would then be destroyed, and the skins would have to be relabeled upon the completion of the dressing processes. We thus have three different labeling operations added to the great many operations already involved in the handling of fur skins up to this point.

The owners of the skins then decide upon the various colors and shades into which they wish to dye these skins. Frequently, long periods of time may elapse between the completion of the dressing stage and the dyeing stage. This is obvious in that a great number of skins are imported, frequently sufficient for a season or two, and the colors will depend upon seasonal demands.

It is

The dyeing of fur skins involves a great many processes. important that we detail some of these processes in order that the committee have a clear grasp of the impossibility of the survival of any stamp, label, tag, or other device through all of these dyeing

processes.

First, the skins are subject to a scouring process to remove the grease or oil. Nuturally, any ink or other markings would likewise be washed out. Any metal would cause spotting and rust and would cause damage to the skins. The next step is the application of a mordant. This is a chemical which enables the dye to penetrate along the lengths of the hair. This chemical likewise would eradicate ink or stamps and would cause damage to the skins when in contact with any metal. The third step is the immersion of the skins into vats to dye. Naturally, the dye would cover, absorb, or eradicate inks, and the effect of contact with metal would cause damage to the skins. Even the machinery used in dyeing, such as vats, extractors, and the like, are porcelain coated to avoid contact with metal. The use of any metal device would be disastrous in its reaction upon the dye solution. Stamps, tags, or labels would be obliterated. During these processes, the skins may be subjected to immersions in dye solutions more than once. Some skins are subject to further dyeing, blending, striping, and shearing before or after manufacture, even though they have been dyed by this process once before. Thus, no label could survive this series of processes. After this handling, the skins are then dried. This involves, in many instances, the use of heat, extraction of excess moisture by machine, and drumming. Again the skins are tumbled. Of course, labels would become intertwined and the skins damaged. After the drumming process, the skins are pulled in order to stretch them back into their original shape. Here, again, no labeling of any kind could survive. Thus the fur skins would again go through two processes of labelirg under H. R. 3734, one when the dye processes are started and once again upon completion.

The

After dyeing, the skins are then made up into garments by the manufacturer. The manufacturer, of course, would then be compelled to remove the individual label, as required by H. R. 3734, and he, in turn, would be required to substitute a label of his own. manufacturer, in making up the garment, matches the skins as to shades and color rather than as to origin. Fur skins, being animal, live matter, do not and cannot all come out in the same identical color even when subject to one dye, as would a bulk of cloth. Thus, the garment manufactured may have skins from many different points of origin blended and amalgamated. The dyers' relationship to the skins, however, does not end at this point. Many skins, such as muskrats, marmots, minks, lambs of all kinds, and so forth, require

further processing on the part of the dyers after the coat is made up. Many garments are blended. Many others are blended and striped. Here, again, the fur skins are manufactured into garments or sections of garments and then sent to the blender or striper for blending and striping.

Some of these processes require immersion, and others, a hand or feather brushing. No label, tag, stamp, or ink would survive these processes. Again, therefore, the manufacturer's label would have to be removed prior to the commencement of work and again be replaced or affixed after completion. Again, when the garment is returned to the manufacturer for closing, sewing of lining, finishing, or trimming, the blenders' and stripers' labels would have to be removed and a new label would have to be attached, all as required by H. R. 3734. Thus, in the processing of dyeing, blending, and striping, the labels would perforce have to be removed at least seven times.

Thus, from the point of arrival of the raw fur skins to the point of completion of the manufactured garment, the skins or garments would have to be labeled from 7 to 10 times, as required by H. R. 3734.

These 7 to 10 labeling operations, of course, are not individual operations. They may require removal of tags or labels from pieces such as paws, gills, legs, heads, and bellies. This can best be understood by means of simple illustration. For example, in the handling of Persian lambskins, the heads, paws, and necks are cut away. These pieces, because of their value, are used in the manufacture of other coats and garments. These pieces, under H. R. 3734, would likewise have to be labeled and relabeled separate and apart from the skins from which they are cut. Thus, at least four additional labeling processes would be required in that instance.

Many skins such as lambs and squirrels are made into lamb and kid plates and squirrel sacs and are then dyed and blended. These lamb and kid plates are composed, in many instances, of 75 different skins which may have many different places of origin. They are thus impossible to label. Even after dressing, it would require four additional labeling processes in addition to those already previously outlined.

POINT III. LABELING AS REQUIRED BY H. R. 3734 IS IMPRACTICABLE, IMPOSSIBLE OF ADMINISTRATION, UNREASONABLE, UNNECESSARY, BURDENSOME, AND DISCRIMINATORY

The special handling of each individual fur skin required by H. R. 3734 for labeling purposes, when repeated to the extent of from 7 to 10 times prior to and through the dressing, dyeing, and blending stages and the numerous times required in the manufacturing and completion stages, would prove burdensome and costly and destructive to the importer, dealer, dresser, dyer, and manufacturer. The skins would be damaged by the affixation of so many labels on so many different occasions and the punching of so many different holes. No ink would survive all of the processes. Now, let us see whether, in fact, any benefit would be gained by anyone up to this point.

This honorable committee cannot and should not assume that the dealer, importer, dresser, dyer, blender, or manufacturer are naive, gullible neophytes who do not know one skin from another. They are usually experts in their field, and all know the different types of fur

skins and fur garments. Aside from this specialized knowledge, the dealers, importers, manufacturers, dressers, dyers, and blenders all receive invoices clearly stating the type of skins and country of origin thereof. No further labeling is required.

Thus, the only purpose served by the labeling required by H. R. 3734 is the increased use-taxing beyond the breaking point-of storage space, dock space, transportation, and plant facilities. In these days, any increased use to which these three phases of our economy are subject might well prove impossible. Încreasing costs of handling would ultimately be reflected right down the line from the original importer to the ultimate consumer.

Of even greater importance to the fur industry and to the ultimate consumer is the unnecessary subjection of fur skins to tearing and spotting in the course of labeling as outlined herein. The risk of damage in the ultimate analysis would tend to diminish the usefulness of fur skins and completed fur garments.

The fur industry has enjoyed a long period of useful service to the people of the United States, both in peace and in war. The fur industry was one of the first and leading industries which led to the development of the Western Hemisphere and North American Continent. The processing and dyeing of fur skins is an industry which has grown by tremendous proportions since the turn of the twentieth century. The diffculties encountered have been great, and every effort has been made not only to satisfy the style consciousness of the customer but to enable all classes of people to have fine-looking garments. Thus, low-priced fur garments, expensive in appearance, durable in wear, have been made available to even the lowest wage-earning segments of our population through the assiduous efforts and ingenuity of the fur processors. Any legislation which would tend to discourage the processing, dyeing, blending, and striping of fur skins and fur garments would, in effect, diminish the usefulness of furs for apparel purposes.

The problems of the dealer, importer, manufacturer, broker, and retailer will be individually discussed in individual memoranda.

CONCLUSION

We respectfully submit on behalf of the fur-processing industry that the committee report H. R. 3734 unfavorably.

1 This group is submitting an independent brief and is appearing independently in opposition to H. R. 3734.

We are representing the fur dressers and fur dyers and many other elements and branches of the fur-processing industry.

Our chief concern with the bill is the impracticability of the labeling as presently required or would presently be required in the statute as written.

I should like to outline the processes through which the various fur skins must go before they reach the finished garment in the manufactured state and in that manner I will state to the committee that labeling as would be required here would be impossible and, if not impossible, impracticable at least impracticable.

When the skins arrive in this country normally as raw skins, they would be duty free and would be quickly cleared from our customs or bonded warehouses.

Now, under this bill they would have to be labeled before that clearance. Now, no one likes to do any more work than he has to do and the dealer or importer is no exception, and as a rule he would direct the processors to go to the warehouses or go to the dock, pick up the skins, and start to put them through the process of dressing and dyeing. Therefore, the burden of that first labeling as required by the act would fall upon the processor.

Now, what effect would that first labeling have upon the situation? Visualize, if you please, the arrival of the skin into the plants of the processors.

The first thing that must happen is that the skin must be treated with a preservative in order that mesenteries, tissues, the fatty tissues, and other matters on the skin, and the flesh that still clings to the back of the skin would not cause a rotting of the cutaneous tissue that will ultimately become leather.

Now, that treatment is a chemical treatment.

Any kind of a tag or label would either be effaced, eradicated, spoiled, or would disappear entirely right at that point.

That would mean that the processor would still have to use his same method of identification that he uses now and would have to remove the label that he just put on, on the dock or in the warehouse, before he starts the processing.

Now, the skins go through various processes for the purpose of tanning that is, creating the leather side of the skin-for the purpose of keeping them pliable and soft so that ultimately when they become a garment they do not stiffen up and do not become hard, as shoe leather would. Through these processes the skins are treated and subjected to so many chemicals, pounding, mauling, and handling that no label on the skin could possibly survive and certainly no label would remain affixed.

Mr. O'HARA. Would you let me ask you a couple of questions there?

Mr. STEIN. Yes, sir.

Mr. O'HARA. When these skins come in-the imported-to the dock, what is the manner in which they are surveyed by the Customs? Are they weighed or not?

Mr. STEIN. Most raw skins are free of duty and, therefore, they would take them on the basis of the manifest, the basis of the invoice, and that states the country of origin, which is printed clearly on the bale or on the bagging.

Mr. O'HARA. The only skins which are not duty-free are silver fox; are they not?

Mr. STEIN. Well, they would be counted or weighed, or whatever measure they use there; but the proportion is so small as against the 195,000,000 skins which are imported that hardly creates a problem, whereas the handling of 195 skins would.

Mr. O'HARA. What is done on silver fox skins; do you buy them? Mr. STEIN. No; unfortunately I do not know. The dealers' representative is here. I think he might be able to answer that question.

Mr. O'HARA. When the skins are brought in, the importer is the one who is the owner of them; is that true?

Mr. STEIN. The importer whom we call the dealer.

Mr. O'HARA. Now, you turn them over to the processors?

Mr. STEIN. The processors, yes, sir; the processor never becomes the owner.

Mr. O'HARA. How are the skins handled? Say you have a bale of skins coming in; how are they identified in the processors' plants?

Mr. STEIN. Well, that is not a difficult problem there because there you keep them as one lot. In other words, you send that lot through every process individually. You would not intermingle them with any other lots, and, of course, while the lot is in the vat

Mr. O'HARA. The processor does business usually for more than one importer or dealer; does he not?

Mr. STEIN. Yes, sir; he does business for more than one, but he keeps each individual lot differently.

Mr. O'HARA. How does he do that?

Mr. STEIN. First, the drums, for example, are very limited in capacity. You cannot have a drum or a vat which you are going to put these skins into so large that it will absorb more than several hundred skins at a time. So that you will find them putting a lot of skins through today; for example, 10 lots of skins-I do not know just what number, but maybe not more than that number, but they do not have any trouble identifying them there.

In storage, then, of course, it is easy to keep them separate and then they go through the finishing processes together as a unit. Thus throughout they are kept together. And then you send the next ones through and you keep them separate.

Mr. O'HARA. Well, when they are hung up to dry then they are intermingled with other skins, are they not?

Mr. STEIN. No; they are not.

Mr. O'HARA. They are kept separate?

Mr. STEIN. If they are not kept separate at least they are kept in separate stages.

Mr. O'HARA. In what way does the processor identify those skins? Mr. STEIN. The processor himself?

Mr. O'HARA. Yes.

Mr. STEIN. Well, as he puts the skins into the vat he shows on his chart or blackboard next to the vat the number of the skins, the time they went into the vat, and so on, so that you can control the length of time they are immersed in the dye or immersed in the pickling and then when they are removed, of course, the number is erased as they go on to the next customer.

Mr. O'HARA. Do they not mark some skins with some needled process or with some preparation similar to that?

Mr. STEIN. Yes; some of them are; but they are marked in such a place so that the needle point and perforation will ultimately be cut

away.

Mr. O'HARA. Where does that needling take place?