Approved Code No. 71-Reprint Registry No. 619-1-03 

NATIONAL RECOVERY ADMINISTRATION 

CODE OF FAIR COMPETITION 

FOR THE 

PAINT, VARNISH 

AND LACQUER MANUFACTURING 

INDUSTRY 

AS APPROVED ON OCTOBER 31, 1933 

BY 

PRESIDENT ROOSEVELT 

WE DO OUR PART 

INCLUDES AMENDMENTS Nos. 1-11 

I 

I ~ f\ D " ---- { ~ t .,__________ f 

I .., 

U.S. DEPO~TCP·· ' UNITlm STATES .,__ _____ -::·----~~---; 

GOVERNMENT PRINTING OFFICE 

WASHINGTON : 1934 

For sale by the Superintendent of Documents, Washington, D.C. - - - - - - Price 5 cents 

V 
This publication is for sale by the Superintendent of Documents, Government 

Printing Office, Washington, D.C., and by district offices of the Bureau of Foreign 

and Domestic Commerce. 

DISTRICT OFFICES OF THE DEPARTMENT OF COMMERCE 

Atlanta, Ga.: 504 Post Office Building. 

Birmingham, Ala.: 257 Federal Building. 

Boston, Mass.: 1801 Customhouse. 

Buffalo, N.Y.: Chamber of Commerce Building. , Charleston, S.C.: Chamber of Commerce Building. 

Chicago, Ill.: Suite 1706, 201 North Wells Street. 

Cleveland, Ohio: Chamber of Commerce. 

Dallas, Tex.: Chamber of Commerce Building. 

Detroit, Mich.: 801 First National Bank Building. 

Houston, Tex.: Chamber of Commerce Building. 

Indianapolis, Ind.: Chamber of Commerce Building. 

Jacksonville, Fla.: Chamber of Commerce Building. 

Kansas City, Mo.: 1028 Baltimore Avenue. Los Angeles, Calif.: 1163 South Broadway. 

Louisville, Ky.: 408 Federal Building. 

Memphis, Tenn.: 229 Federal Building. 

Minneapolis, Minn. : 213 Federal Building. 

New Orleans, La.: Room 225-A, Customhouse. 

New York, N.Y.: 734 Customhouse. 

Norfolk, Va.: 406 East Plume Street. 

Philadelphia, Pa.: 422 Commercial Trust Building. 

Pittsburgh, Pa.: Chamber of Commerce Building. 

Portland, Oreg.: 215 New Post Office Building. 

St. Louis, Mo.: 506 Olive Street. 

San Francisco, Calif.: 310 Customhouse. 

Seattle, Wash.: 809 Federal Building. 
Approved Code No. 71 

CODE OF FAIR COMPETITION 

FOR THE 

PAINT, VARNISH, AND LACQUER MANUFACTURING INDUSTRY 

As Approved on October 31, 1933 

BY 

PRESIDENT ROOSEVELT 

EXECUTIVE ORDER 

An application having been duly made, pursuant to and in full 

compliance with the provisions of Title I of the National Industrial 

Recovery Act, approved June 16, 1933, for my approval of a Code 

of Fair Competition for the Paint, Varnish, and Lacquer Manufacturing Indu try, and hearings having been held thereon and the 

Admjnistrator having rendered his report containing an analysis of 

the said code of fair competition together with his recommendations 

and findings with respect thereto, and the Administrator having 

found that the said code of fair competition complies in all respects 

with the pertinent provisions of Title I of said Act and that the 

requirements of clauses (1) and (2) of subsection (a) of Section 3 

of the said Act have been met: · 

NOW, THEREFORE, I, Franklin D. Roosevelt, President of the 

United States, pursuant to the authority vested in me by Title I of the 

ational Industrial Recovery Act, approved June 16, 1933, and otherwi e, do adopt and approve the report, recommendations, and findings of the Administrator and do order that the said code of fair 

competition be and it is hereby approved. 

FRANKLIN D. ROOSEVELT. 

Approval recommended: 

HUGH S. JOHNSON, 

Administrator. 

THE WRITE H ousE, 

October 31, 1933. 

62870°-482- 121- 34 (169) 
REPORT TO THE PRESIDENT 

The PRESIDENT, 

The White House. 

Sm: This is a report of the hearing on the Code of Fair Competition for the Paint, Varnish, and Lacquer Manufacturing Industry 

conducted in Washington on the 26th of September, 1933, in accordance with the provisions of the National Industrial Recovery Act. 

ECONOMIC EFFECT OF THE CODE 

Paint is a manufactured product used in part for new production 

of industrial and consumers goods, and in part as a maintenance 

material. The quantity required for the former purpose bears a 

positive relation to general manufacturing activity. For the latter 

purpose, where the need may be deferred, the current financial condition of the owner of the property has considerable bearing _upon 

the quantity of paint used. For this latter purpose also the cost of 

the paint is a factor of considerable importance. 

The quality of paint in general may be judged by the effectiveness of the covering produced, either as protection or appearance, or 

both, and the life of that covering. These qualities are not only a 

function of the ingredients of the paint, but also are a function of 

the method of preparation of the ingredients and their mixing. It 

is possible, therefore, to produce paint of varying degrees of quality 

through a wide scale of costs, and the public is not necessarily in a 

position to judge quality other than by price. As a consequence of 

this condition, many practices involving the sale of cheap paint have 

grown up in the Industry, which, coupled with the financial situation 

of the last few years, has tended to cause demoralization. 

The Code, as submitted herewith, contains in Part Two an unusual number qf trade practices which are considered detrimental to 

the Industry and consequently are prohibited. In the form in which 

they now stand they meet the approval of the Consumers' Advisory 

Board. 

The provisions contained in this Code as to minimum wages and 

maximum hours are generally in line with approved codes employing labor of the same quality and under similar conditions. 

The reduction in the number of hours from 47.5 of June, 1933, to a 

maximum of 41.2 average for a six months' period provided by the 

Code will mean an increase in employment of approximately 25 percent. It is estimated that at the low point of employment there were 

approximately 18,000 workers in early 1933, and that the provisions 

of this Code, even under present conditions, should increase the 

number employed to nearly 25,000. 

The wages set up in the Code will increa e the pay of only about 

20 percent of the workers in the Northern area and 30 percent of the 

(170) 
171 

workers in the Southern area, but the resulting (increase in purchasing power, when coupled with the increase in number of workers in 

the Industry, will be material. 

FINDINGS 

The Administrator finds that-

(a) · The Code as recommended complies in all respects with the 

pertinent provisions of Title I of the Act, including, without limitation, subsection (a) of Section 7 and subsection (b) of Section 10 

thereof; and that 

(b) The applicant group imposes no inequitable restrictions on 

admission to membership therein and is truly representative of the 

Paint, Varnish, and Lacq-a.er Manufacturing Industry; and that 

( c) The Code as recommended is not designed to promote monopolies or to eliminate or oppress small enterprises and will not 

operate to discriminate against them and will tend to effectuate the 

policy of Title I of the National Industrial Recovery Act. 

It is recommended, therefore, that this Code be immediately 

adopted. 

Respectfully, 

OCTOBER ~7, 193:1. 

HUGH s. JOHNSON' 

Adminwtrator. 
CODE OF FAIR COMPETITION FOR THE PAINT, VARNISH, Ar D LACQUER 11A UFACTURI.r G INDUSTRY 

ARTICLE I-PURPOSE 

For the purpose of effectuating the policy of Title I of the Act of 

June 16, 1933, known as the National Industrial Recovery Act1 the 

following provisions are established as a Code of Fair Competition 

for the Paint, Varnish, and Lacquer Manufacturing Industry. 

ARTICLE II-DEFINITIONS 

The term "The Industry" means all persons in the continental 

Unit.ed States engaged in the manufacture of paint, kalsomine and 

water paint, varni h, including hellac varnish lacquer, and kindred 

products, including putty, semi.finished base materials for lacquers, 

thinners, and diluents ( when such semifinished base materials are 

sold or offered for sale in competition with the finished products of 

this Industry), liquid and pla tic roof coating and roof cements, and 

artists' colors; and/or such branches or ubdivisions thereof as may 

from ti1ne to time be included under the provisions of this Code, 

provided that if any member of the Indu try also manufactures products of any other industry, the provi ions of this Code shall apply 

only to that part of hi busine s which is included in this Code. 

The term "Export Trade" means any business transacted with any 

purchaser for shipment of products of the Indu try outside of the 

continental United State . . The term "employee" as used herein include any person engaged 

in any phase of the Industry in any capacity in the nature of em- ployee irrespective of the method of payment of his compensation. 

The term" employer" as used herein includes anyone for whose benefit uch an employee is so engaged. The term "member of The 

Industry" include any manufacturer who shall be subject to this 

Code. The term " member of the Code" include any member of The 

Industry who shall expressly signify assent to this Code. The term 

"Association" herein me.ans the American Paint and Varnish Manufacturer ' Association Inc., and the National Paint Oil and Varnish 

Association, Inc., or their succe or or successors. The term "Association Headquarters" means the office maintained jointly by the As- . ociations at 2201 ew York Avenue, N"\V., "\Vashington, D.C. The 

term" Trade Sales" as used herein means all sales to jobbers, dealers, 

painters, automotive refini hing shops, and ~a.le made directly to the 

con. umer, with the exception of such sales as are hereinafter defined 

as "Industrial Sales." The term "Industrial Sales" as used herein 

means all sales to the following classes of bu3 ers, covering products 

of The Industry used by uch buyer on their products or for the 

finishing of their equipment and for the painting, upkeep, and 

(172) 
173 

maintenance of their plants, equipment, tenements, and for any otherpurpose. 

Industrial plants of all kinds (such as automobile manu:fac-- turers, implement manufacturers, furniture manufacturers, 

etc., etc.) 

Transportation companies (including street railways, bus, and 

air transportation companies) 

Car and locomotive builders 

Public service companies 

Oil refiners and pipe-line companies 

Packing houses 

Steel manufacturers and those who :fabricate their own products 

Bridge builders and bridges 

Coal or other mining operations 

Steamship lines, shipyards, wharves, and docks 

All departments of any State, County, ~1unicipal, or other 

political subdivi ions, but only for the following products: 

traffic paint; road paint; products used on bridges, trucks, 

and machinery; automobile license tag coatings; or materials :for finishing :furniture, or any other products manufactured in prisons or reformatories. All other business 

from State, County, ~1unicipal, and other political subdivisions, such as products u ed on buildings, institutions, etc., 

to be classified as "Trade Sales." 

All Departments of the United States Government, regardless 

of usage. 

ARTICLE III-INDUSTRY LAW .AND EFFECTIVE DATE 

On and after the fifteenth calendar day after the President of the 

United States shall have approved this Code, the provisions hereof 

shall constitute standards of fair competition :for The Industry and 

shall be automatically binding upon all members of The Industry, 

except that all articles of this Code which are included in Part 2 

hereof shall not apply to export trade. 

ARTICLE IV-COLLECTIVE BARGAINING 

In accordance with Section 7 (a) of the Act of June 16, 1933, 

known as the National Industrial Recovery Act, it is agreed: (1) that 

employees shall have the right to organize and bargain collectively 

through representatives of their own choosing, anq shall be free from 

interference, restraint, or coercion of employers of labor or their 

agents, in the designation of such representatives or in self-organiza- tion or in other concerted activities for the purpose of collective 

bargaining or other mutual aid or protection; (2) that no employee 

and no one seeking employment shall be r equired as a condition of 

employment to join any company union or to refrain from joining, 

organizing, or a sistino- a labor organization of his own choosing; 

and (3) that employers shall comply with the maxin1um hours of 

labor, minimum rate of pay, and other conditions of employment 

approved or prescribed by the President. 
174 

ARTICLE V-MINil\IU M w AGES AND 1\-fAXIl\IUM HOURS 

(a) No employee engaged in accounting, clerical, office, or delivery 

service in any office or in any other place or manner, excepting employees in retail stores and excepting outside salesmen, shall work or 

be permitted to work in excess of 40 hours per week for 20 weeks 

and 48 hours per week for 6 weeks in any 26-week period. 

(b) No factory or mechanical worker or artisan shall work or be 

permitted to work more than 40 hours in one week nor more than 8 

hours in any one day; provided, however, that during any 6 weeks 

of a 26-week period (the first period to begin on the effective date 

of this Code) employees may work not more than 45 hours a week 

nor more than 9 hours in any one day, with the exception of (1) 

supervisory staff (including foremen), (2) maintenance workers, 

engineers, and firemen, which excepted employees may not work in 

excess of the maximum hours stated above except by payment of one 

and one-third rate for overtime if such employees are compensated 

on an hourly basis. Each week during any 26-week period shall be 

considered as a complete unit of employment for the purpose of paying for overtime to excepted employees. If an excepted employee on 

an hourly basis works more than 40 hours and not more than 45 

hours in any one week, the employer shall compensate him at the end 

of said week for the hours worked in excess of 40 hours at the extra 

rate or shall declare to the employee that such week will be considered 

as one of the 6 weeks in which a maximum of 45 hours is permitted. 

This does not, however, mean that an excepted employee, when necessary, may not work more than 45 hours at the extra compensation. 

If such excepted employees are paid by the week, month, or on a 

yearly basis and enjoy vacation periods, sick leaves, and other benefits 

granted to salaried workers they shall not be paid an additional 

amount for any reasonable overtime work. 

( c) The maximum hours fixed in the foregoing Paragraphs (a) 

and (b) shall not apply to watchmen, janitors, or other caretakers; 

nor to employees in a managerial, executive, or other capacity who 

receive $35.00 per week or more; provided that with respect to the 

.exceptions in this Paragraph and in Paragraphs (a) and (b) of this 

Article there shall be no evasion of this Code by reclassification of 

it.he function of workers. A worker shall not be included in any one 

of the above exceptions unless the identical functions which he 

performs were identically classified on June 16, 1933. 

( d) The provisions for maximum hours set forth in Paragraphs 

(a) and (b) of this Article establish a maximum number of hours of 

labor per 26-week period for each employee so that under no circum-

-stances shall any employee knowingly be employed or permitted to 

work for one or more employers in The Industry in the aggregate 

in excess of the prescribed number of hours. (e) Employers in The Industry, subj ect to the exception provided 

in Paragraph (h) of this Article, shall not pay any of the classes of 

€mployees covered by Paragraph (a ) less than $15 .00 per week in any 

-city of over 500,000 population, or in the immediate trade area of 

such city; nor less than $14.50 per week in any city of between 250,000 

and 500,000 population, or in the immediate trade area of such city; 

nor less than $14.00 per week in any city or town of less than 250,000 
175 

population, or in the immediate trade area of such city or town; 

provided that employers in The Industry may pay to any class of 

employees covered by Paragraph (a) who perform the work of office 

boys and office girls, not less than 80 percent of the minimum wage 

de ignated by this Paragraph, provided that the number so excepted 

shall not exceed 5 percent of the total Pmployees of the employer and 

provided, further, that each employer may have at least one such 

employee. Population for the purposes of this Code snall be determined by reference to the 1930 Federal Censns. 

(f) Employers in The Industry, subject to the exception provided 

in Paragraph (h) of this Article, shall not pay any employee of the 

classes covered by P aragraph (b), or employees excepted therein, 

namely, supervisory staff (including foremen), maintenance workers, 

engineers, and firemen, less thi:i.,n 40 cents per hour to male employees, 

or less than 35 cents per hour to female employees. The foregoing 

distinction in minimum rates between male and female employees is 

not a discrimination by reason of sex but because of a difference in 

the work done. Where female employees do the same kind and 

amount of work as male employees they shall receive the same wages. 

It is agreed that this Paragraph establishes a guaranteed minimum 

rate of pay regardless of whether- the employee is compensated on 

the basis of a time rate or on piecework performance. 

(g) The provisions of Paragraphs ( e) and (£) of this Article 

shall not apply to any employee partially incapacitated through age 

or otherwise, who has served not less than 10 years in the continuous 

employment of the employer, provided that the number so excepted 

shall not exceed 5 percent of the total employees of the employer, and 

provided that each employer may have at least one such employee, 

and provided further that the minimum wage paid to such employee 

shall not be less than 30 cents per hour. 

(h) Employers in The Industry shall not pay less than 90 percent 

of the minimum wages provided in Paragraphs ( e) and (f) of this 

Article, to employees in the Southern states. For the purpose of this 

Article, the Southern States are defined asAlabama North Carolina 

Arkansas Oklahoma 

Florida South Carolina 

Georgia Tennessee 

Kentucky Texas 

Louisiana Virginia 

Mississippi 

(i) No person under the age o:f 16 shall be employed 1n The 

Industry. · 

ARTICLE VI-PRESIDENTIAL AUTHORITY 

As required by Section 10 (b) of Title I of the National Industrial Recovery Act, the following provision is contained in this 

Code: The President may from time to time cancel or modify any 

order, approval, license, rule, or regulation issued under Title I 

thereof. 

62870°--482--121-34-2 
176 

ARTICLE VII-1\IoNOPOLIES 

No provision in this Code shall be interpreted or applied in such 

a manner as to: (1) Promote monopolies; (2) Permit or encourage 

unfair com petition; ( 3) Eliminate, opp res , or discriminate against 

small enterprises. 

ARTICLE VIII-STATE LA ws 

Within each state, members of The Industry shall comply with 

any laws of such state imposing more stringent requirements, regulating the age of employees, wages, hours of work, or general working 

conditions, than under this Code. 

ARTICLE IX-REPORTS 

The Paint Industry Recovery Board, through Association Headquarters, shall collect and provide all reports required by the Administrator under the National Industrial Recovery Act. Every member 

of The Indu try shall furnish such reports as are required pursuant 

to such requirements. 

In addition to information required to be submitted through the 

Paint Industry Recovery Board, there shall be furnished to govern -

ment agencies such statistical information as the Administrator may 

deem necessary for the purpose recited in Section 3 (a) of the 

National Industrial Recovery Act. 

ARTICLE X-ADl\IINISTRA TION 

After this Code shall have been approved by the President of the 

United States, it shall be administered through the Association by a 

board to be immediately created and to be known as the " Paint 

Industry Recovery Board." 

This Board shall be composed of the following members: Not 

more than 3 members without voting power to be appointed by the 

President, the 8 members of the present General Code Committee, 

20 members, representing commodity groups, 20 members representing comm uni ties. 

The members of the Board representing commodity groups shall 

be elected as follows: 5 member to be elected by paint manufacturers, 5 members to be elected by varnish manufacturer , 5 members 

to be elected by lacquer manufacturer , 5 member to be elected by 

kal omine and water-paint manufacturers. 

Provided that each of these groups shall contain 2 members from 

the Eastern State , 1 member from the State in or west of the Rocky 

Mountains and 2 members from the remaining States. Nominations 

for election to the Board for said Commodity groups shall be made 

by member of The Industry at large, regardless of membership in 

any a sociation, and the nominations so made shall be submitted to a 

mail vote of all members of The Indu try throughout the United 

States and those receiving the highest number of votes in each Group 

shall be declared to have been elected to represent the Commodity 

groups. The members of the Board repre enting communities shall 

be elected in the following manner: 1 each to be elected by the members of The In lustry doin<Y busine in the logical trading areas of 

the following citi , which manufacturer hall be called together for 
177 

the purpose of such election by the President of the Local Paini 

lub, or local paint manufacturers' association if any such exists: 

Atlanta-New Orleans l(ansas City 

Baltimore Los Angeles 1 

Boston Louisville 

Ruffalo :Minneapolis-St. Paul 

Chicago New York 

Cincinnati Philadelphia 

Cleveland Pittsburgh 

Dallas-Houston St. Louis 

Denver San Francisco 

Detroit Seattle-Tacoma-Portland 

No person shall be eligible for membership on this Board who is 

not directly engaged in the manufacture of products of The Industry, except the members to be appointed by the President of the 

United States. Furthermore, no company or group of affiliated companies shall have more than one representative on this Board. 

Vacancies which may occur in the Board for any reason whatsoever 

shall be filled by election in the same manner as hereinbefore provided. This Board, subject to the approval of the Administrator 1 

shall elect its own Chairman, adopt its own rules of procedure (not 

in conflict with any other provisions herein contained), appoint such 

committees as may to it seem necessary from time to time, and may 

delegate its authority to such committees. A majority of the Board 

shall have the power to recommend to the Administrator for his 

approval the addition of representatives of other groups or com- munities to its membership; provided that such additional members 

shall be elected in the same manner as above described. 

The staff, Association Headquarters, and other facilities of the 

Association shall be employed in carrying out the work of the 

Paint Industry Recovery Board. Such funds as may be required for 

the work of this Board shall be subject to appropriation by the 

Budget and Finance Committee of the Association. All members 

of the Industry or groups thereof who qualify as such under this 

Code are eligible to membership in the American Paint & Varnish 

Manufacturers' Association, Inc., or its successor, without payment 

of initiation fee, which has been temporarily waived. If group 

membership, such groups hall pay into the Treasury of the American Paint and Varnish Th1anufacturers' Association, Inc., a total 

amount equal to the dues of each member of such group as if each 

member were a direct member of the American Paint and Varnish 

Manufacturers' Association, Inc. If for any reason an eligible manufacturer doe not desire to join this Association he may, nevertheless receive all of its benefits, including participation in this Code, by 

paying a fee to its Treasurer equal to the due , provided that should 

any member of this Code desire not to become a m mber of the Association and desire not to pay to its Trea urer a um equal to the 

dues he shall nevertheless pay his proportionate share of the 

amounts required to pay the co t of assembly, analy is and publication of necessary reports and data and of the maintenance of this 

administrative authority and its activities and the Paint Industry 

Recovery Board shall a sess each such member of the Industry with 

his proportionate share based upon the value of sales or otherwise 
178 

as the Paint Industry_ Recov~ry Board may prescribe, subject to the 

approval of the Administrator. 

The Paint Industry Recovery Board shall have full responsibility 

for its expenditures within the limits of such appropriations as are 

made from time to time, provided that no traveling or other expenses of Board members shall be paid out of the Association funds 

when attending Board meetings, but actual expenses of members of 

the Board when engaged in the business of the Board, other than 

attendance at Board meetings, may be paid out of such funds provided prior authority for such expenditure or expenditures has been 

given by the Board. 

ARTICLE Xl-Al\IEND~IENTS 

Such of the provisions of this Code as are not required to be included therein by the National Industrial Recovery Act of June 16, 

1933, may, with the approval of the President, be modified or eliminated as changes and circumstances or experience may indicate. It 

is contemplated that from time to time supplementary provisions to 

this Code will be submitted for the approval of the President to 

prevent unfair competition in price and other unfair and destructive 

competitive practices and to effectuate the other purposes and policies of Title I of the National Industrial Recovery Act, consistent 

with the provisions hereof. :Members of The Industry or a local 

paint manufacturers' association, if any such exists, shall submit 

desired amendments of this Code to the Paint Ind1!Btry Recovery 

Board through Association Headquarters. By agreement of a majority of the Board, an amendment, so received or one initiated by 

the Board itself, shall be referred to The Industry in the following 

manner: those members of the Board who represent the commodity 

groups shall submit the proposed amendment to their respective 

groups, if in their opinion it is germane to the interests of such 

groups; those members of the Board who represent manufacturers 

from the several cities shall call meetings of the manufacturers in 

their communities. The several Board members shall then submit 

individual reports to Association Headquarters, which shall collate 

them and submit a full report to the Board. Thereafter the Board 

shall vote on submitting the Amendment to the Government and 

shall o submit it if at least two-thirds of the Board vote to do so, 

provided that the proponent of any amendment shall have the right 

to submit such amendment direct to the National Recovery Administration for its consideration. 

By presenting this Code the members of The Industry do not 

thereby consent to any modifications thereof and reserve the right 

to object individually or jointly to any such modifications. 

PART 2-TRADE PRACTICES 

ARTICLE XII-MISBRANDING MrsL.d.BELL -a, AND FALSE ADVERTISING 

:Misbranding, mislabeling, and false, deceptive, and misleading advertising are prohibited by this Code. 
179 

ARTICLE XIII-GIFTS TO EMPLOYEES OF ANOTHER 

It shall be a violation of this Code for any person engaged in The 

Industry, to offer or give-or to permit any representative of his to 

offer or give- any commission, gratuity, or other thing of substantial 

value to employees of his customers or prospective customers, except 

in the case of payments made with the consent of the employer for a 

definite service rendered. 

ARTICLE XIV- MANUFACTURING RESTRICTIONS 

It shall be a violation of this Code for any manufacturer to fail 

to abide by the manufacturing restrictions as set out in Schedule 

A which is attached hereto and made a part of this Code, provided 

that this Article shall not apply to export trade and provided further that Paragraphs 2, 4~ 5, and 6 of Schedule A shall not apply 

to products commonly known as 5-, 10-, and 25-cent merchandise 

which is sold at retail to the consumer at not more than 25 cents per 

package. 

ARTICLE XV-ExcHANGE OF Goons 

The practice of taking in exchange for one's own goods, Industry 

products of another manufacturer, distributor, or dealer, is unethical, unfair, and is hereby prohibited. It shall be a violation of 

this Code for any manufacturer in the Industry to take or allow to 

be taken in exchange for his own products, any products of the 

Industry, or to give or permit the giving of any advice or assistance 

in facilitating such exchange or replacement, or to make or permit 

to be made any concessions, allowances, or gifts of any kind to 

promote or facilitate such exchange. 

Every member of the Industry is required to enter into a written 

agreement with his jobbers and/or distributors whereby such job- bers and/ or distributors agree to refrain from the practice prohibited 

by this Article. I t shall be a violation of this Code for any member 

of the Industry to deal or continue to deal with any jobber and/ or 

distributor who shall have acted contrary to such agreement, provided that no member of the Industry shall be held responsible for 

such dealings as he may have engaged in prior to the time he has 

received notice of the breach of such agreement by a jobber 

and/ or distributor, and provided that no member of the Industry 

hall be held responsible for such dealings after the Paint Industry 

Recovery Boa:r:d has given approval for further dealings with a 

jobber and/ or distributor who may have violated such an agreement. 

The Paint Industry Recovery Board may require each member of 

the Industry to file a copy of each agreement which he may make 

with a jobber and/or distributor. 

ARTICLE XVI-STANDARD TERMS OF CASH DISCOUNT 

On and after the effective date the terms granted by manufacturers, excluding export trade, shall not exceed: Trade sales accounts, 2 percent for cash in 10 days, net 60 days; industrial sales accounts, 1 

percent for cash in 10 days, net 30 days; except that the discount to 
180 

trade ales account may be extended to the 10th day of the month 

following purcha e and he discount to indu trial ales accounts may 

be extended to the 20th day of the month following purcha e to cu - tomer who regularly di count in the month following purchase, and 

provided that no di count shall be allowed after the discount date. 

ARTICLE ...t.rVII-DATINGS 

Except as specifically provided by this Article, members of The 

Industry shall not grant any datings on the ales of any Indu try 

products. 

(a) Spring Stock Orders.-Datings on orders to established dealer 

and/or jobber accounts, excluding export trade, shall be limited to 

datings op Spring Stock Orders shipped at the manufacturers conYenience after October 15, with an April 1 dating and regular terms; 

one order to an account. 

(b) New Accounts.-The maximum dating on trade sales stock 

orders (initial stock order only) to new dealer and/or jobber account excluding export trade shall be limited to four months fro1n 

the date of shipment and with standard terms provided that orders 

shipped between October 15 and December 1 in any year may be with 

an pril 1 dating and with regular terms. 

(c) Roof Coatings and Cem,ents.-A maximum dating of four 

months may be given on a carload of not less than 40,000 lb . of 

liquid and plastic roof coatings and/or roof cements, not including 

other products, whenever the lowe t published le -than-carload 

freight rate (by rail or water) is more than 50 cents per cwt. ( d) Anticipated Discount.-If any dating shall be permitted 

under this Article, an anticipated di count may be allowed to the 

extent of one-half of one percent a month. 

ARTICLE XVIII-GuARA TEES 

(a) Price Gua1·antees.-Guarantees against price decline shall be 

prohibited except in the ca e of an order on which a dating ha been 

allowed under Article XVII when such a price guarantee may be 

given for a time not to exceed the dating period granted. 

(b) Time Guarantees.-Definite time gua rantees on the life and/or 

ervice of the product of The Indu try are hereby prohibited. 

ARTICLE XIX-CoxsrnNMENT 

The pra tice of supplying accounts on con ignmerit and/or tru t 

certificate aareement , except a hereinafter provided, is prohibited. 

Thi al o includes consignments which are ometimes made under 

so-called "warehouse agreements" but doe not prohibit manufacturer from carrying a stock of their good in a public or priYate 

warehou e at their own expense in any section of the United States, 

provid d that u h tocks must not be warehou ed , ith or for the 

account of any per on firm, or corporation dealing in or handling 

(a , a merchant) or using (a a painter) product of the indu try. 

Every manufacturer who ha an3 such c n i o-nment tocks in the 

hand of buyers on the effecti,e dat of thi Code may continue the 
181 

same but he shall file a detailed list of such accounts within 60 days 

of the effective date of this Code with Association Headquarters 

and/ or the office of a local paint manufacturers' association, if any 

such exists, where reference may be made to it at any reasonable time 

by interested parties. Until such time as an account as listed above 

is discontinued, such accounts may Le similarly supplied by any 

manufacturer in the Industry. The Paint Industry Recovery Board 

shall, subject to the approval of the Administrator, develop such 

rlans as will effectuate the ultimate elimination of consignments 

from the Industry. This Article shall not apply to export trade. 

ARTICLE XX-FREE DEALS 

Except as otherwise provided herein, free deals in or connected 

with Industry products are prohibited. "Free deals" for the purpose of this Code means all forms of marketing devices, including 

the gift or loan of spraying or other valuable equipment, whether 

the full cost thereof or only a part of said cost is borne by the manufacturer, whereby the said manufacturer furnishes goods of any kind 

other than such of his own products as have been contracted for on 

his usual terms : Provided that the term " Free Deals " shall not 

apply to the furnishing of advertising accessories of small value 

such as the usual circulars, color cards, window displays, display 

racks, and posters which accompany paint and varnish products as a 

description thereof, nor shall it apply to novelties of small value such 

as caps, yardsticks, paddles, etc. 

Furthermore, the term "Free Deals" shall not be construed to 

include any advertising allowance which is made for a definite service rendered and for which there is a proper accounting that is auditable as !-'I. direct charge for cooperative advertising. 

Illustrative of the practices which are prohibited are included the 

following: 

(a) Premiums (gifts of unrelated merchandise) such as blankets, 

articles of furniture , etc. 

(b) Prizes and awards. This does not refer to prizes and awards 

gfren within a manufacturer's own organization. 

( c) Free Goods ( extra amounts of one's own products). 

( d) Merchandising practices of the type commonly known as 

" One-cent sales." 

( e) Free Samples. (But the term "Free Deals" does not apply 

to samples given for test purposes; neither does it apply to trade-sale 

samples given for demonstration purposes, provided that no size 

larger than 5-lb. samples of water-paint goods in dry form or 1/32 

gallons of other industry products shall be so used and that such 

samples are plainly labeled "Samples.") 

(f) The sale of alcohol, turpentine, linseed oil, or any other products not manufactured by The Industry at prices less than the resale 

market price. 

ARTICLE XXI-DiscoNTINU ANCE OF SHADES AND CoLoRs 

,vhen it becomes necessary and advisable £or any manufacturer to 

discontinue certain shades or colors in any· trade-sales line, he shall 

give his dealer and/ or jobber customers who purchase such lines six 
182 

months' advance notice prior to discontinuing the manufacture of 

such shades or colors, providing that this Article shall not apply to 

export trade. 

ARTICLE XXII-SELLING BELOW CosT 

Products of The Industry shall not be sold at less than cost as 

herein defined: 

(1) The cost of Lacquer Thinners in full tank cars or tank wagons 

containing not less than one thousand-gallon quantity, when sold and 

delivered to one purchaser, shall be not less than the sum total of the 

current market replacement price of each and every ingredient in the 

completed Thinner. 

The cost of all other products shall include the following: 

(2) The seller's total market replacement cost of raw materials 

(based on cost furnished monthly, or oftener if necessary, by authority of the Paint Industry Recovery Board through Association Headquarters, subject to approval by the Administrator) ; and if anv raw 

materials are used (such as varnishes, japans, driers, etc., purchased 

in finished form by the seller) for which costs are not furnished 

monthly or oftener, as herein provided, the cost used for such item 

or items shall be the seller's total current delivered replacement cost. 

(3) Containers and/or packages. 

(4) Oost of Processing.-To include all direct costs (such as power 

and labor), depreciation figured in accordance with provisions of the 

Federal Income Tax laws, plus a proper proportion of all indirect 

factory expenses ( excepting interest on investment), in accordance 

with the share each product should bear, provided that the distribution of indirect factory expense per unit of production shall be on 

the basis of the average rate of utilization of plant facilities of profit 

making producers during the years 1928 to 1932 inclusive, and provided that such average rate shall not include any plants not in 

operation. 

( 5) There shall also be included in the cost a proportion of the 

general and administrative expenses, such proportion to be determined and to be recommended by the Paint Industry Recovery Board 

to the Administrator for approval. 

(6) Transportation charges when goods are sold f.o.b. destination. 

In the case of any complaint by an interested party that a manufacturer is violating the above cost provisions the burden of proof of 

compliance shall rest upon the accused manufacturer. If the Code 

Authority or the Administrator is not satisfied by the proof furnished 

by the defendant manufacturer the matter is to be referred to the 

Federal Trade Commission who shall audit the cost accounting of 

the defendant and review his allocation of burden; an..d the report 

of that Commission shall be final regarding the costs of the defend-

.ant manufacturer. 

ARTICLE XXIII-CoMPETITIVE RELATIONS 

(a) Inducing Breach of Oontract.-No manufacturer either directly or indirectly or through his salesmen, representatives, or 
183 

agents, shall encourage any purchaser of the products of The Industry to disregard or fail to live up to his commitment to another 

member of the Industry. . (b ) Disparagernent of 001npetitors.-The use of or participation 

in the publishing or the disseminating of any false statement, representation or insinuation which disparages the business of a competitor, or attacks the reputation, goods, prices, credit, service, or advertising of any competitor or of any other industry, is an unfair and 

uneconomic practice and is prohibited. 

( c) Enticing Employees.-Members of The Industry shall recognize the right of employees to use all honorable and reasonable efforts 

to better their conditions, but shall refrain from directly or indirectly 

soliciting or bidding for the services of the employee of another 

member. Only when such an employee takes the initiative shall a 

member of The Industry have the right to negotiate with him about 

prospective employment. 

ARTICLE XXIV-RETURNED Gooos 

No member of The Industry shall accept the return of merchandise from any customer without having given prior consent to the 

return thereof. On such goods as are accepted for return a reasonable charge shall be made and the freight charges must be charged 

to the shipper returning the merchandise, except in the case of defective products or where in some other way the manufaci:ure1.· u.121,y 

be responsible. 

ApprovPd Code No. 71. 

Registry No. 619/ 1/ 03. 
SCHEDULE A 

Manufacturvng Restrictions.-Industry products, excepting those for export 

trade, shall not be manufactured for the purpose of marketing them as trade 

sales goods in containers of sizes and type prohibited by this rule, nor shall 

they be produced in tints or shades to a greater number than allowed by this 

rule, subject to Article XXI hereof, provided that Paragraphs 2, 4, 5, and 6 

hereof shall not apply to product commonly known as 5-, 10-, and 25-cent 

merchandise which is sold to the consumer at not more than 25 cents per 

package. 

1. (a) o two-pound cans in any line, except floor wax. 

(b) No three-pound can in any line. 

2. (a) o ize le s than quarter-gallon in barn and roof paint. 

( b) o ize les than gallon can in bingle tain. 

3. o half-gallon can in the following product : Aluminum paints, barn 

paints, roof paint , auto-top dre ing, wagon and carriage paints and enamels, 

oil stains, pirit tain , and ,arnLb stain--. 

4. o half-pint can in first-grade house paint . 5. o half-pint can in fir t-grade fia t paint . 6. o quarter-p·nt cans in all bou e paint and fiat paint. 

7. o oblong or quare varni h can~ in ize smaller than one-half gallon 

for any product, excepting bellac varni be , carriage and automotive finishes 

( clear and colors), lacquers, lacquer thinner , liquid wax, liquid poll h, varnish 

remover, bronzing liquid, Japan and Liquid drier , penetrating stains and spirit 

stains. 

8. No shades or tints in excess of the following maximum numbers for each • 

brand and/or color card: 

Interior floor paints and floor enamels_____________________ 10 House Paints ____________________________________________ 32 

Flat Wall Paint ----------------------------------------- 20 

Enamel------------------------------------------------- 1 Porch Paints_____________________________________________ 8 

Roof and Barn Paint ----------------------------------- 4 

Shingle Stain ------------------------------------------- 14 

Wagon and Carriage Paint or Enamel ------------------- 10 

Oil Stain----------------------------------------------- 10 

Varnish Stain------------------------------------------ 8 

Spirit and Penetrating tain ----------------------------- 14 

(All the fore oino- exclu fre of black and white) Oil Colors _______________________________________________ 32 

(Including black, but counting the several shades of a 

single color a one color.) 

8. {a) The maximum number of grade for the following products hall be: 

Architectural and l\Iarine Varni he ___ ------------------- 10 

(Interior and exterior) Other Varni hes _________________________________________ 28 

(Inc:ludino- all not pre,iously pecified, such as Japan 

Driers, Asphaltum, etc.) 

9. No oil color in other than liquid mea urn or in other than three ize , namely, o-allon , quart , and half-pint . with th exception f tube , and e:s: ept- ing al o gla jar wh n old as a part of a ale unit with white bive paint 

to b , tinted ,,..ith . uch color in oil in gla jar to tandar 1 color , which ales 

unit bas b en spe ·ially developed for thi purpose by th manufacturer. 

(1 4) 
185 

Manufacturing Restrictii<>ns for Kalsornine and Water Palints.-10. No shades 

or tints in excess of the following numbers for each color card: 

*Kalsomine (Hot Water)_________________________________ 20 

*Kalsomine (Cold Water) _________________________________ 20 

Water Paint, interior non-washable _______________ White only 

Exterior water-mixed paints washable paste and powder form __________________________________________________ 20 

Interior Water-Mixed Paints washable paste and powder form __________________________________________________ 20 

Fresco or Positive, Art or Deep Colors___________________ 20 

Plastic Paints___________________________________________ 8 

Cement and/or Lime Water Mixed Paint_________________ 16 

11. Kalsomine (Hot or Cold) in the following sizes only: Barrels weighing 

not less than 300 lbs. net, except for the Pacific Coast, where the 280 lb. barrel 

is authorized; kegs containing 100 lbs. net weight; 25 lb. net weight packages ; 

5 lb. net weight containers. 

( Existing contracts covering Kalsomine in containers differing in wei~ht 

content from standards covered herein shall be completed prior to December 

31, 1933, provided that should a purchaser, now under contract with a manufacturer extending beyond that date, decline to accept a readjustment of his 

contract to bring the packages into line with these provisions, the manufacturer party to the contract shall refer the matter to the Paint Industry 

Recovery Board prior to December 31, 1933, for such amicable adjustments as 

the Board may be able to work out with the parties at interest.) 

12. Interior Cold Water Paint, powder form, nonwashable. Barrels weigh- ing not less than 350 lbs. net, 25 and 100 lb. containers, 5 lb. net weight 

containers; to be made in White only. 

13. Plastic or Texture Paints (Dry), in the following sizes only: 5, 10, 25, 

50, and 100 lb. net weight containers and not less than 300 lb. net weight 

barrels. 

Paste form in same size containers as F'irst Grade Flat Paints. 

14. Patching Plaster to be sold in sizes a s now marketed. 

15. Interior and Exterior Water-Mixed Paints, Washable, in the foll owing 

sizes only: 

(a) Dry Powder F'orm.-5 lb., 25 lb., and 100 lb. containers; barrels of 300 

lbs. net, or more. 

(b) Paste Form.-1 quart, 1 and 5 gallon cans and 30 gallon drums. 

16. Cement and/or Lime Bound Water Mixed Paints in the followin(T sizes 

only: 5 and 10 lb. containers, 50 and 100 lb. containers, barrels of 300 lbs. net, 

or more. 

17. Fresco Colors (Positive, Deep, or Art Colors) to be packed in the following sizes only : 

(a) Powder F'orm.-1 lb. cartons or cans, 25 and 100 lb. containers, Barrels 

or 300 lbs. net or more. 

(b) Paste Form.-To be packed in 1⁄2 pint, quart, and 1 gallon cans only. 

18. Dry Sizes, Water-Mixed. To be packed in the following sizes only: 

1 lb. cartons, 100 lb. containers, and 300 lb. Net Barrels, or more. 

• Means material commonly known and described by this term. 
AMENDMENTS TO CODE OF FAIR COMPETITION FOR 

THE PAI T, VARNISH AND LACQUER MANUFACTURING INDUST:RY 

AMENDMENT 1. Article II is amended by the addition of the following between the first and second paragraphs: 

"The term 'Artists' Colors' means artists' oil colors, or artists' 

paints, water colors including poster and showcard colors, tempera 

colors, and artists' pastels, prepared canva es and panels, artists' 

mediums and varnishes, artists' drawing and lettering inks, artists' 

block printing inks of oil or water base, charcoal, modelling tools and 

all types of artists' woodenware, such as easels, palettes, color boxes, 

and such kindred materials and articles ordinarily used in schools 

and by art students, artists, commercial artists, etchers, modellers, 

sculptors and craftsmen." 

AMENDMENT 2. Article V, Section ( c) is amended to read as 

follows: 

" The maximum hours fixed in the foregoing Paragraphs (a) and 

(b) shall not apply to watchmen, janitors or other caretakers; provided that such employees shall not work more than 48 hours in 

any one week, nor more than 84 hours in any 2-week period, except 

by payment of one and one-third rate for overtime; nor to employees 

in a managerial, executive, or other capacity who receive $35.00 

per week or more; provided that with respect to the exceptions in 

this Paragraph and in Paragraphs (a) and (b) of this Article there 

shall be no evasion of this Code by reclassification of the function 

of ~ orkers. A worker shall not be included in any one of the above 

exceptions unless the identical functions which he performs were 

identically classified on June 16, 1933." 

AMENDMENT 3. Article XIV is amended to read as follows: 

" With the exception of Artists' Colors, as defined in Article II, it shall be a violation of this Code for any manufacturer to fail 

to abide by the manufacturing restrictions as set out in Schedule 

A which is attached hereto and made a part of this Code, provided 

that this Article shall not apply to export trade and provided further 

that Paragraphs 2, 4, 5 and 6 of Schedule A hall not apply to 

products commonly known as 5, 10, and 25-cent merchandise which 

i old at retail to the consumer at not more than 25 cents per 

package.' 

AMENDMENT 4. Article XVI is amended to read as follows : 

"On and after the effective date the terms granted by manufacturer , excluding export trade, shall not exceed : Trade sales accounts, 2% for ca h in 10 days, net 60 days; excepting Arti ts' 

Colors, on which the terms shall be-2% for cash in 10 day -net 

\ 30 days; industrial sales accounts, 1 % for ca~h in 10 days, net 30 

(1 6) 
187 

days; except that the discount to trade sales accounts may be extended to the 10th day of the month following purchase and the 

discount to industrial sales accounts may be extended to the 20th 

day of the month following purchase to customers who regularly 

discount in the month following purchase, and provided that no 

discount shall be allowed after the discount date." 

AMENDMENT 5. Article XVII, Section (a ) is amended to read 

as follows: 

" (a) Spring Stock Orders-Datings on orders to established 

dealer and/ or jobber accounts, excluding export trade, and Artists' 

Colors, shall be limited to datings on Spring Stock Orders shipped 

at the manufacturer's convenience after October 15, with an April 1 

dating and regule.r terms; one order to an account. 

AMENDMENT 6. Article XVII, Section (b) is amended to read 

as follows: 

"(b) New Accounts-The maximum dating on trade sales stock 

orders (inimal stock order only) to new dealer and/ or jobber accounts, excluding export trade, and Artists' Colors, shall be limited 

to four months from the date of shipment and with standard terms, 

provided that orders shipped between October 15 and December 1 

in any year may be with an April 1 dating and with regular terms. 

Datings on initial trade sales stock orders of artists' colors from 

new dealer and/or jobber accounts shall be limited to two months 

from the date of shipment and with standard terms." 

AMENDMENT 7.-The following Section ( e) is added to Article 

XVII: 

" ( e) Artists' Colors: Fall Stock Orders: Datings on orders to 

established dealer and/ or jobber accounts shall be limited to datings 

on fall stock orders and shipped at the manufacturer's convenience 

after April 1, with a September 1 dating and regular terms and one 

order to an account. In the case of show -card colors and inks, which are subject to freezing, dating shall be limited on spring 

stock orders shipped at the manufacturer's convenience after N ovember 1st ( or, in the event shipment is made by a water route, which is 

affected by the closing of navigation, this date may be advanced 

not to exceed ten days prior to the official closing of navigation over 

such route), with an April 1st dating and regular terms and one 

order to an account." 

AMENDMENT 8. Section (4) of Article XXII is amended to read 

as follows: 

"The Paint Industry Recovery Board shall classify the products 

of the Industry and establish and furnish to all manufacturers figures representing all direct factory costs ( such as power and labor) 

depreciation determined in accordance with the provisions of the 

Federal Income Tax Laws, plus a proper proportion of all indirect 

factory expenses ( excepting interest on investment) in accordance 

with the share each class of products should bear. Such figures 

shall be the lowest reasonable cost of manufacturers, large and small, 

throughout the Industry and (subject to change by the Board) shall 

be used as the minimum processing cost by all members of the 

Industry, subject to the approval of the Administrator." 
188 

AMENDMENT 9. Section 16 of Schedule A is amended to read as 

follows: 

"Cement and/or Lime Bound Water Mixed Paints in the following sizes only: 5 and 10 lb. containers, 25, 50 and 100 lb. containers, 

barrels of 300 lbs. net, or more." 

AMENDME T 10. Article XXV is added, which reads as follows: 

"ARTICLE XXV-PuTTY DrvrsION 

"All provisions of this Code not in conflict with the prov1s10ns 

of Schedule B attached hereto and made a part hereof shall apply 

to the Putty Division as defined herein. 

"SECTION 1. Definitions: The term 'Putty Division' of the Paint, 

Varni h and Lacquer Manufacturing Indu try a u ed herein shall 

be construed to include all manufacturers of putty and/ or plastic 

substitutes th2refor used for the purpo e of glazing and for such 

other purposes where putty is ordinarily used. 

SECTION 2. Putty Advisory Committee: There shall be a committee 

of five members from the Putty Division of the A sociation: 2 from 

the Eastern states; 1 from the states in or west of the Rocky Mountains; and 2 from the remaining states; who shall be nominated and 

elected by the m mber at large of the Putty Division and ubmitted 

to the Paint Industry Recovery Board for approval. 

"It hall be the duty of this committee to advise with the Paint 

Industry Recovery Board, as may be nece ary from time to time, 

provided that the functions of this committee shall be entirely of an 

advisory nature and not binding upon the Paint Industry Recovery 

Board or its representative . 

"SECTION 3. Fair Trade Practices: It shall be a violation of this 

Code for any member of the Putty Division to fail to abide by the 

Fair Trade Practices set forth in Schedule B attached hereto." 

AMENDMENT 11. Schedule B, Fair Trade Practices, is added, which 

reads as follows : 

" SCHEDULE B-F AIR TRADE PRACTICES 

"1. Manufacturing Restrictions: Putty, except for export trade 

shall not be manufactured for the purpose of marketing as Trade 

Sales goods in packages other than the following : 1 lb. cans-5 lb. 

can -121⁄2 lb. pails-16 lb. pails-25 lb. pails; provided that nothing 

in this Code shall prevent the sale of these products in packages 

weighing more than 25 lb. net. 

" 2. Allowances : (a) No allowances shall be made for the return 

of any empty package, which empty package weighs less than 60 

lb. net. 

(b) No allowance shall be made for cartage. 

"3 Free Goods and Premiums: In addition to the provi ion of 

Article XX, Putty Knives shall not be given free of charge in connection with the 1narketing of putty. 

' 4. Standardization of Grades: With the exception of product 

made to order or on specifications, putty shall not be manufactured 

in a greater number of grades than herein permitted. 
189 

"(a) Woodsash Putty may be manufactured not to exceed: 

" ( 1) 5 grades com po ed of calcium carbonate; 

(2) 5 grades compo ed of calcium carbonate and not less 

than 5% white lead. 

"(b) Factory type metal sa h putty shall be manufactured in not 

more than 3 different grades. 

" ( c) Casement metal sash putty shall be manufactured in not 

more than 2 grades. 

' ( d) Primeless putty shall not be manufactured in more than 2 

grades. 

" 5. Commercial grade of Putty, regardless of brand name, shall 

be the lowest quality Putty offered. 

"6. Mislabelling, Misbranding and False Advertising: In addition to the provisions of Article XII, the fallowing are hereby 

prohibited: 

(a) Except as a part of a complete formula label the term 

" Linseed Oil " or the term " linseed ' shall not be used in connection 

with the description of any putty, the vehicle portion of which is 

le than 100 percent pure Lin eed Oil. 

(b) The term" Chalk"," Chalk Whiting" or "True Chalk Whiting" hall not be used in connection with the description of any 

putty, unless the pigment portion thereof is 100 percent true Chalk 

,i\Thiting. (But nothino- in this clau e is to restrict the use of the 

single word " Whiting?, so long as the material used is Calcium 

Carbonate) . 

( c) The term " Pure ", ingly, or with any other word or words, 

or any derivative thereof, . hall not be used in connection with the 

de cription of Putty unless the liquid portion thereof is 100 percent 

pure Linseed Oil. 

ApproYed Code No. 71. Amendments Nos. 1-11. 

Registry No. 619-1--03. 

0 
UNIVER S ITY OF F LO RIDA 

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