NATIONAL RECOVERY ADMINISTRATION 

CODE OF FAIR COMPETITION 

FOR THE 

RABBIT FUR DYEING 

INDUSTRY 

AS SUBMITTED ON AUGUST 24, 1933 

REGISTRY No. 911-1-03 

The Code for the Rabbit Fur Dyeing Industry 

in its present form merely reflects the proposal of the above-mentioned 

industry, and none of the provisions contained therein are 

to be regarded as having received the approval of 

the National Recovery Administration 

as applying to this industry 

UNIV. Q~ F't Lll. 

~ 

WE DO OUR PART 

I l 

i A 'I """ ---~ 

GOVERNMENT PRINTING OFFICE 

WASillNGTON: 1933 

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RABBIT FUR DYEING INDUSTRY 

CODE INDEX #911/1/03 

To: Maj. Gen. C. C. Williams, National Recovery Administration, 

Washington, D.C. 

BRIEF oF NATIONAL AssociATION oF RABBIT FuR DYERs, ETc. 

INTRODUCTION 

The rabbit fur dyeing industry is made up of a number of concerns 

engaged as service organizations in the bleaching and/or dyeing of 

rabbit skins (pelts), the work being performed for others on a contract basis. Although the volume of business is substantial, and the 

number of persons employed in the industry sizeable, the services 

are performed by a small number of organizations located in the 

vicinity of New York City and the State of New Jersey. 

The dyeing services rendered in connection with rabbit skins by 

reason of the actual cheapness of the rabbit skin as compared with all 

<>ther furs, creates operating problems distinct and wholly different 

from those existing in the industry engaged in dyeing higher priced 

or so-called, "fancy" furs. The requirements of this industry, its 

labor and production problems as well as the general nature and 

-conduct of its operations are to a great extent foreign to those of the 

"fancy" dyeing industry. We claim that we are an industry separate 

and apart from the general fur dyeing industry, particularly insofar .as our labor arid production problems are concerned, and that we are 

.entitled to a separate code. The industrial reasons for this contention 

are set forth more fully hereinbelow. 

THE ASSOCIATION-ITS ORIGIN AND PURPOSES 

The association was recently organized for the sole purpose of aidfug 

the Government in carrying out the provisions of the act. The entire 

rabbit dyeing industry is made up of a group of eleven concerns, ten 

<>f which specialize as service organizations in the dyeing of skins for 

<>thers on a contract basis, and one concern being engaged in dyeing 

for its own account exclusively. This concern is engaged in fur 

dealing, fur dressing and likewise as a fur dyer. Of the ten concerns 

who are exclusive service organizations, one concern, namely, the 

Great Norther Fur Dyeing & Dressing Co., Inc., has approximately 

20% to 25% of the total rabbit dyeing business. The balance of 

75% to 80% is divided among the remaining concerns. This percentage varies, depending upon the color of the skin which is in vogue. Frequently, with the change in styles, the percentage of this one 

concern is considerably decreased. 

816o-33 (1) 
2 

The industry in the past few years, similar to many others, has 

suffered not only from general business conditions, but from manmade practices which have stifled fair competition in the industry 

and brought about chaotic conditions. By this we mean that by 

reason of cut-throat tactics, price slashing below cost of production, 

secret rebates not passed on to the consumer, but granted for the 

purpose of ruining fair competition, and other similar practices, those 

engaged in the industry have found it difficult to operate in such a 

manner so as to permit the payment to labor of a reasonable and 

fair rate of wage, and still permit some return on capital invest1nent. 

It is our hope that under the guidance and with the support of the 

Administration coupled with the powers granted to it by the Act, 

we may be able to rehabilitate the industry, and not only give more 

employment, but give better employment in the sense of wages and 

hours, and generally aid in national recovery. 

With this purpose in mind, all of the eleven organizations engaged 

in the bleaching and/or dyeing of rabbit skins were gathered together 

in order to form a representative association, and formulate a code. 

Each of the eleven concerns were represented. A code was drafted 

and submitted for their consideration. It was suggested, that in 

order to effectively carry out the provisions of the code and in order 

to assist the Administration in its desire that all industries be selfgoverning in this great enterprise, that an association be organized 

which would be the medium through which this industry could deal 

with the government and whose purpose it would be to aid in the 

enforcement of the code and suggest practical and necessary changes 

of benefit to the industry. This association was thereupon organized. 

Of the eleven concerns present, the one concern engaged in dyeing for 

itself has been temporarily excluded from consideration as a member, 

for the reason that this concern is undecided as to whether it should 

become a member of this association made up of service organizations, or whether it should become a member of a manufacturers' 

association. Of the remaining ten service organizations, nine be arne 

members of this association. Their names and addresses are as 

follows: 

Iceland Fur Dyeing Co., Inc., 11 Hope Street, Brooklyn, N.Y. 

Grand Fur Dyeing Co., Inc., 1013 Grand Street, Brooklyn, .Y. ·Philip A. Singer & Bro., Inc., 169 Malvern Street, Newark, .J. 

Mendoza Fur Dyeing Works, Inc., 158 West 29th St., ew York 

City. 

Diamond Fur Dyeing Co., Inc., 257 West 27th t., New York ity. 

Hudson Fur Dyeing, Inc., 29 Congress Street, wark, .J. 

Oakland Fur Dyeing Co., Inc., 3278 Greene Street, Brookl n, 

NuWest Fur Dyeing Co., Inc., 555 Park enu , Brookl n, 

Van-Dye-Way Corporation, 148 W st 2 th tr ' York 

The Gr at Northern Fur Dy ing & Dre ing ., In ., did 

becom a member of th iation. Th ir r pr ntati 

that thi oncern did n t ar t ub crib to our prop d 

th rea on, that in our d ' t up a ar f Tru 

oth r provi ion int nd d t id in th nf r m nt f th an 

int nd d t a tiT it pr p r b r an all n rn , whi h f rn1 

f up rvi i n th y did n appr ' f. 

Th imat d t al num r £ p r n h 

y ing indu try am unt t appr ximat 1 
3 

number, approximately 400 are estimated to be employed by the 

Great Northern Fur Dyeing & Dressing Co., Inc. The remaining 

number of approximately 1,500 or 1,600 employees are employed by 

concerns who are members of this association. 

The proposed code which has heretofore been filed with the Administration in behalf of this association has been approved entirely by 

eight out of the nine members of the association. The nonassenting 

member, Van-Dye-Way Corporation, has approved of all of the terms 

of the code, with the exception of the rate of wages. It has st&ted that 

it desired to submit a separate schedule of wages to apply solely to its 

concern for other reasons. 

It is our belief, that because of the conditions existing in this 

industry, that our association is a necessary element in order to 

properly assure the observance of the code. We feel that this association, made up of small and large concerns representing the industry, 

will serve many purposes in aiding the Government in the enforcement of the code. All service organizations engaged in the rabbit 

fur dyeing industry, with the exception of the Great Northern Fur 

Dyeing & Dressing Co., Inc., have indicated their willingness to file 

regular reports of labor employed and rate of wage paid with the 

association, and to keep the association informed with respect to such 

other matters as may be required from time to time in connection 

with the enforcement of the code. The Great Northern Fur Dyeing 

& Dressing Co., Inc., has indicated that it is not agreeable to filing 

reports with the association of labor employed, hours and rate of wage 

paid. In keeping with the expressions of the administration towards 

self-policing and self-government in industry, we submit that the 

best interests of the industry of labor employed therein and of the 

Government can be accomplished through our trade association made 

up of members of the industry who are familiar _with the current 

existing conditions, and who will be quick to recognize any attempted 

violation of any provisions of the code. 

THE INDUSTRY 

(A) FURS DRESSED 

There is no available accurate statistical record which applies particularly to the rabbit fur dyeing industry. The only records which 

have been obtained through the Department of Commerce consist of 

an analysis of establishments "engaged primarily in scraping, currying, bleaching, and dyeing pelts and in dressing hair." This analysis 

would seem to include not only rabbit fur dyers, but also all other fur 

dyers (fancy furs) as well as concerns engaged in the dressing of 

rabbit furs and of fancy furs. 

The summary for the years 1927, 1929, and 1931 above referred to 

indicates the following: 

Year 

1931--- i~~~=== ---===--===== ------==------- ========-------- ======------------------ ====== ==== ======== -------===-------------- ======= === ---------== ! l 

Wage earners (average for year) 

5,540 

5, 167 

5, 160 

Wages 

$10, 360, 987 

8, 596,377 

7,968,006 
4 

It should be noted that in the entire fur dressing and dyeing industry from 1927 to 1929 the decrease in wage earners was slightly 

over 67~%, and the decrease in wages over 17%. From 1929 to 

1931, there is practically no decrease in wage earners, and yet, there 

is a further decrease in wages of almost 8% over the same period. 

(B) RABBIT INDUSTRY 

We ar.e able to furnish only estimated figures with respect to the 

rabbit fur dyeing industry, in view of the fact that no statistical 

reports are now available or have heretofore been furnished by concerns engaged in this industry. With the authority of the Act, 

after the approval of the code for the industry, we will be in a position to demand and procure accurate statistical reports from all 

concerns for the present time and for years past. The following 

estimated figures are submitted: 

Annual By non- By asso- Persons employed (wage Year Skins processed produc- associa- ciation earners) tion in tionmemdollars bers members 

Percent Percent 1,800 to 2,000 _________________ 1933 18,000,000 to 20,000,000 ___________ $2,000,000 2D-25 7&- 0 About 2,500 __________________ 1929 20,000,000 to 23,000,000 ___________ 2, 500,000) ---------- ----------

Wage earners employed in 1933 (estimated): Association, about 

1,600; nonassociation, about 400. 

(c) CHANGES IN INDUSTRY (SELLING PRICE ) 
5 

This condition has likewise held back capital investment, which 

would ordinarily be required in additional productive machinery and 

maintenance, and which in turn would have resulted in greater 

employment. 

It is our sincere belief, that with the elimination of some of the 

practices now existing in the industry, and the removal of competitive prices based upon the labor costs of producers and the supervision of all concerns afforded by the Act, there will be considerable 

increase in business, and certainly a considerable increase in the number of persons employed as well as in the rate of wage paid to them. 

LABOR BENEFITS OF CODE 

1. Rate of Wage: 

The minimum rate of wage proposed in our code will result in an 

increase of approximately 35% of the present minimum rate. At 

the present time, male help is being employed in the industry at a 

minimum rate as low as 32¢ an hour, the greater average being about 

40¢ per hour. The rate fixed in the proposed code of 50¢ per hour is 

a decided improvement. 

At the present time, female help is being employed at a minimum 

rate as low as 20¢ an hour, the greater average being about 28¢ per 

hour. The increase to 35¢ per hour is a decided improvement. 

2. Maximum Hours: 

The maximum number of hours provided for in the code is likewise 

of considerable benefit to labor. In seasonal times it has been customary in this industry to employ wage earners, particularly male help 1 

for tin1e and overtime, amounting in some cases as high as 13 or 14 

hours a day. At the present time, the average number of hours of 

male help is between 44 and 48 hours a week not including overtime. 

The reduction of hours specified in the code to a 40-hour week nonseasonal, and 46-hour week seasonal, plus the limitation of overtime to 

a total of only 120 hours during the entire year, will necessitate the 

employment of a considerable number of additional male help. We 

estimate that the limitation on the maximum hours fixed in the code 

will result in an increase in employment during peak periods of approximately 20%, and an increase during nonseasonal periods of 

slightly less than this percentage. 

Applying the maximum-hour provision of the code as effecting females, we estimate that the provisions of the code will require an increase of at least 10% in the employment of female help. 

SEASONAL AND OVERTIME EMPLOYMENT 

In this industry, seasonal employment is a necessary evil. The 

particular requirements of the industry are such, that concerns 

engaged in the marketing of our products, namely, our customers, are 

unable to determjne even a month ahead the kind of colors or styles 

which w1ll be desirable. Accordingly, no merchandise is sent to the 

dyers for processing for long periods in advance. In fact, it is customary for merchandise to be sent to the dyers by our customers 

practically at the last moment when they have orders for the resale of 

the skins. It, therefore, follows that in seasonal times, the dyers 

will have a rush of work which must be processed and delivered within 
6 

a week or two. This necessitates double shifts and overtime on the 

part of the employees. We have reduced the number of overtime 

hours considerably by the maximum provisions of the Code. We 

believe, that to reduce it any further, would create a great hardship. 

In the processing of rabbit skins, the dyeing process itself requires a 

period of from three to four days. Immed1ately after the dyeing, 

there is an additional process which requires about two or three days, 

and which consists of the drying and a careful cleaning of the skin. 

Once the dyeing process on the skin is commenced, it is essential that 

the full process of dyeing, drying, and cleaning be completed, without 

:any interruption. In fact, a delay of a few hours in commencing the .drying and cleaning process, after the dyeing operation, is very often 

.injurious to the skin, and will render it unmarketable. For this reason 

uring seasonal periods particularly overtime work is absolutely 

·necessary in order that the process, once commenced, may be completed. Accordingly, it is submitted, that limitation of overtime to 

120 hours, spread over the period of a year, is necessary for the 

industry in addition to the maximum hours provided for seasonal 

periods. This overtime is actually in the sense of emergency tLme, 

without which the industry would suffer great injury. 

DISTINCTIONS BETWEEN RABBIT DYEING INDUSTRY AND FANCY DYEI G 

INDUSTRY 

The rabbit industry is now recognized as an industry dealing with 

the type of fur skin which for practical purposes has become a necessity with the middle class of purchasing public, which are in the 

majority. The rabbit skin, by various processes and treatments, i 

made serviceable, economical, and of a price where it can compete 

successfully with the average-priced cloth coat, still giving the wearer 

the added service and benefit. of warmth, durability, and style. 

The distinguishing features of the dyed rabbit skin is that the cost 

of the process applied to the dressed skin is very great in proportion 

to the value of the skin itself. The service charge on the rabbit kin 

is a substantial item of the cost as will be seen from the figures her in- below set forth. On the other hand, with respect to all other fur 

skins which are dyed, the service charge is usually a very minor part 

of the cost of the article. For example, the value of the average rab it 

skin which comes to the dyer in a dressed state is in the nei<Yhborhoo 

of 20¢ to 25¢ (this includes a dressing charge of approximately 7¢ p r 

skin). The service charge in connection with the dy in<Y of th kin 

is now in the neighborhood of ¢ to 1 ¢, dependent upon th fini h 

product desired. 

It therefore appear that the d ing 

is a hi<Yh as 70% of the cost of th dr d 

service harge for dyeing f rabbit kin 1 

initial co t of the raw kin it lf. 

mparing th r i e harg I ra. bi 

f r dy in<Y f h r kin , w ubmit h f ll winO': 

fur kin \i hi h ar d d, run in l u fr m 

t a high a 17 .00 p r ki . h lab r 

i r all. n in ignifi ant it min hno- th nt.ir st. ln m 

th f d • int-- th kin. i in th n i<Yh h rh n t < f ,) 

h t tal t f th rLi l f r xnm1l w lf hn \\hi l 
7 

neighborhood of $8.00 to $10.00 a skin involve a dyeing charge of 

$1.00 or less; white foxes which are worth from $35.00 to $40.00 a skin 

require a service charge of about $2.00; squirrels which are worth from 

50¢ to 60¢ a skin require a service charge ·of about 10¢; weasels which 

are worth from $2.00 to $3.00 a skin require a service charge of about 

15¢. 

Because of the difference in the service charge in the dyeing services 

rendered by our industry and the fancy fur dyers, the two industries 

have at all times been considered distinct and separate, particularly 

1n their labor problems. The fancy fur dyers always paid a higher 

rate of wage than that customarily paid by us, for two reasons. The 

first is the fact that in the fancy-dyeing industry, the labor required 

is of a more skilled nature; more hand work is required; the article is 

a more expensive skin, requiring ·careful handling and treatment. The 

rabbit skin requires less skilled labor due to the fact that more machinery is employed, and the skin is so much cheaper. The second reason 

for the differential in wages is, that where a higher price skin is involved, a difference of a few cents an hour in the labor charge can 

easily be absorbed in the price of the article. 

Furthermore, this industry must compete with the importation of 

dressed and dyed rabbit skins from France, Germany, and Belgium. 

At the present time, it can fairly compete with the foreign markets 

for the reason that the service charge for dyeing and dressing in this 

country, plus the cost of the skin, is about the same or slightly less 

than the cost of importing the rabbit skin inclusive of the duty. An 

increase in the labor cost, in excess of the amount suggested in the 

proposed code filed by us, would give to the import market an unfair 

advantage over the domestic product by reason of the higher cost of 

the domestic article. Such an increase would benefit the foreign 

markets to the exclusion and detriment of the domestic industry. All 

benefits to labor contemplated by the code would be lost in such event, 

due to the reduction or decrease in production which would necessarily 

follow, Ynless the tariff duties on the imported skins would be proportionately increased. 

The rabbit skin cannot absorb any greater increase in labor cost 

than that provided for in our proposed code. This conclusion haB 

been arrived at after careful consideration and discussion, which was ·engaged in by representatives of all concerns involved in this industry. 

Any greater increase would be prohibitive, and would only result in ·decreased consumption which would result in decreased employment. 

In addition to the labor difference above set forth, the rabbitdyeing industry requires a greater overhead for plant, machinery, and 

.dyestuffs. In treating the rabbit skins, machinery is required for 

processes which are unnecessary to the fancy fur dyeing industry. 

For instance, some of the processes used which are foreign to the other 

industry are sheering, unhairing, and brushing, in addition to the 

usual dyeing and cleaning processes which are used by both industries. 

Special machinery and equipment is required in the rabbit industry, 

in order that the skin may receive the various treatments referred to. 

The rabbit dyers, because of the necessity of additional machinery, 

have an increased overhead usually requiring three times as much 

space for the same volume of gross business as that of the fancy dyers. 

There is likewise the consideration of additional power, electric current, mechanical labor, repairs, machine maintenance, and capital 
8 

investment which are not involved 1n the operation of the fancy 

dyers' business. 

For all of these reasons, this industry has always been recognized as 

unique and distinct from that of the fancy dyers. The products of 

this industry are handled by different dealers, and these products have 

different markets. 

We therefore submit that the proposed code heretofore filed by us on 

behalf of the rabbit fur-dyeing industry be considered and adopted 

separate and apart from any other fur-dyeing code. 

In conclusion may we state that in submitting the proposed code for 

the rabbit-dyeing industry, we have endeavored to include provisions 

which will be of mutual benefit to those employed in the industry, a 

well as to the individual concerns engaged therein. It is our earnest 

desire to lend our aid and cooperation in the national attempt to 

rehabilitate all industries, and to encourage reemployment. We 

pledge our support to the President and to the Administration in the 

enforcement of the Act. 

Dated New York, August 15, 1933. 

Respectfully submitted. 

NATIONAL AssociATION OF RABBIT FuR DYERS, INc., 

By MEYER GELLEN, Secretary. 

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