2. The percentage of the total volume of the fabric trade which is dishonestly conducted is extremely small, and most of the changes in the organization of trade methods which have taken place during the last generation have been of such a character as to make dishonest competitive methods unpopular and unprofitable. The really pertinent point, however, in connection with fraudulent practices is the manifest fact that the imposition of a requirement that fabrics shall be marked to indicate their composition on a basis which has no relation to their quality would have no appreciable effect in reducing such fraud as may exist. It would merely introduce a new chance for the misleading of the public.

3. Fraudulent competition has been successfully attacked only by direct methods aimed at false representations. By an old and generally accepted principle of law the buyer is supposed to have wits and to exercise reasonable prudence in his purchases. But the spirit of the law defends him against deliberate misrepresentation. In Britain the merchandise marks act, which is designed to meet those evils to which fraud in the sale of cloth belongs, has been in force in its present form since 1887. This law, in effect, so far as it bears on false representations, does not require the manufacturer or merchant to make any claim or statement concerning the nature of his merchandise, but if he makes any claim or statement it must be an honest one. and heavy penalties are imposed in case any misleading statement is made. At least one bill based on the British merchandise marks act is now before Congress. Apparently the public feels some need for legislation better to protect it against false representations in the sale of merchandise. This feeling applies to wool fabrics as well as to many other lines. If there is to be legislation it should take the form of a law of this kind, the enforceability of which has been demonstrated and which is based on a sound principle of law. This would be more effective as a protection to the public in the case of wool fabrics than would the establishment of a set of standards based on percentages of component materials when a knowledge of these percentages gives to the consumer no trustworthy idea of the quality of the fabrics. In summary, the fourth point made is that the proposed legislation, so far as it is designed for the protection of the public, is aimed at the dishonest few in the wool industries. Normal conditions protect the public against fraud in all except a small percentage of cases. These dishonest persons should be hunted out and their practices stopped by means which will protect the public against them instead of by a type of legislation whose chief effect will be to handicap honest business while encouraging new types of fraud.

GENERAL SUMMARY.

It has been shown that the proposed bill would put a premium on fabrics of new wool. That is its avowed purpose. It has been shown also that it would put an unfair stigma on reworked wool and fabrics containing that material. This would be desirable either if reworked wool were a bad fiber or if fabrics made from it were necessarily of poorer quality than fabrics of new wool; but they are not, and this also has been proved. It has been shown that the branding as prescribed by the law would have no relation to the value or desired properties of the fabrics, and that instead of such marking making it possible for the consumer to know what he is buying it would merely add to his confusion. It has been shown that normal competition serves as a better check on fraud than the enactment and enforcement of this measure could be. It has been shown that the law would make wool fabrics cost more and that the consumer would receive no adequate compensation for this increase in price. It has been shown that the proposed measure would not correct the evils it aims at, while another measure based on a tested principle of law would. This so-called Truth in Fabric law would be ineffective, costly, and against the public interest. CHARLES H. WILSON,

Chairman,

SAMUEL R. HAINES,

APPENDIX 1.

The census for 1914 gives the following figures covering the quantity of virgin wool consumed in the various branches of the wool manufacture. These figures are for wool in the condition in which it was purchased; that is to say, the figures give the amount in pounds whether the wool was in the grease or scoured.

Pounds of wool in condition purchased, census year 1914.

The figures for the principal fibers used in wool manufacture in 1914 (industries as above listed) given in millions of pounds were as follows:

Products of the woolen-goods and worsted-goods industries, 1914.

1 In addition, woolen and worsted goods to the value of $2,635,889 in 1914 and $3,183,485 in 1909 were made by establishments engaged primarily in the manufacture of other products; of these amounts products valued at $1,500,567 in 1914 and $1,902,187 in 1909 were made by carpet and rug and by felt-goods mills. Can not be shown separately; included in "all other" for the group.

177735-208

Products of the woolen-goods and worsted-goods industries, 1914—Continued.

I Can not be shown separately; included in "all other" for the group.

26, 125, 575
$8,783, 020

86, 412,097
$69, 801, 271

6,473, 849 $1,689, 530

4,048, 514 $3,173, 034

9,499,666 $2,425, 360

8,985, 170

18,723,346
$6,344,824

840,585
$400, 736

6,473,849 $1,689, 530

7,378,486
$820, 535

247,182 $270,093 $228,055

99, 143, 435 $76,616, 590

7,402, 229 $2,438, 196

85,571,512 $69, 400, 535

4,048, 514 $3,173, 034

2, 121, 180 $1,604, 825

8,985, 170 $4,926, 929

$4,500

APPENDIX 3.

NEW MATERIALS USED IN WOOLEN-GOODS AND WORSTED-GOODS INDUSTRIES,

1 Scoured equivalent of woo! purchased (millions of pounds): Total, 257.4; woolen industry, 58.7; worsted industry, 198.7.

REWORKED MATERIALS USED IN WOOLEN-GOODS AND WORSTED-GOODS INDUSTRIES, CENSUS OF 1914.

FIBER MATERIALS OTHER THAN WOOL USED IN THE WOOLEN-GOODS AND WORESTED-GOODS INDUSTRIES, CENSUS OF 1914.

Percentage of reworked wool to total wool fiber retained for consumption in the United

DESCRIPTION OF SAMPLES.

Samples of fiber.

1. This exhibit is a high-grade new wool, scoured and ready for manufacture. A buyer of cloth or fabric who wants goods made of such wool and is willing to pay for them should be sure of getting them, but the proposed bill gives him no such certainty. Market price, $1.95.

la. This sample is a fine scoured Australian wool with a present market value of not less than $2.40 per pound. Obviously this can only be used in expensive fabrics. This sample should be compared with 20 or 22 for price as well as for quality.

2. Shearlings: New wool taken from the skins of sheep slaughtered for mutton, too soon after shearing to permit the fleece to have attained any great length. These fibers make a much less satisfactory yarn or cloth than can be made from many grades of shoddy. Shearlings, however, must be classed as virgin wool. Market price, $0.80. 3. Tag locks: The ends of wool fiber from portions of the fleece thoroughly matted with foreign matter. These are separated from the remainder of the fleece and sold separately at low prices. By special treatment short and inferior wool can be reclaimed from these tag locks, but these wools are of inferior quality and in many respects poorer than many grades of shoddy. They would, however, be classed as virgin wool and would be sold at a premium as compared with stigmatized reworked wool of better quality. Market price, $0.05.

4. Tag locks: Scoured and ready for manufacture. Market price, $0.70.

5. A kempy wool from South Africa: This is an excellent raw material for some purposes, but because of its coarse character it is inferior tɔ many grades of reworked stock as a material for clothing. It is, however, a virgin wool, and under the bill proposed would receive the same mark as the finest grade of new wool. Market price, $0.20.

6. Card waste: This is a waste material which collects about the cards used in carding wool in the woolen mill. This material has its proper place in wool manufacture. Under the bill as drawn this would be classed as virgin wool and would be at a premium, while garnetted sweater stock or any other high-grade shoddy, both of which intrinsically are much better raw material, would be stigmatized. Market price, $0.15.

7. Coarse noils: In the manufacture of wool into worsted yarns the material is combed for the purpose of laying the fibers parallel and taking out the short fibers. These short fibers are called noils. The noils in this sample came from coarse wools, but they would be classed as virgin wool and their price would be enhanced while any high grade reworked stock, a much better material, would be stigmatized, in case the pending bill were passed. Market price $0.35.

8. French noils: These noils are of a finer grade than sample 7, and for some varieties of cloth they are necessary for giving the kind of finish desired. In strength and wearing properties they are inferior to many sorts of shoddy and yet they must be classed as virgin wool. Compare the length and character of this fiber with that of samples No. 20 or No. 22. Market price $0.85.

20. A high grade reworked wool or shoddy from all-wool new clips or trimmings from new cloth resulting from the cutting of patterns in clothing factories: It is a clean, strong fiber, clearly superior to several of the exhibits of virgin wool, and yet under the bill it would be given the same designation as the poorest grade of reworked stockit is shoddy. Market price $0.68.

22. Garnetted sweater stock, made by resolving sweater yarns into the original plain fiber: This material is in every respect equal to a very high grade virgin wool, and is certainly superior to many types of new wool. Under the bill it would be classed as shoddy, and fabrics made from it would be stigmatized. Market price $0.70. 23. A shoddy of a type which can be used only in low priced fabrics under present conditions of competition: Any manufacturer putting this sort of material into a fabric for which a high price is charged would suffer in competition the fate of any other cheat. Properly used it gives a serviceable fabric at a price much below that which must be charged for a fabric of new wool of like quality. Market price $0.324.

30. Sea-island cotton: Concerning this specimen the dealer from whom it was secured says: "Such cotton, if it could be obtained, would be worth $1.50 a pound to-day." Cotton of this kind would not be likely to be used as a cheapening adulterant in a wool fabric. Cotton has a recognized place in the wool manufacture and it is no more accurate to speak of a mixed cotton and wool fabric as adulterated than to so designate a fabric made of silk and linen. The presence of cotton can be determined by expert cloth buyers by chemical test. These cloth buyers under competitive conditions effectively safeguard the consumer against dishonesty.