Ad description
A press ad, an Instagram ad and a website for Skydiamond:
a. In the double page press ad, seen in February 2023, the left-hand page featured a photo of a large diamond in a blue sky. Beneath the sky at the foot of the page was a landscape of trees and a single wind turbine. It featured the headline “Say hello to the world’s first and only diamond made entirely from the sky”. Smaller text underneath stated “We make diamonds using four natural ingredients, the sun, the wind, rain and something we have too much of, atmospheric carbon. In doing so, our technology turns a negative into a positive. Now that we can mine the sky, we never need to mine the earth again.”
The right-hand page featured a photo of three diamond necklaces and three diamond rings on a white background with the headline “SKYDIAMOND Beauty. Reinvented”. Text at the foot of the page stated “Shop the exclusive fine jewellery collection of hand-made engagement rings, pendants and stud earrings, made with the world’s rarest diamonds. skydiamond.com”.
b. The Instagram ad, posted from the @skymineddiamond account on 28 January 2023 featured a carousel of three photos. The first showed the side of a model’s face with a large diamond earring in her ear and the text “Love is … a diamond gift made from the sky”. Text in the accompanying post read “skymineddiamond Cupid Approved – A Skydiamond Valentine’s Day guide […] #skygrowndiamonds #ethicaldiamonds #diamondsmadefromthesky”. The second photo in the carousel featured a model’s neck with three pendant necklaces on it and the text, “Love is… a pendant made from the sky.” The third photo featured the side of a model’s face with a small diamond earring in her ear and the text “Love is…a pair of earrings made from the sky”.
c. The homepage of The Sky Mining Company’s website, www.skydiamond.com, seen in February 2023, included the headline “Create your engagement ring with diamonds made from the sky”. Clicking on a box which stated “Start with a Skydiamond” took users to a page titled “Select your Skydiamond” with photos of different shapes and carat sizes of Skydiamonds to choose from. Clicking on one of these options took website users to the details for a “0.46 Carat Round Skydiamond”. Alongside the photo of the diamond, details were given on Carat, cut, clarity, certificate and the “date of diamond creation”.
A “Frequently Asked Questions” (FAQs) page included the question “Are Skydiamonds real diamonds?”. The text then stated “Each Skydiamond is a perfectly formed real diamond”.
Issue
The Natural Diamond Council, who understood the products were laboratory-created diamonds, challenged whether the claims “Skydiamonds”, “diamonds”, “real diamonds” and “diamonds made entirely from the sky” in the ads were misleading.
Response
The Sky Mining Company t/a Skydiamond believed that the ads made clear that their diamonds were not mined from the earth and as such were not naturally occurring diamonds, referred to as natural diamonds. The ads, coupled with the very extensive information and graphics on their website, set out unequivocally that their diamonds were manufactured and included detailed information on the unique and multifaceted production process. They did not believe that the absence of the single word qualifiers “synthetic” or “laboratory-grown” or “laboratory-created” would inevitably lead an average consumer to being misled about their diamonds. On the contrary, they believed that the extent of the qualifying information, graphics and visuals made readily available could in fact only lead an average consumer to conclude that their diamonds were not earth-mined, as they intended. Their brand was built on the premise that their diamonds did not come from the earth and do not have the negative environmental impacts associated with diamond mining.
The components required for the manufacture of Skydiamonds were all sourced from the sky. These were atmospheric carbon dioxide (as a source of carbon), rainwater (as a source of hydrogen) and renewable energy from solar and wind power. The carbon dioxide and hydrogen were extracted and produced using proven industrial processes and are then combined to form methane in a biological process. The resulting methane was fed into chemical vapour deposition (CVD) machines in which diamonds developed at a high temperature over a period of 14 days. A time-lapse video showing the manufacture of a diamond over this 14-day period was available on the process description pages of the website. The rough diamonds produced by the process were chemically and physically identical to mined rough diamonds. As in the case of mined diamonds, Skydiamonds were sent away for further processing, cutting, polishing and certification. The innovative end-to-end production process was patented and therefore, by definition, it was novel and unique. Of the 23 process steps set out in the patent, only one was shared with conventional lab-grown diamond production processes, namely the CVD step. This would therefore make the qualifier “laboratory-grown” or “laboratory-created” potentially misleading. A more appropriate, precise and complete description would be in the form of the extensive and prominent qualifying information and graphics provided by them, in particular on their website. They said that if single word qualifiers were to be used, which they considered to be less optimal than the information provided, then “made” or “manufactured” were the clearest and least ambiguous. The names “Skydiamond” and “Sky Mining” were trademarked therefore confirming by definition the distinctiveness as well as the descriptiveness of the brand.
They went to extraordinary lengths to differentiate themselves from mined diamonds given that the entire purpose of the business was to provide a sustainable manufactured alternative to earth-mined diamonds. The branding was deliberately chosen to convey this and the extensive qualifying information provided by them was intended to inform the consumer about the distinction and the benefits, juxtaposing the ravaging of the earth with the purity (and purification) of the sky. They rarely referred to Skydiamonds as just diamonds and if they did it was almost always with the adjunct “made from the sky” or similar. It was impossible for the average consumer to conclude from the use of the words “skydiamond”, “diamonds from the sky”, “diamonds made from the sky”, “diamonds mined from the sky” and “we make our diamonds …” that their diamonds were anything other than manufactured or non-mined both in isolation but also in the context of the extensive qualifying information and graphics provided.
With respect to the National Association of Jewellers’ “Diamond Terminology Guideline” (the Guideline), which was introduced in 2020, they made a number of observations. Firstly, the Guideline was not applicable to the ASA investigation and they believed it was inappropriate to place reliance on it. Even if it were applicable, it was only a guide or tool that provided a non-exhaustive suggestion of single word terminology that could be used to distinguish manufactured diamonds from mined diamonds. It should not be, and did not profess to be, the only basis for defining the origin of a diamond or for determining definitively whether diamond ads were misleading to an average consumer. They referred to the dictionary definition of a diamond which did not indicate that the word diamond used in isolation could only ever mean a “natural” or “naturally occurring” mined diamond. A synthetic diamond was every bit as “real” as a natural diamond, which they believed the Guideline acknowledged. A “diamond” was the name of an object which in and of itself did not describe or denote its origin (as being mined or manufactured). They referred to a ruling by the US Federal Trade Commission in 2018 which agreed with that position, namely that “a diamond is a diamond” regardless of whether it was mined or made. They believed the Guideline, which was authored by the natural, mined diamond industry, only represented the views of that industry, which sought to maintain control of the use of the word ‘diamond’ solely for their own products. Furthermore, because the commercialisation of their manufacturing process post-dated the introduction of the Guideline in 2020, such novel and innovative industrial processes were not contemplated by the Guideline. Had they been, then the Guideline itself might have recognised the inappropriateness of the use of the term “laboratory” in connection with such processes and might have found additional single word qualifiers such as “manufactured”, “made” or “man-made” to be acceptable. They referred to consumer research which they believed supported their position that an average consumer would not be misled by the terminology used in their ads and in the extensive qualifying information and graphics they provide. Some of the research relied on was in the public domain whilst some was specifically commissioned by Sky Mining.
Firstly, they referred to independent publicly available market analysis conducted by The MVEye, a leading specialist research organisation in the gem, jewellery and watch industry and provided a presentation setting out the research findings. The research evidenced global market awareness of manufactured diamonds as being at 81% in 2023, up from 80% in 2020. Secondly, Sky Mining had previously separately commissioned The MV Eye to conduct a random survey of 1,508 consumers in the UK and USA, and they provided a further presentation setting out those findings. In the UK, 501 consumers with a household income greater than £60,000 were surveyed. The MV Eye asked the question: “SkyDiamond takes carbon from the sky and turns it into diamonds and have a negative carbon footprint … Is that enough of a differentiator for its diamonds to be in a separate product category from other diamonds in a retail store?”; 79% answered “yes” and 21% “no”. They said this showed consumers in both the UK and US specifically considered Skydiamonds to be in a separate product category to natural, mined diamonds.
Thirdly, Sky Mining provided an independent YouGov poll that took place in September 2023, which they had commissioned in response to the ASA investigation. A representative sample of 2,104 UK adults was taken by YouGov from their panel. In response to the question: “Before taking this survey, were you aware that man-made diamonds exist?”, 76% responded “Yes I was” and 24% responded “No I wasn’t”. In response to the following question posed to the 1,600 respondents who were aware of man-made diamonds: “Before taking this survey, were you aware that man-made diamonds are used in jewellery as well as land-mined diamonds?”, 93% responded “Yes I was” and 7% responded “No I wasn’t”. All respondents were asked the question: “Man-made and land-mined diamonds are the same optically, chemically, and structurally and therefore have the same appearance and properties which cannot be differentiated. Having read the above information, to what extent, do you agree or disagree that it is accurate for both land mined and man-made diamonds to be called diamonds?”, 57% agreed, 19% disagreed and 23% answered “Don’t know”. They were then asked: “Still thinking about the information you read on the previous question ... To what extent if at all do you agree it is accurate referring to both land mined and man-made diamonds as 'real diamonds'?”, 46% agreed, 32% disagreed and 22% answered “Don’t know”.
Respondents were also asked questions specific to Skydiamonds. When asked the question: “Thinking about the brand name 'Skydiamond', which ONE of the following types of diamonds do you think they sell? (Please select the option that best applies)”; 55% responded “Man-made diamonds”, 6% responded “Land-mined diamonds” and 39% responded “Don’t know”. When presented with an image of ad (a) and asked: “Thinking about the image you just saw and read ... From this, do you think consumers would understand that Skydiamond's diamonds were produced or sourced in a different way from those that were mined from the earth?”; 72% answered “Yes they will”, 15% “No they won’t” and 13% “Don’t know”.
Fourthly, they had also conducted a poll of their Instagram followers commencing on 12 September 2023 and they provided screenshots from Instagram of the poll results. In response to the question: “Do you think we make or mine diamonds?”, 91% replied “Make”, and 9% replied “Mine”. In response to the question: “Is saying ‘made from the sky’ clear we are man-made?”, 58% replied “Yes”, and 42% replied “No”. In response to the question: “‘Made in the Cotswolds’ is it clear we are manmade?”, 57% replied “Yes”, and 43% replied “No”.
Finally, they provided a letter from a jewellery expert with over 30 years of design and resale experience in the industry. This expert, who himself incorporated Skydiamonds in his jewellery, stated that Sky Mining’s products were very clearly and deliberately differentiated from natural, mined diamonds and that his customers were deliberately buying them on the basis of an informed choice, namely precisely because they were manufactured sustainably and not mined from the earth.
Sky Mining say that if it was accepted that consumers would understand from their ads that Skydiamonds were produced or sourced in a different way from those minded from the earth then it must therefore be the case that they would understand that Skydiamonds were manufactured. This was because there were only two categories of diamond which existed: land-mined diamonds and manufactured diamonds. There were no further categories of diamonds and specifically no type of natural diamond that originated from or in the sky. They said the evidence they provided helped to inform and identify what the understanding of an average consumer might be, and that statistical evidence should therefore be considered. It was not the understanding of consumers as a whole, or indeed of a specific uninformed group of consumers, that needed to be assessed, but the understanding of an average reasonably well-informed, observant and circumspect consumer. They said the statistical evidence showed that around 80% of all consumers were aware of manufactured diamonds as distinct from earth-mined diamonds. As such, it was far more likely than not that any consumer would be aware of the distinction, and almost certain that an average reasonably well-informed, observant and circumspect consumer would be.
They said that it was an obvious stretch to conclude that because Skydiamonds are manufactured today from ingredients coming from the sky, that they would be confused with natural diamonds which came from the earth and were produced millions of years ago. Expressions like “mined from the sky” and “the world’s rarest” were obvious exaggerations or puffery, especially in the context of the ads and/or the qualifying information. They would not be taken literally by an average consumer and did not materially mislead. Mining was clearly associated with extraction from the earth and indeed this was the environmental impact which Sky Mining sought to avoid. As to rarity, Sky Mining’s process was globally patented and as such could not be copied by other producers of manufactured diamonds. Sky Mining’s annual production output represented around 0.001% of the annual production of diamond mines worldwide.
With regards to ad (a), they highlighted parts of the ad which they believed made unambiguously clear that they manufactured diamonds using constituents from the sky, and therefore made explicitly clear that they did not mine the earth. The ad referred to the product being the “world’s first and only diamond made entirely from the sky” and stated “We make diamonds using four … ingredients, the sun, wind, rain and … atmospheric carbon. In doing so, our technology turns a negative into a positive”, “Now that we can mine the sky, we never need to mine the earth again” and “SKYDIAMOND”. They also referred to the results of the YouGov poll where 72% of people presented with an image of ad (a) agreed that consumers would understand that Skydiamond's diamonds were produced or sourced in a different way from those that were mined from the earth.
With regard to ad (b), they said their Instagram profile “skymineddiamond” included clear statements including, “The world’s first and only diamond made entirely from the sky. Skydiamond.com” and “Diamonds made from the sky to protect the earth”. The ad and Instagram profile linked directly to the Skydiamond website, which contained extensive information about their process and how they were different from natural, mined diamonds. Ad (b) itself contained repeated references and captions to the products depicted in the images being “made from the sky” and repeatedly used the hashtags “skygrowndiamonds”, “ethicaldiamonds”, “diamondsmadefromthesky” and “sustainablediamond”. Because ad (b) was constrained by space, they made the more detailed qualifying information available via their Instagram profile, hashtags and website given that the post itself could not contain the full process description, graphics and FAQs. They therefore believed that ad (b) made unambiguously clear that they manufactured sustainable diamonds using constituents from the sky, and made it explicitly clear that they did not mine the earth. Therefore, the average reasonably well-informed, observant and circumspect consumer would conclude from the ad that Sky Mining’s diamonds were not natural mined diamonds.
With regard to ad (c), which comprised limited parts of the Sky Mining website, they said that only selected sections of the website were the subject of the complaint rather than the website as a whole and so the selected pages were therefore taken out of context, although extensive qualifying information was also provided on a number of the pages which were the subject of the complaint. The homepage prominently and repeatedly used the term “… made from the sky” as well as prominently (in distinct boxes) using the terms “Mined entirely from the sky”, “Made in the Cotswolds, England” and “-CO2. World’s only carbon negative diamond”. There was also a graphic of an industrial plant below which was the caption “Diamonds in the sky – How our diamonds are born” which linked to a page which set out “The process: From carbon dioxide to a perfectly pure loose diamond” and gave further prominent and clear information about the process involved in producing Skydiamonds in extensive detail, both in text form and graphically. The process description contained boxes identifying the four ingredients taken from the sky, namely: carbon dioxide, rainwater, solar energy and wind energy, and contained a description of how these were converted into diamonds step by step during the manufacturing process. There was a video graphic with a vivid time-lapse video of one of the steps showing how a diamond was created in a CVD machine. There were also further links on the homepage to the process description pages from the tiles “CO2. World’s only carbon negative diamond” and “Made in the Cotswolds, England”. Furthermore there were links and tabs on the homepage to “About us” and to “FAQs”. The “About us” tab on the homepage contained dropdown links directly to “Our mission” and “Our process”, and those pages each contained further extensive information about the production of Skydiamonds. The FAQs prominently and repeatedly described how Skydiamonds were different from other diamonds, earth-mined diamonds and natural diamonds. The very first FAQ question addressed this difference and stated, “We make the world’s only diamonds made entirely from the sky. We do this by taking atmospheric carbon from the sky and turning it into a Skydiamond. We use only 100% renewable energy, captured rainwater and CO2 to grow our Skydiamonds. Our production process took several years to perfect and we are extremely proud to be the world’s only diamond producer that is carbon negative through design and not offsetting.”
They said that the homepage and “About us” page contained and linked extensively to content about the manufacturing process and that, especially in light of the consumer research, it would be sufficient to use language such as “made from the sky” or even just “Skydiamond” to achieve the necessary distinction between their diamonds and natural diamonds, in the eyes of the average consumer. However, they went much further than that in terms of the extensive content on their website, which included visual media. They believed that it was unambiguously clear to an average consumer from their website that they manufactured diamonds using a technological process that took all of the process constituents, including atmospheric carbon, from the sky. In doing so they clearly and explicitly did not mine the earth and did not sell natural, earth-mined diamonds. They made clear that it was the only diamond made this way and therefore, by definition, it could not be a natural, earth-mined diamond. They went to great lengths to distinguish themselves from the mined diamond industry and also, to some extent, from lab-grown diamond manufacturers. An average consumer would not conclude from their website that their diamonds were natural, mined diamonds.
Regarding the claim “real diamond” on their FAQ page, this was not a claim which they led with in their marketing. It was an answer in response to a specific question namely whether Skydiamonds were actually diamonds. The answer was given in the context of all of the other FAQs which made the distinction between Skydiamonds and natural, earth-mined diamonds clear, and should not be taken in isolation. It was true that a Skydiamond was a diamond, chemically, structurally and optically. It had exactly the same composition and physical properties of a natural diamond.
Assessment
Upheld
The CAP Code stated that marketing communications must not mislead the consumer by omitting material information. They must not mislead by hiding material information or presenting it in an unclear, unintelligible, ambiguous or untimely manner.
The ads all included images of clear gemstones and references to diamonds. The ASA considered that consumers would understand the word “diamond” in isolation to mean a mineral consisting of crystallised carbon that was naturally occurring. We considered that while some consumers may have been aware that synthetic diamonds could be manufactured or created in a laboratory, many would not. The YouGov survey referenced by Skydiamond showed that around a quarter of the people surveyed, who were a representative sample of UK adults, were unaware that synthetic diamonds existed, which was a significant proportion. We understood that although synthetic diamonds had the same chemical and physical properties as mined diamonds, there were differences in their future value. We also considered that, whether a gemstone was natural or synthetic would be a key consideration for many consumers and was therefore material information. We therefore considered that ads for synthetic diamonds needed to make clear the nature of the product in order to avoid misleading consumers. We understood that Skydiamond’s production process, which involved using carbon captured from the atmosphere, was different from other synthetic diamonds. Nonetheless, because their diamonds were synthetic, we considered that this was material information consumers needed before making a transactional decision.
The National Association of Jewellers’ “Diamond Terminology Guideline” (the Guideline), which had the status of ‘Assured Advice’ from Trading Standards, stated that when referring to synthetic diamonds, a qualification such as “synthetic”, “laboratory-grown” or “laboratory-created” should be used. The Guideline had been updated in 2023 with no major changes to the 2020 version. We took note of that advice, although it was not binding on the ASA. We assessed how we considered the average consumer (who was reasonably well-informed and reasonably observant and circumspect) was likely to respond to each ad individually.
We acknowledged the various pieces of consumer research provided by Skydiamond. We did not consider that they provided strong evidence of how the average consumer would interpret the individual ads under investigation. Nonetheless, they did provide some relevant insights into consumer awareness and understanding more generally.
As above, the YouGov survey indicated that a significant minority (around a quarter) of UK consumers were unaware of synthetic diamonds. The MV Eye market analysis reported a higher level of awareness globally. Although the UK respondents in that survey were not representative of the general UK population because they all had a household income of greater than £60,000, it was nonetheless the case that 25% of them had not heard of “diamonds grown in a lab”. The report also noted that awareness in Wales was the lowest at 54%.Respondents in the YouGov survey were also asked various questions specific to Skydiamonds. When asked about the brand name ‘Skydiamonds’, a high proportion answered that they didn’t know (39%) whether they sold “man-made diamonds” or thought they did not (6%). They were also asked for their view on the press ad (a). However, the question asked was “Do you think consumers would understand that Skydiamond's diamonds were produced or sourced in a different way from those that were mined from the earth?” We did not consider the question wording meant that those answering “yes” definitively understood that the diamonds were synthetic. Notwithstanding that, nearly 30% answered “No they won’t” or “Don’t know”, which was a significant minority.
Regarding the poll of their Instagram users, we considered that people who followed the account and chose to engage with a poll were likely to have a greater existing awareness of the brand and were therefore unlikely to be representative of the average consumer viewing the ads. However, even from those in that more informed group who responded, 42% did not believe that the claim “Made from the Sky” made clear they were “man-made”.
None of the ads included an explicit qualification that Skydiamonds were “synthetic”, “laboratory-created” or similar. We therefore considered whether it was clear from the other content of the ads that Skydiamond diamonds were synthetic.
Ad (a) stated “Say hello to the world’s first and only diamond made entirely from the sky. We make diamonds using four natural ingredients, the sun, the wind, rain and … atmospheric carbon. In doing so, our technology turns a negative into a positive. Now that we can mine the sky, we never need to mine the earth again”, “made with the world’s rarest diamonds” and the company name “SKYDIAMOND”. We considered that consumers would understand from the ad that Skydiamond’s diamonds were produced or sourced in a different way from those that were mined from the earth, because the ad stated prominently that they were “made entirely from the sky”, referred to not needing to “mine the earth again” and mentioned “our technology”. However, the ad also placed significant emphasis on the natural provenance of the diamonds, by the prominent reference to being “made entirely from the sky”, the list of “four natural ingredients” and the statement “we can mine the sky”, as well as featuring a large image of a blue sky. It also referred to “the world’s rarest diamonds”. We considered that rarity in this context would be most associated by consumers with a finite natural occurring resource which could not be produced by humans, rather than something which was manufactured. Whilst some consumers who saw the ad would understand that, while the “ingredients” they used were natural, the diamonds themselves would have had to have been manufactured, a significant minority (particularly those who were unaware of synthetic diamonds) would not. Therefore, particularly because the ad referred to their diamonds being “mined”, emphasised their “natural” ingredients and referred to them as “the world’s rarest”, it was ambiguous as to whether the diamonds were naturally occurring or synthetic. We concluded that ad (a) omitted material information and was likely to mislead at least a significant minority of consumers, particularly those who were unaware of synthetic diamonds.
Ad (b) stated “Love is… a diamond gift made from the sky” and referred to “Skydiamond”, “skygrowndiamonds” and “diamondsmadefromthesky” in its caption. The ad was a post on their own Instagram account. Whilst some of Skydiamond’s Instagram followers were likely to be aware that their diamonds were synthetic, not all would be. In addition, the post was also visible to non-followers visiting the page who would be less familiar with the company. We acknowledged that where an ad was constrained by time or space, the measures the marketer took to make that information available to the consumer by other means were relevant when considering whether it was misleading. However, we did not consider that ad (b) was constrained by space in the way that Skydiamond described. Whilst some consumers would understand from the ad that Skydiamond’s diamonds were produced or sourced in a different way from those that were mined from the earth, it was ambiguous as to whether they were synthetic. We concluded that ad (b) omitted material information and was likely to mislead at least a significant minority of consumers, particularly those who were unaware of synthetic diamonds.
The homepage of their website, ad (c), included a large, prominent reference at the top of the page to “diamonds made from the sky” and “Skydiamond”. Much further down the page, text included “Mined entirely from the sky” and “Made in the Cotswolds, England”. Links listed under “Skylights” included “Diamonds in the sky – How our diamonds are born” and featured in image of what appeared to be a factory. As referenced above, we considered that some consumers would understand the claims to mean that Skydiamond’s diamonds were produced or sourced in a different way from those that were mined from the earth, particularly those who scrolled further down the page. Some would also understand that the diamonds themselves would therefore have to be manufactured by an industrial process; however, many consumers would not. Therefore, and particularly because the ad referred to their diamonds being “mined” and the focus placed on the provenance of the diamonds as from the “sky”, it was ambiguous as to whether the diamonds were naturally occurring or synthetic and those claims were therefore misleading.
We acknowledged that further information on the Sky Mining manufacturing process appeared on the “FAQs” and “About us” pages, as well as other pages on the website. However, in the absence of a clearly worded and prominent qualification such as “synthetic”, “laboratory-created” or “laboratory-grown”, or another way of clearly and prominently communicating the same meaning, we considered it was still ambiguous as to whether the diamonds were synthetic or not. Furthermore, consumers could go through the entire process of buying a Skydiamond, from homepage to completion of the purchase, without any explicit mention that the diamond was synthetic. We therefore concluded that ad (c) omitted material information and was likely to mislead at least a significant minority of consumers, particularly those who were unaware of synthetic diamonds.
In addition, the FAQ page included the question “Are Skydiamonds real diamonds?” and stated “Each Skydiamond is a perfectly formed real diamond”. We considered that it was misleading to describe a synthetic diamond as a “real diamond” and that ad (c) was also misleading on that basis.
Because the ads did not make clear that Skydiamond diamonds were synthetic we concluded that the claims “diamonds”, “diamonds made entirely from the sky” and “Skydiamond” were misleading.
The ad breached CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising), and 3.9 (Qualification).
Action
The ads must not appear again in the form complained about. We told The Sky Mining Company Ltd t/a Skydiamond not to misleadingly use the terms “diamonds”, “diamonds made entirely from the sky” and “Skydiamond” to describe their synthetic diamonds in isolation without a clear and prominent qualifier, such as “synthetic”, “laboratory-grown” or “laboratory-created”, or another way of clearly and prominently conveying the same meaning to consumers . We also told them not to use the claim “real diamonds” to describe synthetic diamonds.
