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We have studied the matter for some weeks and it seems to us a very complicated one in that certain remedies proposed to correct one fault may by their language upset customs in the business and trade which are advantageous to the consumer as well as to the producer.

Particularly is this so as regards trade descriptions of goods which have been in use for 15 or 25 or more years, and have come to have in the minds of everyone using them a distinct meaning which may be different from the strictly technical meaning of the same terms.

However, we do not wish to burden you with any argument on the bill in this letter, but merely desire to explain to you the care with which we have investigated the subiect and our deep interest in it.

May I ask your clerk to keep Mr. Newell, as secretary of the association, informed as to the hearings to be held in the future. I shall be very glad to remain subject to your call if I may be of assistance to your committee in its work. Very truly, yours,

S. F. DRIBBEN, Chairman Fabric Committee.

LETTER SUBMITTED BY THE AMERICAN ASSOCIATION OF WOOLEN AND WORSTED

MANUFACTURERS.

New York, March 23, 1920. Hon. JOHN J. Esch,

Chairman Committee on Interstate and Foreign Commerce, Washington, D. C. Sir: Having had the pleasure of meeting you at the hearings before the Committee on Interstate and Foreign Commerce on proposed labeling legislation last week, I am venturing to submit a few facts concerning the line-up of the woolen and worsted industry in opposition to the French and other radical labeling bills and in support of the Rogers bill.

There are two general associations in the woolen and worsted industry:

1. The National Association of Wool Manufacturers, of Boston, of which Frederic S. Clark, president of the Talbot Mills, North Billerica, Mass., is president, and Paul T. Cherington, secretary and treasurer.

2. The American Association of Woolen and Worsted Manufacturers, of which George B. Sanford, of Sanford & Russell, New York, is president, and J. J. Nevins, secretary and treasurer.

Both of these associations have appointed committees to deal with the general subject of the proposed legislation, and each of these committees has separately prepared briefs and exhibits.

If conformable with your plans and program, it could be so arranged that the National Association should have an opportunity to present its case first, followed by the case for the American Association, and that followed by resolutions passed by the latter association, presented with a brief statement by the president. Such a procedure would form a natural sequence of events.

The case for the National Association will stress the manufacturing aspects of the problem, while the case of the American Association will deal more particularly with the merchandising of the product.

I am sure you will not misunderstand the purpose of this letter, but will appreciate that it is written with the idea of informing you as to the most logical plan of procedure agreed upon by the two associations in the interests of a clear presentation of the case, and is submitted merely in the hope of aiding you in preparing your program for the continuance of the hearings to-morrow morning. Respectfully,

J. J. NEVINS, Secretary.

LETTER SUBMITTED BY THE WISCONSIN LIVE STOCK BREEDERS' ASSOCIATION,

Madison, Wis., March 30, 1920, Congressman John J. Esch,

Chairman of Committee on Interstate and Foreign Commerce, Washington, D. C. DEAR Mr. Esch: The stockmen of Wisconsin are interested in the proposed truthin-fabric legislation

They, of course, are both consumers and producers of wool. It will interest you to know that Wisconsin annually produces between 4,000,000 and 5,000,000 pounds of

wool which, in quality, is equal to any, and even surpasses many, of the medium wools of this country.

Wisconsin sheepmen are firm in their belief that wool growers of America produce wool of as good quality as any country and that with the adoption of similar manufacturing practices woolen goods of the best grade could be made from it. It is their opinion that the practices of some of our manufacturers in mixing a large percentage of shoddy with virgin wool in the making of their fabric is responsible for the too general feeling that American wools are unsatisfactory for the manufacture of high grade goods.

They appreciate that at the present time the term “all wool," as applied to manufactured fabrics, may mean that the fabric is all shoddy or at least very large percentage of shoddy. "They realize that the average consumer generally believes that "all wool" means virgin wool, but that the fact is that a considerable percentage of the raw material used in making all wool cloth and clothing is shoddy and not in reality virgin wool.

They confidently feel that the American inventive genius can and will devise tests for determining accurately the amount of virgin wool and of shoddy in goods. As consumers they believe that the public is entitled to know what it is buying in fabrics as well as in foods and as producers they feel that they have a right to insist upon fair competition-which means that purchasers of clothing may know when they are getting wool and when shoddy. You may rely upon Wisconsin sheepmen to back you in any movement which shall aid the consuming public to secure cloth and clothing as represented. We feel that we may count upon Wisconsin Congressmen to support legislation which are in the interests of consumers and producers of wool. Very truly, yours,

W. L. Houser, President.

A. W. HOPKINS, Secretary. P. S.-The officials and members of the Wisconsin division of the Fleece Wool States Growers' Association are also fully interested in this appeal. At a meeting of the directors of that organization, held here yesterday, we were asked to convey to you their wishes on the subject.

LETTER SUBMITTED BY THE WASHINGTON WOOL GROWERS' ASSOCIATION.

PROSSER, WASH., March 30, 1920. Mr. JOHN J. Esch,

Chairman Interstate and Foreign Committee, Washington, D. C. MY DEAR SIR: You have received a telegram from the Washington Wool Growers' Association urging the passage of the truth-in-fabric bill. There is another matter that on behalf of the wool growers of this State I would like to call to your attention.

At this particular season of the year wool buyers and wool speculators always take advantage of every opportunity to bear the wool market. They are now circulating through the West, and as far as I have been able to learn have not made a price on wool to the growers. They claim as their reason that the British Government for the past two months has dumped a considerable quantity of wool on our markets, some of the coarse braid wool going as low as 16 and 17 cents and some of the inferior fine wool selling as low as 35 and 37 cents. This wool, no doubt, is not comparable with our wool in quality, but, nevertheless, the effect is the same. It is going to result in the wool growers in this country losing thousands of dollars and the consumer will not profit.

It is generally supposed that the wool growers are making fabulous profits. This impression is wholly erroneous. If statistics were obtainable, I feel sure that the percentage of failures in the sheep industry would far exceed the average of failures in any other line of agricultural pursuits. There is a tremendous hazard attached to the sheep industry. One storm might eliminate a man from the business entirely. Our western country is capable of carrying a greater number of sheep than it is now carrying, but it is difficult to encourage the herdsmen to increase their bands with such erratic market conditions.

If your official capacity will permit you, I would like to ask on behalf of the Washington Wool Growers' Association that you make an investigation of this matter and see if it can not be remedied. Very truly, yours,

J. F. SEARS, Secretary-Treasurer. 177735—20_ 34

LETTER SUBMITTED BY THE NATIONAL HOUSEWIVES LEAG

New York, N. Y., April 2, 1920. Hon. John J. Esch,

Chairman Interstate Commerce Committee, Washington, D. C. DEAR SIR: The National Housewives League (Inc.) has indorsed the Barkley bill.

This organization has members in every State in the Union and complete organization in many. It was organized in 1911 and its work is educational, constructive, and defensive for the protection of the American home. It is therefore composed of a body of women trained in home and commercial economics.

We believe that the consumer should have the same protection when buying fabrics as when buying food, and therefore urge upon your committee the passage of this bill. Asking that you present this letter at the meeting of your committee, I am, Yours, very truly,

JENNIE DEWEY Heath,

President. Mrs. Julian HEATH.

LETTER SUBMITTED BY THE WINCH ESTER WOOLEN CO.

NORWICH, Conn., April 9, 1920. Hon. John J. Esch,

Chairman Committee on Interstate and Foreign Commerce, Washington, D. C. Sir: The testimony offered to the investigating committee on truth-in-fabric legislation has so clearly proved the advantageous use to which the product of woolen rags and clippings is devoted, that further arguments would be cumulative and therefore useless.

During the last few days of the hearing, however, several statements have been placed on record by the protagonists of the labeling bills, and for lack of time or opportunity, these do not appear to have been refuted or modified before the committee. Without entering into a discussion on the pros and cons of the principles involved in the labeling we confine ourselves to what appear to be gross inaccuracies and willful misstatements.

1. We remind you of the statement of J. F. Walker, president of the Fleece Wool Growers (hearing Mar. 31), and repeated by M. Q. Macdonald (hearing Mar, 31). These gentlemen charged that the obstacle to the producer (of wool) has been that of the unfair competition to which he has constantly been subjected by the secondhand product of his labor, call it shoddy or reworked wool. Both these witnesses instanced the advertisement of “Newool."

These false interpretations of a trade mark or label, which we refuted by telegram of March 31, are typical of the protagonists' methods of attacking reworked wool. These attacks are utterly baseless, and the only concrete evidence they have produced has been proved false and can only have been introduced to mislead the public. The charge of misrepresentation has in this case a far more important effect, however; it distinctly indicates that the protagonists of labeling legislation themselves, although presumably experts in virgin wool, either can not distinguish virgin wool from shoddy, or in their search for truth deliberately issue misstatements without troubling to investigate.

2. Representative French in introducing his bill, March 26, compares the rights of the public and the manufacturer each to know the contents of an article that is offered for sale."

These are not parallel rights in this case.

"The manufacturer would not think of buying a bag of or containing wool without looking to see whether it was virgin wool or woolen rags."

Note, first, that the contents of the hypothetical bag all consist of wool (Representative French's version) irrespective of its condition.

Second, the manufacturer would not think of buying a bag of virgin wool without looking to see that the quality of the virgin wool suited his requirements. This is necessitated by his service to the public as an honest purveyor, and the suitability of the material for his machinery. This latter selection is impossible to the public, due primarily to his inability to judge, and subsequently to his lack of understanding of the manufacturing processes.

There are to-day virgin wools used in the manufacture of woolen fabrics that are worth only 25 cents per pound, in contradistinction to reworked wools woven into fabrics and worth $1 per pound.

3. Alexander Walker, of Strong Hewat & Co., on March 31, states that England is now making worsteds with reworked wool. It is an absolute impossibility to incorporate reworked wool or short stapled virgin wool into worsted yarns for worsted fabrics. That Mr. Walker's knowledge of the wool industry is lacking is evidenced by his statement "that the United States will use looms which will utilize reworked wool in the making of worsted fabrics. The problem of the loom has nothing to do with the use of reworked wool either for worsted or woolen fabrics. The spinning and previous preparing processes are the only ones that differentiate worsted yarns from woolen. The method of procedure in these operations preclude the incorporation of reworked wool in worsted fabrics as Alexander Walker suggests.

As manufacturers and users of both virgin and reworked wool, we believe that these statements should receive the attention of your committee. We beg to remain, sir, Very truly, yours,

THE WINCHESTER WOOLEN Co., By NATHAN KALVIN, Secretary.

LETTER SUBMITTED BY JOHN B. BROWN.

Chestertown, N. Y., April 10, 1920. To COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE.

GENTLEMEN: When the pure-foyd bill was introduced by late ex-President Roosevelt, I opposed it as a tea and coffee and spice death, fearing my profits would be reduced. Since I've learned the public was willing to pay for pure food and my profits have been maintained. Manufacturers of so-called woolen cloth will secure a larger value of trade if they produce pure wool cloth, if permitted to publish the makeup, and their profits will not decrease after the first year of the truth of fabrics. The cost of labor entering so largely into every article put together has compelled the public to buy the best of everything. The difference between cost of a man's suiting, cloth cost only considered, of all virgin wool (6 pounds, at 70 cents a pound, equals $4.20, and all raw cotton, 8 pounds, at 10 cents, equals $3.20) is only $1. If the manufacturers will be willing to trade for a fair profit, cloth will be no higher if made of virgin wool. The raw wool needed for man's suit to-day's basis is only 6 pounds, The farmer could only get $4.20 profit if sheep could be raised and kept without cost. A suit of clothes t-day will cost $60 to $80—say $60. The difference between $5, cost of needed virgin wool, and $60 for a suit is divided between manufacturer of cloth, the Russian Hebrew garment worker, his employer, and the retailer. The 1.100 increased per cent over wool cost and retailer's price is surely sufficient to warrant the gentle public in expecting all-wool suit at $61, is willing to pay the extra $1, if assured by label that the buyer could know an honest delivery was made. Clothing is getting almost worn out by a patient public, who can not afford cloths at to-day's going prices, as to-day's cloths have no wear. If factories are protected by customs revenues and the farmers neglected, the result will be, and its coming, short crops, owing to labor turning to factory, discouragement, and following will be want, famine, disease, pestilence. If your committee dubt this statement, another year will convince you. As a New York business min, I can see rural discouragements when I come to Chestertown, my summer home. Farmers do get increased prices, but their costs are more. If they do not get legislative help riots in cities will follow, as famine knows no armistice. Very respectfully, yours,

John B. Brown, Sr., Warren County Sheep Breeders' Cooperative Association (Inc.).

LETTER SUBMITTED BY THE AMERICAN HOME ECONOMICS ASSOCIATION.

NEW YORK, N. Y., April 12, 1920. Congressman John J. Esch,

Chairman Interstate and Foreign Commerce Committee, Washington, D. C. DEAR Sır: The American Home Economics Association, the national organization of students and teachers of home economics, desires to contribute to the record of the hearing on textile labeling and misbranding legislation, held before the Interstate and Foreign Commerce Committee on March 24, the following statements:

The American Home Economics Association strongly indorses legislation penalizing misbranding of merchandise as embodied in the Barkley misbranding bill introduced in 1916 and in succeeding sessions of Congress, and more recently in the Rogers honest merchandise act of 1920.

We hold that the French truth-in-fabric bill will not serve as a reliable guide to the purchaser of woolen fabrics or garments. Because there is so great a variation in the grades of virgin wool and of shoddy, respectively, a label which states only the relative percentages of wool and shoddy in any fabric does not reliably indicate the wearing quality of the fabric. Even were the measure amended to require a statement of the different grades of virgin wool and shoddy used in the fabric, the average consumer could not comprehend the technical terms that must necessarily be used in designating these grades. We feel, therefore, that under certain circumstances the labeling proposed by the French bill might even tend to cause the consumer to invest in a less durable fabric containing virgin wool at the expense of more durable fabrics containing high grade shoddy. The virgin-wool supply of the world is such that a large proportion of reworked wool or shoddy must continue to be used, for a number of years at least, to supplement the inadequate supply of virgin wool, and our experience as consumers and as students of textiles has taught us that the presence of shoddy, as such, does not necessarily impair the wearing qualities of a fabric.

The insanitary conditions under which it has been found that woolen rags are sorted in many places, and also conditions relating to the wages and hours of workers engaged in this branch of the reworked wool industry should, we believe, be thoroughly investigated and properly regulated by State and, if necessary, by Federal law.

We approve the misbranding legislation outlined in the Barkley and the Rogers bills for the following reasons:

1. It is comprehensible, protecting consumers not only of textiles but of every kind of merchandise.

2. It is practical, as proved by the successful operation during 32 years of the British merchandise marks act on which both these bills are patterned.

3. It is comparatively inexpensive of operation.

4. By penalizing false statements it clears the way for an era of educational branding and advertising in which the consumer may feel confidence and which will serve him as a reliable guide. At present, with no machinery available for automatically and promptly bringing to justice those who through ignorance or the desire to defraud represent their wares as better than they actually are, the consumer is frequently deceived into investing his money to poor advantage, and this has naturally resulted in a tendency on his part to discount generally statements by manufacturers and merchants whose goods are not personally known to him. This skepticism on the part of the purchaser often makes him turn away in doubt from a really good investment, to his own loss and that of the merchant.

5. Misbranding legislation is particularly needed in the field of textiles and readymade clothing. The scarcity and high price of raw materials has resulted in lowering qualities in many makes of goods once standard, and in other cases in the use of substitutes less satisfactory than the material which they replace. Modern methods of manufacture can successfully camouflage the appearance of an inferior article. Most important of all, the large proportion of fabrics leaving the mill does not reach the consumer in the form of yard goods but passes into the hands of the cutting-up trade and emerges in the form of ready-made garments, having lost in the process any identifying trade-mark or symbol woven into the material. It is well known that this fact affords an opportunity for misrepresentation as to quality that the unscrupulous are not slow to improve, to the detriment not only of the consumer but of the manufacturer, who has established a trade-mark by years of honest mer. chandise and great expense for advertising.

6. Misbranding legislation would tend to eliminate many faults and misleading statements that now arise, not from deliberate intent, but from ignorance or carelessness on the part of buyers and advertising managers.

The American Home Economics Association contends that the passage of misbranding legislation is vitally needed at the present time

1. Because the era of industrial and commercial depression anticipated by business men will undoubtedly increase the temptation to misrepresent qualities.

2. Because the continued shrinkage of the dollar makes it more necessary than ever before that the purchaser invest his income to the best advantage, and this can only be done on the basis of accurate information as to qualities.

3. Because misrepresentation is most likely to be practiced in the cheaper grades of goods, purchased by the consumer who can least afford to invest his money to poor advantage.

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