and the word "virgin" is to cover everything from a fiber so coarse that it can not safely or confortably be worn next to the skin to the finest grades of wool used in textiles. On the other hand, the finest fibers which have been knitted or woven into perhaps the softest fabric, so that they can be easily torn apart in the clippings and garnetted and worked up into good yarns, however fine they are or close to their original length, are to be condemned by the disreputable word "shoddy," which in common parlance means something that is not what it should be or not what it seems to be, or of shady respectability, and is always a term of reproach.

In going into a retail store a woman is to be advised by this label or tag that an article contains shoddy. She, knowing nothing of the relative merits of the different forms of reworked wool, will certainly form a prejudice at once against any fabric or garment or gown marked with the word shoddy.

Opinions such as I am expressing carry more force when backed by some experience. During the entire course of the war, first in the Council of National Defense, and then as an officer of the War Department, and finally in the War Industries Board, I was responsible for securing for the United States Government its entire supply of knit goods, including all the woolen underwear, woolen stockings, puttees, woolen garments, mufflers and everything that the Government needed in that kind of clothing for the soldiers and sailors.

It was obviously of the first importance that the Government should make plain to the contractors exactly what it required in each of these purchases. It is equally obvious that the Government must make plain to its inspectors what they should look for in the garments and the fabrics furnished to the Government to insure proper delivery under the terms of the contract with the Government. You will see at once how absolutely silly it would have been if in our specifications we had simply said about the raw material that it should contain "virgin wool." It would have meant nothing at all to the manufacturer or to the inspector. These inspectors were men of some textile sense, and yet virgin wool" would have meant nothing at all to them. The distinction between shoddy and virgin wool will mean nothing at all to the woman in the retail store. Exact specifications were written for each of the Government articles in which the raw material was defined beyond the shadow of a doubt as to the grade of wool, the condition of the wool, and exactly how it was to be handled. Specifications for Government fabrics in very carefully chosen words will take two or three paragraphs of probably 9 or 10 lines each in newspaper type; a third of a column in newspaper, fine print, would be required to print the Government specifications for the Army overcoats or even for the woolen undershirts. Now, if it takes all of that space without a superfluous word to give the information necessary to the manufacturer to know what is wanted and to give to the Government inspector the information needed to check up the product of the manufacturer, how much information is the consumer in the retail store going to get from the mere tag that says this cloth contains 80 per cent of virgin wool and 10 per cent shoddy and 10 per cent cotton. It will mean or should mean nothing at all, and as merchants we say it is much more dangerous to give a little information without giving all of the essential information than to give none at all. You are simply in this bill giving a half truth,

not even a half truth, not one-hundredth of the truth, and you are actually giving a sense of false security to the consumer, which is worse than nothing, absolutely worse than relying upon the reputation of the dealer or the reputation of the manufacturer. We believe that it is an obnoxious principle to embody in legislation, and especially by the wording that is used in this bill.

The term "virgin wool," if the Government buyers had used it, would have allowed manufacturers to deliver underwear such as the Canadian Government furnished its soldiers at the beginning of the war. It was all made of virgin wool. But it was wool so coarse that a man could not wear it. The British Quartermaster General told me that their men by the thousands in the dead of winter in France tore off that underwear. An orderly told me he had seen them do it any number of times; men suffering with cold who could not stand this coarse stuff on them. Even in Canada they had to stop buying such coarse underwear.

Now, I want to approach this from another angle of experience. Two or three years ago

Mr. DEWALT (interposing). In your specifications for the underwear for our troops, did you incorporate any shoddy?

Mr. CROMWELL. No; it was excluded from all knit goods except the puttees, where it was put in in order to help use up the clips from the uniforms.

Mr. DEWALT. What did you specify or enumerate as to wool?

Mr. CROMWELL. That the wool should not be of lower grade than half blood.

Mr. DEWALT. Will you explain, please, what is meant by half blood?

Mr. CROMWELL. Half blood is a grade of wool that can only be demonstrated by showing samples. It is a fine wool. The trade term "fine wool" is better than "half-blood" wool. It is a very nice wool of a kind grown largely here and was imported very largely from Australia. It was a wool of which we could get a large supply and was an ideal wool for that purpose.

Mr. DEWALT. Is the term used with reference to the breeding of sheep?

Mr. CROMWELL. I think not. At any rate, a wool dealer would grade it as half-blood wool on the fineness of the fiber, without reference to the kind of sheep. It is a well-known term.

Mr. JONES. A gentleman introduced yesterday some reference to it. I think it was Mr. Clark.

Mr. CLARK. Most of those samples I showed yesterday were fine samples, 1 to 1-A, and better than half blood. There was no sample there that was of the half-blood grade. Wools are graded, as Mr. Cromwell says, half blood, going below that, three-eighths, and onequarter, and then above half blood, double X, triple X, with more gradations.

Mr. JONES. You have one sample marked one-quarter. Is that one-quarter blood?

Mr. CLARK. That was a cotton sample.

Mr. JONES. I thought it was wool.

Mr. CROMWELL. The Canadian underwear was made of about a quarter-blood wool.

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Mr. DEWALT. Speaking again of the reference to virgin wool; if you know, can you tell us why the Government specified virgin wool? Mr. CROMWELL. The Government did not specify that.

Mr. DEWALT. Not virgin wool, but half blood.

Mr. CROMWELL. Of course. I drew the specifications myself, and knew that half-blood straight wool would make the very best underwear.

Mr. DEWALT. Why the exclusion of the shoddy?

Mr. CROMWELL. Shoddy was excluded for various reasons. The first reason was the difficulty that it would have put upon the inspectors. The second reason was that it was not necessary to use reworked wool in the underwear for the Government, so we reserved all of it for civilian use, and it made exceedingly good underwear. composed half of Government clips and half of straight cotton. It would have complicated the Government problem very greatly if we had allowed any of those clips to be used in the Army knit goods. Mr. CLARK. Explain that the material from the Government clips would be shoddy.

Mr. DEWALT. Whether reworked or not, it would be shoddy. Mr. CLARK. Shoddy would be reworked wool from Government clips.

Mr. CROMWELL. I want to approach this from another angle of experience. About three years ago the proprietor of a Washington dry goods store, in this city, was indicted criminally for fraudulent dealing, claiming that he had falsely advertised some underwear. His defense was that he had used in his advertisements only the words which were on the labels of the underwear which was sold, and on that defense he was acquitted. Thereupon the Fair Trade League took the matter up with the Federal Trade Commission and moved to have the whole matter of underwear and hosiery labels looked into. The National Association of Knit Goods Manufacturers, being most anxious to put their house in order, and to avoid any suspicion that its members were deceiving the public, appointed a committee, of which I was made the chairman, to look into the entire matter of labeling. Underwear and hosiery are sold in boxes and the boxes must have labels. So here was a case where labels, not on the garments but on the boxes, was the universal practice, and it was not a question of whether we would have any labels but how those labels should be worded.

We looked into the entire matter. We found that some of the labels were plainly misleading. The labels which were in the shadow zone, however, were labels on which were used words which were clearly understood in the trade and the industry, but might very easily convey a different meaning to the consumer.

With the British merchandise marks principle in mind, we made a report to the association which was unanimously accepted, and afterwards accepted by the National Association of Dry Goods Wholesalers, and approved, I think, unanimously by the trade papers. Instead of describing definite labeling that should be done we prescribed the labeling that should not be done, with a view to preventing fraud. Instead of dictating to the manufacturer how he should label his stockings he was left free to put them in a box simply marked "stockings, size 10." He could put up undershirts and say merely "undershirts, size 42." We did not tell him that he must

label it wool or part wool or anything of that kind, and we believed that in the method we took we served the best interests of the trade and the best interests of the public. Both were equally in our mind. But we said that when a man put the word "wool" on the label of underwear or hosiery it must be all wool. Where he said it was silk underwear or silk hosiery, it must be all silk; that if a coat contained silk and wool and cotton, he must say silk and wool and cotton; he could not use simply the name of the better material. The trouble in Washington with the dealer I have referred to was that the underwear had Australian wool in it, but it contained only a small percentage of Australian wool and a very large percentage of cotton and some inferior grades of wool.

So the principle of the Rogers bill or of the Barkley bill was exactly the principle which was adopted in our report. It was accepted by the Federal Trade Commission and made the basis of an order which resulted from a perfectly friendly proceeding between underwear manufacturers and the Trade Commission. This order is in universal operation to-day in the hosiery and underwear industry. I think that we have successfully met it from the point of view of this Barkley bill or the Rogers bill. We hope that these bills, one or the other, or something that grows out of them, will be adopted, because we believe there is need for such legislation.

No

I think there is a very greatly exaggerated idea of the fraud that goes on. Such as there is, is not fraud of the kind that comes much from labeling. There are many other ways of misrepresenting merchandise, as to the quantity, as to who made it, as to the sources that it came from, such as pretended fire or bankruptcy sales. One of the things we found wrong was the use of words which suggested that the material came from a country where they did not come from. For instance, the word "Egyptian" has been used to describe American cotton stained a yellowish tint in imitation of genuine Egyptian cotton. Hereafter the underwear and hosiery labels must say "Egyptian color" if the cotton used is not genuine Egyptian. matter how much general information that the manufacturer puts upon the labels or upon the tags it can not completely describe the fabric or the garment specifically as it would leave out one of the most important elements of manufacturing and that is the human element. That is the element which means the skill, the care, and the integrity of the manufacturer. You can no more get good dependable fabric out of a mill by merely putting into its hopper good material than you can be sure of a good dinner by putting good food into the kitchen and being indifferent to whether it is prepared by the cook or by the furnace man. It makes all the difference in the world who puts those materials into the fabric or into the garment.

During the war we sent uniform specifications to dozens and scores and hundreds of clothing manufacturers. Uniforms that came from one mill would be all accepted, absolutely perfect. Uniforms from other mills made on the same specifications, while technically right, would be rejected simply because they could not be worn. There was one manufacturer with large contracts, whose deliveries were so unreliable and rejected in such enormous percentage that he actually had the nerve to put up a refinishing factory just outside of the Government, depot where the goods were accepted, to save himself the cartage and freight expense of going back to his

factory where the goods were made. He had them refinished there by the thousands. And yet all these uniforms were made up from the same specifications, and under a bill like this French bill they would all have on them identical tags. All of them were from the same material, which was furnished by the Government in each case. Every material that went into these uniforms was furnished to these men by the Government, but the contractor referred to showed a callous lack of care and indifference in making up his uniforms.

So we believe that no tag and no label can give the consumer anything but a half truth or set up anything more than a false sense of security, which is wrong, and it is in exactly that atmosphere of misrepresentation that frauds are practiced by unscrupulous dealers. Mr. DEWALT. You say that in spite of the fact that these specifications, as outlined by the Government, were given to scores of manufacturers, that the product received from different ones varied so much that some of them could be accepted and others totally rejected. That is a fact, is it?

Mr. CROMWELL. Yes.

Mr. DEWALT. That is a fact?

Mr. CROMWELL. Not could be, but were rejected.

Mr. DEWALT. That being so, how does it comport with the idea of Dr. Alsberg that he gave us this morning as to the practicability of establishing a standard by the Government, which standard is communicated to the different manufacturers, and then have the manufacturers produce with their manufacturing processes and then mark the goods "standard A," "standard B"? How would that, in your judgment, work out, according to your experience?

Mr. CROMWELL. I think it would not work. I discussed that matter with Dr. Alsberg. I think he qualified as a food expert and not as a textile expert. I think he said that textiles practically did not come under his inspection in his work.

Mr. DEWALT. Will you give us your reasons why you think it would not work out?

Mr. CROMWELL. I think that the kinds or varieties of fabrics are so complicated that if different standards as he suggested the Government adopt, standard A, standard B, were adopted, there would have to be as many standards as there are types of fabrics in the specifications. I do not know how they would do it for underwear or hosiery. You would have so many different standards of everything. I think it would not work in the retail-goods store, for one store could show the goods and say to the customer, these are A and another B, and another C. It would mean little to the customer as to what actually entered into A, B, or C.

Mr. DEWALT. I do not quite follow you there. The standard, if established by the Government, would compel, or at least place the the duty upon the manufacturer to have a product which met that standard requirement. Then, when he marked the goods "standard A," and the Government having adopted certain specifications that were standard, it would be knowledge communicated to the consumer that the goods sold were of a requisite quality as to durability and as to preservation of the body from the inclemency of the weather, etc., as outlined by Dr. Alsberg. So that I scarcely follow you in the conclusion, because we have too many standards; it would be confusing.