to live. The answer most working designers arrive at is: in both places. Put it on the quote, because that is the document she reads while deciding, and put it on the invoice, because that is the document that survives. A disclosure buried in a text message you sent in March is not a record you want to reconstruct in November when she brings the ring back for sizing and asks what the center stone actually is.

What follows is what the Guides ask of a small maker, what belongs in the words themselves, and how to keep supplier paper you can actually produce two years later.

What the FTC Jewelry Guides actually require of a small maker

The Jewelry Guides are administrative interpretations, published at 16 CFR Part 23. They are not a separate statute with their own penalties. They describe what the FTC considers deceptive under Section 5 of the FTC Act, which is the enforcement hook. In practice that distinction matters less than designers hope. If your description of a stone would mislead a reasonable buyer, the Guides are the map the agency uses to say so.

Three principles carry most of the weight for a commission studio.

• Disclose before the sale. A qualification that appears only after payment does not cure a misleading description made before it.
• Make it conspicuous. The Guides repeatedly use the phrase "equally conspicuous" and "immediately preceding." A qualifier in eight point gray type under a headline in bold does not satisfy that.
• Do not imply what you cannot support. Origin, treatment, karat and plating claims all have to be true of the specific piece you are delivering, not true of your line generally.

The 2018 revision to the Guides removed the word "natural" from the definition of a diamond. That single edit is the reason so much of the current disclosure conversation exists. A lab grown stone is a diamond. It is simply a diamond that has to be described as lab grown.

Keep reading: How did one designer rebuild her remount business around a fifty percent deposit policy?

Lab grown versus mined: the disclosure language that is required

The qualifier has to sit right next to the word "diamond," in equal prominence, so the buyer cannot read the noun without the modifier. The Guides identify wording the FTC treats as adequate.

Use	Do not use alone	Why
Laboratory grown	Diamond	Unqualified, implies mined origin
Laboratory created	Cultured	Only acceptable with a clear qualifier attached
[Producer name] created	Real, genuine, natural	The Guides warn against terms implying a mined stone
Simulant, or the material name, for moissanite or CZ	Diamond simulant described as a diamond	A simulant is not a diamond at all

Two traps catch small studios. The first is abbreviation. "LG diamond" on a quote line is not conspicuous to a client who has never seen the abbreviation. Spell it out. The second is the melee. If your center stone is mined and your accent stones are lab grown, or the reverse, say so per component. A single sentence covering the whole ring is not accurate when the ring has two origins in it.

Treatment disclosure for sapphires, emeralds and rubies

The Guides call for disclosure of a treatment when any of three conditions is true: the treatment is not permanent, the treatment creates special care requirements, or the treatment has a significant effect on the stone's value. Colored stone work in a commission studio hits all three regularly.

The common cases

• Emerald. Nearly all commercial emerald is fissure filled with oil or resin. It is not permanent and it dictates care: no ultrasonic, no steam, no solvent. That is textbook disclosable.
• Ruby and sapphire. Standard heat treatment is stable and permanent, but the Guides' value prong still makes disclosure the safe practice, and unheated stones are worth stating for the opposite reason. Lead glass filled ruby is a different animal entirely: fragile, damaged by pickle and by a jeweler's torch, and always disclosable.
• Beryllium diffusion. Color introduced into the stone. Disclose, and note that recutting can alter the color.
• Pearls. Dyed, bleached and irradiated pearls need saying, as does cultured versus natural.

There is a practical benefit here beyond compliance. When you write "resin filled, do not clean in an ultrasonic" on the invoice, you have also protected yourself against the repair bill you would otherwise eat when she takes it to a mall kiosk for a free cleaning.

Keep reading: Is the shift toward lab grown center stones changing what I should quote for bench labor?

The warranty statement that belongs on every diamond invoice

Federal warranty law, the Magnuson-Moss Warranty Act, does not force you to offer a warranty. What it does is govern the form of one if you offer it in writing on a consumer product. Any written warranty on a product costing more than fifteen dollars has to be designated as either Full or Limited, and the terms have to be available to the buyer before she pays, not folded inside the box afterward.

For a bench studio, a limited warranty is nearly always the right instrument. A useful one states plainly:

1. That it is a limited warranty, using that word.
2. What is covered: workmanship, typically setting and solder joints.
3. What is not: loss, impact damage, wear on prongs and shanks, stone chipping, work performed by another shop.
4. Duration, and whether it survives resizing elsewhere.
5. What you will do: repair, replace, or refund, and who pays shipping.

Say the quiet part out loud in the exclusions. "Prong wear from normal use is not a defect in workmanship" is a sentence that ends an argument three years from now, and it is entirely fair to write.

Karat and plating claims you cannot make

Metal marking sits under the National Gold and Silver Marking Act as well as the Guides. If you stamp a quality mark, US law expects your registered trademark to appear alongside it so the mark is traceable to somebody. A karat stamp with no maker's mark is a liability, not a credential.

The tolerances are tighter than most people assume. Gold has a half karat tolerance on an unsoldered article and one karat where solder is used. Sterling means 925 parts per thousand silver, and "coin silver" means 900. If you alloy your own or work with a caster, know which figure your finished piece hits before you stamp it.

Surface claims are defined by thickness, not by feel.

• Gold filled or rolled gold plate: a bonded layer of at least 10 karat gold that is at least one twentieth of the article's total weight.
• Gold electroplate: a minimum of 0.5 microns of at least 10 karat gold.
• Heavy gold electroplate: a minimum of 2.5 microns.
• Vermeil: a sterling silver base with at least 2.5 microns of at least 10 karat gold.

If your plater will not tell you the micron thickness, you cannot honestly use the term. "Gold tone" is the phrase for finishes you cannot document.

See how BeadInvoice handles this for fine and handmade jewelry commissions

Where disclosure belongs: quote, invoice, or both

Both, and for different reasons. The quote is a pre sale document, which is where the Guides' timing requirement is satisfied. The invoice is the record that follows the piece for its life, through appraisals, insurance scheduling and eventual resale.

A workable rule: every stone line on a commission quote carries five facts, in this order.

1. Origin: mined or laboratory grown.
2. Species: diamond, sapphire, spinel, and so on.
3. Weight, stated as an exact carat figure or as a fraction with the tolerance named.
4. Treatment, or the word "none known" where your supplier states none.
5. Report number and lab, when one exists.

If you quote fractional weights, the Guides expect the buyer to know the range. "1/2 ct" that could mean 0.45 needs the tolerance stated. Writing "0.47 ct" is simpler and safer.

Keeping supplier documentation you can produce later

Your disclosure is only as good as the paper behind it. When a client asks in year four whether the accent stones were lab grown, "I believe so" is not an answer that protects you.

Attach to each commission record: the supplier invoice showing origin and treatment language, the grading report PDF where one exists, the memo paperwork for anything you took on consignment, and a photograph of the parcel paper. Name the files with the commission number so retrieval takes ten seconds rather than an afternoon in an email archive.

One more habit worth building. When a supplier's invoice says only "diamond" with no origin qualifier, ask in writing and keep the reply. A supplier's silence is not evidence of mined origin, and you are the one whose name is on the invoice the customer keeps.

Putting it on the paperwork without doing it twice

Disclosure fails in small studios for a boring reason: it lives in your head and gets retyped from scratch every time. The fix is structural. Build stone origin, treatment and report number into the quote line itself, so the same fields carry through to the invoice without a second pass and without a copy paste error at eleven at night.

That is how BeadInvoice is built. Metal weight, stone cost and bench hours are quoted on one document, each stone line carries its origin and treatment fields, your warranty text sits on every invoice by default, and the deposit is collected against that same record before the bench work starts. Set the language once, and every commission you take this year is disclosed the same way.