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the substitutions were 15 or 20 years ago. The substitutions to-day are all an improvement over the leather that could be used at the same price.

Mr. Burtness. The producer of hides is in a rather bad way now. I remember selling a cowhide which would have brought S12 during the war, sold for 75 cents last year, and then I went down to the hardware store and bought a couple of washers for a pump that cost a dollar, and probably the washers could have been made out of the ears of the cow. Now, do you think a bill of this sort would help the producer of hides any?

Mr. Hazzard. It would put a premium upon inferior leather and a penalty on some of these substitutes.

Mr. Burtness. Might it not tend to encourage the use of leather in a good many factories instead of substitutes?

Mr. Hazzard. It would encourage the use of the leather, but the trouble goes a little further, if a factory

Mr. Burtness (interposing). It might hurt the consumer?

Mr. Hazzard. Yes, sir.

The Chairman. And the quality of the goods?

Mr. Hazzard. Yes. I would only say this, the same thing that I said before the Appropriations Committee in the Senate, that it has been my fortune to study conditions a little bit the world over, and prosperity depends largely on two things: Mass production efficiently distributed, and we probably lead the world in efficient mass production; our weakest point to-day is in efficient distribution. When conditions get so that the farmer down in Aroostook, Me., will get nearer for his potatoes what the man in Washington pays when they go on to his tat>le, and when the man in Aroostook buys his shoes for nearer the price that they leave the factory, the nearer we are coming to real prosperity. Improvement in distribution is not coming through tagging or anything else; it is coming through the general education of the buying public to know values. Now, I am not necessarily saying this against the man that charges a high price for his shoes, because that man may be charging the high price on some special women's shoes, he may have a specialty shop; he may have a big expense, just the same as the Hotel Biltmore has in its service, which is perfectly legitimate, but there are a lot of people who will go to one place and pay $8 who will not buy the same shoe for $3 in another place. I have seen that exemplified over and over again.

The Chairman. Do you recommend legislation to correct that evil between the people who would rather pay $8 than $3?

Mr. Hazzard. No; I do not recommend any legislation to improve human nature. That has been here ever since Adam, and we haven't gotten far from it yet.

(Mr. Hazzard submitted the following papers:)

New England Shoe And Leather Association,

Boston, Mass., April H, 1924Hon. Samuel E. Winslow,

Chairman Committee on Interstate and Foreign Commerce,

Washington, D. C. Dear Mr. Winslow: I send you herewith the brief which the New England Shoe and Leather Association desires to file with your committee in opposition to the enactment of the Reece shoe tag bill, so called.

Thanking you in advance for your courtesy in laying this before your committee, I am,

Yours very truly,

Thos. F. Anderson, Secretary.

Bbief Op The New England Shoe And Leather Association

Committee On Interstate And Foreign Commerce,

Washington, D. C.

Gentlemen: The New England Shoe and Leather Association, organized 55 years ago, and including in its membership a large number of firms and corporations engaged in the manufacture and wholesaling of boots and shoes in Massachusetts, Maine, and New Hampshire, respectfully wishes to enter its protest against the enactment of H. R. 4141, "A bill to protect the public against deceit and unfair prices resulting from the presence of other than leather, wool, and silk in clothing and articles of apparel purporting to be made of said material," and providing "That every manufacturer of shoes and other articles of footwear purporting to be made of leather within any Territory of the United States, or the District of Columbia, shall before offering such articles for sale or for transportation to any State, or the District of Columbia, cause each article to be stamped or tagged showing the amount and kind of material other than leather used in its manufacture."

Our association strongly objects to this bill for the following reasons:

That it constitutes an uncalled for reflection on the honor of the shoe manufacturers of the United States, 500 or 600 of these being engaged in business in New England, whereas our shoe industry always has been regarded as one of the most honorable in the country.

That there is no public demand for such legislation, as proved by the fact that similar proposals have been defeated in a number of State legislatures.

That it is of the species of regulatory and interfering legislation that is tending to strangle industrial initiative and becoming a burden to all of the people of the United States.

That it is useless, unnecessary, and unworkable.

That the tagging or stamping of boots and shoes, as proposed by this bill, in view of the multitude of combinations possible in the fabrication of footwear, be absolutely confusing to the public.

That the bill is fatally defective and impotent, in that it fails to establish, and can not establish, standards of leather quality.

The foregoing are a few of the reasons that might be advanced in opposition to this bill.

Our association in this connection would like to respectfully impress upon your committee the fact that the use of substitute materials in shoes, not visible or subject to direct wear, may safely be left to the 1,300 manufacturers thereof. These manufacturers, as is well known, are operating under intensely competitive conditions, not only as among themselves but with manufacturers of footwear in foreign countries, for, unhappily, the American shoe industry is one of the few industries of the country that has been left entirely without any tariff protection. The qviestion of value in footwear is absolutely regulated by these competitive conditions and does not require any intervention on the part of our Government.

Finally, we would remind your committee that boots and shoes are made in practically two-thirds of the States of the Union, that the general processes of manufacturing footwear are standardized, that shoes are everywhere made on the same machines, and that any differences in component parts is merely a question of price, different classes of people demanding different grades of footwear.

Moreover, there is not anywhere in our shoe industry any secrecy or concealment as to the operation of factories or the use of component parts that go into the making of a shoe. These factories are open to the inspection of anyone interested, including the direct competitors of their owners.

There is nothing watever in connection with our boot and shoe industry of which that industry is in the least ashamed, and we feel justified in stating that no industry is less in need of governmental regulation than it.

As stated in an editorial in the current issue of the Shoe and Leather Reporter:

"Tagging shoes implies that the time-honored custom of buying and selling has broken down. There is no basis for such an absurd conclusion. Honesty, integrity, and all the cardinal virtues are pretty well distributed among buyers and sellers. There are times when sellers need protection from fraudulently inclined buyers, just as there are always some sellers who lie in wait for credulous customers. Government meddling will not improve this situation."

Respectfully submitted,

New England Shoe And Leather Association.
Herbert T. Drake, President.
Thos. F. Anderson, Secretary.

Box Toe Comes Up Smiling Every Time—Not Damaged By Pressure Of 170 PoundsWill Not Wrinkle Or Bunch Over Toe

A box toe that will not wrinkle or bunch over the toe or lose its shape has been developed by the Armstrong Cork Co. for soft-toed shoes. f*

Even though the toe of the shoe is crushed flat as it is in the picture below, the box is not damaged and returns to its natural shape.

Returns Quickly To Normal

In the photograph, the toe of this-patent leather dancing shoe is supporting a weight of 170 pounds, and the picture taken of the shoe after the severe test shows that the toe has returned to its normal shape and there are no evidences whatever of the test.

Gives Proper Support

The Armstrong box toe gives just the proper support to the toe. It is being welcomed by manufacturers at the present time because of the popularity of plain-toed . shoes for walking. The scarf edge of the Armstrong box does not show and the resilience of the material permits the toe to be bent naturally and comfortably without a bunching or wrinkling of the box. The box is also impervious to moisture.

A complete line of sizes is now available in this new box toe.

Shoe Tag Legislation

Brief In Opposition To The Enactment Of H. R. 4141, Of The Sixty-eighth

Congress, First Session

(Submitted by R. P. Hazzard)

Representing the National Boot and Shoe Manufacturers' Association, we desire to enter our opposition to the legislation proposed by H. R. 4141, entitled: "A bill to protect the public against deceit and unfair prices resulting from the presence of other than leather, wool, and silk in clothing and articles of apparel purporting to be made of said material."

This bill requires that every manufacturer of shoes and other articles of footwear purporting to be made of leather, within any Territory of the United States or the District of Columbia, shall, before offering such articles for sale or transportation to any State or the District of Columbia, cause such articles to be stamped or tagged, showing the amount and kind of material other than leather used in their manufacture.

The penalty imposed is that any person, association, company, or corporation, violating the provisions of this act, shall be guilty of a misdemeanor, and for the first offense shall be fined not more than $1,000, or by imprisonment for not more than one year, or both, and for each offense thereafter, shall be fined not more than $5,000, or by imprisonment for not more than three years, or both.

The bill further provides that the Secretary of Agriculture, the Secretary of Commerce, and the Secretary of the Treasury shall make uniform regulations for carrying out the provisions of this act, and that it shall be the duty of each district attorney to whom the Secretary of Commerce shall report any violations of this act, or to whom any appropriate officer, or agent, may present satisfactory evidence of such violation, to cause appropriate proceedings to commence and prosecute in the proper courts of the United States without delay in the enforcement of the penalties provided therein.

ARGUMENTS

First. As far as shoe materials are concerned there is nothing poorer than poor leather, and as no provision has been made in this bill as regards quality of either leather or workmanship the bill, therefore, is useless as regards protection to the consumer.

Second. Purporting means "to intend"—"to mean"—"to signify." The sale of a shoe even if made in part of leather, does not purport that the shoe is all leather, for there are no all leather shoes made. Every shoe has materials

in it other than leather. The most serviceable welt shoe ever produced is the Army shoe and that has a canvas back insole.

Third. The only shoes that purport to be all leather are such shoes as are branded "All Leather" or "100 Per Cent Leather," which shoes are not so made but that the present laws effecting false branding should take care of this.

Fourth. Sitbstitvtions—good rubber heels will outwear poor leather heels. Certain composition soles will outwear leather soles. Fiber counters are guaranteed to outwear the leather outsole, while leather counters are not guaranteed— -why? Because results, proven by statistics, show that the average fiber counter outwears the average leather counter.

Fifth. Substitutions are essential to service in shoes sold at popular prices and good substitutions are preferable to poor leather, and the large majority of people are buyers of shoes at popular prices.

We contend that the consumer is not particularly concerned as to material used in any particular part of the shoe which he purchases, but rather demands service; style and price and branding will not get him any of these of itself.

The bill would tend to perpetrate a serious and expensive fraud on the consuming public.

It is our contention, after reviewing the proposed bill from every angle that the enumeration of all articles other than leather used in the manufacture of shoes would be a burdensome formality and would afford the purchaser no real information and no protection whatever, but the most serious objection of all -would be the compulsion under which some manufacturers would feel that they "were placed to use leather exclusively under such circumstances, and would necessarily use a very cheap grade of leather which could be finished and disguised so as to have the appearance of good quality, while practically worthless. Soles cut out of bellies and heads, heels with spongy lifts, inner soles of two pieces of split leather, while entirely of leather might easily be inferior to any of the better class of substitutes. They would comply with the law, but would really perpetrate a serious and expensive fraud on the consuming public.

Respectfully submitted by

R. P. Hazzard.

BRIEF IN OPPOSITION TO THE ENACTMENT OF H. R. 4141, OF THE SIXTY-EIGHTH

CONGRESS, FIRST SESSION

(Submitted by National Boot and Shoe Manufacturers' Association of the United States (Inc.), National Association of Shoe Wholesalers of the United States, National Shoe Retailers' Association of the United States of America (Inc.), and National Shoe Travelers' Association (Inc.)

PREFACE

Representing the National Boot and Shoe Manufacturers' Association, the National Association of Shoe Wholesalers, the National Shoe Retailers' Association, and the National Shoe Travelers' Association, we desire to enter our opposition to the legislation proposed by H. R. 4141, entitled: "A bill to protect the public against deceit and unfair prices resulting from the presence of other than leather, wool, and silk in clothing and articles of apparel purporting to be made of said material."

This bill requires that every manufacturer of shoes and other articles of footwear purporting to be made of leather, within any territory of the United States or the District of Columbia, shall, before offering such articles for sale or transportation to any State or the District of Columbia, cause such articles to be stamped or tagged showing the amount and kind of material other than leather used in their manufacture.

The penalty imposed is that any person, association, company, or corporation violating the provisions of this act shall be guilty of a misdemeanor, and for the first offense shall be fined not more than $1,000, or by imprisonment for not more than one year, or both, and for each offense thereafter shall be fined not more than $5,000 or by imprisonment for not more than three years, or both.

The bill further provides that the Secretary of Agriculture, the Secretary of Commerce, and the Secretary of the Treasury shall make uniform regulations for carrying out the provisions of this act, and that it shall be the duty of each district attorney to whom the Secretary of Commerce shall report any violations of this act or to whom any appropriate officer or agent may present satisfactory evidence of such violation, to cause appropriate proceedings to commence and prosecute in the proper courts of the United States without delay in the enforcement of the penalties provided therein.

SUMMARY OF POINTS

I. This bill was evidently drafted with the intention of giving the public an honest shoe, but, owing to the fact that it does not comprise the essentials of good shoemaking, it will not result in giving as good values as are now given under the compelling force of competition.

(a) Good shoemaking requires massing of strength at strategic points, namely, sole, vamp, top, etc. These points are not covered in this bill.

(b) Use of materials other than leather in certain parts allows the manufacturer to produce a maximum service shoe.

(<?) This bill will increase the use of inferior leather and consequently the price of leather and shoes.

(d) Competition now gives the public the maximum service shoe.

II. The use of materials other than leather, for leather is in line with the conservation of our natural and economic resources. It permits the utilization of waste in the manufacture of by-products along the lines of the most scientific progress in industry.

III. The proposed legislation will undermine a valuable good will developed by manufacturers and wholesalers and retail merchants throughout the country.

IV. This bill would tend to perpetrate a serious and expensive fraud on the consuming public.

Point I

This bill was evidently drafted with the intention of giving the public an honest shoe, but owing to the fact that it does not comprise the essentials of good shoemaking, it will not result in giving as good values as are now given under the compelling force of competition.

VITAL PARTS OF SHOE

The most important items entering into a shoe are obviously upper leather and sole leather. Leather of every kind and of almost every grade finds its way into the manufacture of shoes. There is a wider divergence in serviceableness and wearing qualities between the different grades and kinds of leather than there is between leather and substitutes for leather.

This bill would make it compulsory to stamp or tag every shoe, showing the amount and kind of material other than leather used in its manufacture.

Under the strict interpretation of this bill, every shoe would have to be stamped or tagged.

Assuming, however, that the purpose of the bill is to indicate to the public when and where substitutes for leather are used in the manufacture of footwear, the bill fails to provide that the consumer shall know the grade and kind of leather used in the upper and in the sole of his shoe, the points subject to the severest wear.

It is analogous to a requirement that tailors shall specify the material used in the lining of suits, but need not specify the material or quality of the suiting itself. It is on a par with building laws which should provide in detail as to the decoration of the building, but should not provide for the foundations, walls, and floors.

MAXIMUM SERVICE SHOE

The public in purchasing shoes wishes to obtain a shoe giving the maximum service and comfort for the money expended. Such a shoe is an honest shoe. Let us consider the laws of good shoemaking in the construction of such a shoe.

Shoes are sold to the consumer at fixed popular prices. Competition among manufacturers is a competition of quality, therefore, rather than of price. In producing a shoe to sell at a given popular price the manufacturer has appropriations for merchandise, labor, overhead expenses and selling expenses. His appropriation for merchandise he must divide in accordance with his best judgment and distribute over the various items of outersole, innersole, heel, vamp, top, tongue, findings, etc. He is at liberty to improve the quality of the heel at the expense of the sole, or to improve the quality of the sole at the expense of the vamp. He must exercise his skill and ability in producing with a given appropriation a shoe which will give the maximum service to the consumer. In those parts of the shoe which are subject to the severest wear and the greatest strain he must expend the major part of his appropriation. If these points are slighted, the shoe is a poor shoe.

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