In a communication dated November 30, 1908, from the National Association of Hosiery and Underwear Manufacturers it is urged by that association that Schedule I, paragraph 318, of the tariff of 1897 be amended so as to effect an increase in the duty on cotton hosiery to the extent indicated by the following table:

In explanation of the foregoing table it should be said that the manufacturers' proposed schedule contemplates a minimum ad valorem rate of 15 per cent and a maximum of 35 per cent in addition to the specific duties on all grades up to $5 per dozen pairs, and a minimum rate of 65 per cent and a maximum rate of 85 per cent ad valorem on all cotton hosiery valued at more than $5 per dozen pairs.

It will be seen from the foregoing that a very material and considerable increase in the duties on cotton hosiery is contemplated by the manufacturers' schedules, and, in the judgment of this association, the proposed schedule, if adopted, would reduce the importation of cotton hosiery at least 80 per cent. This we consider to be a matter for serious consideration, because the volume of importations of cotton hosiery brings to the Government annually in revenue approximately the sum of $4,000,000. We therefore submit that the increase of these duties, resulting necessarily in a loss of revenue to the Government, should not be affected unless some forceful reason for so doing is presented to your committee.

In support of their petition for an increase in the duty on cotton hosiery the manufacturers have submitted for consideration tables of comparative costs on four qualities, alleging that they are the principal items of hosiery imported and represent a greater per cent of the total import than others, and are also the most popular articles of consumption. Before considering examples set forth in their petition in detail we desire to say that the imported articles are coarser than the American articles with which they are compared; that instead of 39-gauge lisle half hose, made of 60/2 lisle yarn, weight 1 pound, the importations are of goods made of 70/2 lisle yarn, and in connection with women's hose the grades are even coarser, and instead of 36 gauge and 39 gauge the great mass of importations, in fact, we might say almost the entire amount of corresponding grades, is 33-gauge women's cotton hose and 36-gauge women's lisle and mercerized lisle hose. While the various grades, therefore, are sharply in competition with each other, a discrimination should be exercised in describing the character of each in making a comparison of the cost of producing them.

We now come to a consideration of the statements of comparative cost of production in Chemnitz and in the United States, contained in the tables marked examples 1 to 4, in the manufacturers' letter. A proper comparison with the American-made articles should be made along the following lines:

EXAMPLE 1.-Comparative cost of 39-gauge lisle half hose, foreign, made of 70/2_lisle yarn, and American, made of 60/2 lisle yarn, weight 1 pound

German half hose are generally made from 70/2 lisle yarns, as 60/2 lisle yarns are too heavy to work to advantage on the hosiery machines. EXAMPLE 2.-Comparative cost of 33-gauge, foreign manufacture, and 36-gauge, American manufacture, women's cotton hose, made of 1/20 combed Egyptian yarn, weight 1 pound

We quote German cost on 33-gauge ladies' cotton hosiery, as almost all the goods imported from Germany at above cost are made on 33-gauge frames and not on 36-gauge, as stated by American manufacturers' brief.

EXAMPLE 3.-Comparative cost of 89-gauge women's lisle hose, made of 70/2 combed Egyptian lisle, weight 1 pound 6 ounces.

Difference in favor of American manufacturer under present law, plus landing expense..

.70

EXAMPLE 4.-Comparative cost of 39-gauge women's mercerized combed Egyptian lisle, made of 70/2 combed Egyptian mercerized lisle, weight 1 pound 6 ounces.

Difference in favor of American manufacturer under present law, plus landing expense..

3. 12

.65

EXAMPLE 5.-Cost of 36-gauge, German made, women's lisle hose, made of 70/2 combed Egyptian lisle, weight 1 pound 6 ounces.

EXAMPLE 6.-Cost of 36-gauge, German made, women's mercerized combed Egytian lisle, made of 70/2 combed Egyptian mercerized lisle, weight 1 pound 6 ounces.

The National Association of Hosiery Manufacturers includes examples 3 and 4 as qualities representing two of the principal items of hosiery imported. We wish to take exception to this statement. The principal qualities that are imported that compete with American-made 39-gauge women's lisle hose are women's lisle hose made on 36-gauge frames, and following we give the German manufacturers' cost on these goods. The reason the Americans do not make 36-gauge women's lisle hose is that there have been very few of this gauge machine imported into the United States, but the German manufacturers use 36-gauge machines quite extensively. On examples 3 and 4 we are only able to furnish the German export costs of these two qualities and not the detail of yarns, wages, etc. To all the German costs, detailed in examples 1, 2, 5, and 6, will have to be added the manufacturers' profit, as the export prices of these goods from Germany are as follows, to which we annex the net currency cost, landed at the port of New York, for your information:

It is stated in the manufacturers' letter that a large percentage of German hosiery exported to this country is called a product of "cottage industry" in the villages around Chemnitz. No figures are given to substantiate this claim, and from our own intimate knowledge of manufacturing conditions in this line in Germany we maintain that the "cottage industry" represents a very small percentage of the hosiery manufactured. "Cottage industry" is mostly employed in embroidering and seaming, and the vast amount, in fact principally all, of the

ordinary cotton hose that reaches this country from Germany is made in the factories upon expensive machines. The claim that there are no restrictions as to the hours of labor and age of the workers is utterly at variance with the fact, because there is no country in the world where labor and school hours are controlled as completely as in Germany, and the hosiery industry is not excepted from the requirements of German law.

It is said in the course of the manufacturers' letter that the wages to-day paid operatives in cotton-hosiery mills are fully 25 per cent higher than eleven years ago, and that this increase has been the result of the increased cost of living during the past ten years. We admit that wages are higher, perhaps, to the extent of 25 per cent in American cotton-hosiery mills than they were eleven years ago, but we also represent as the fact that there has been a corresponding increase in the wages paid to operatives engaged in the same industry in Germany. The increase in the wages among American workmen was during the year 1907, when the American mills were so flooded with orders that it was impossible for them to produce the goods that they had sold; not only were the mills running full time, but overtime, and organized labor, as is always the fact when manufacturers are busy, demanded an increase in wages, which the American manufacturers were compelled to pay. The American industry is supplied with operatives from England and Germany, and when the increased cost of living in this country is excessively offset by an increase in wages, the foreign manufacturer is compelled to increase the wages of his operatives in order to retain them, the supply of operatives being limited and the number at work in the United States being small in comparison with the demand for skilled operators. It may also be added that wages had to be increased in Germany proportionately to the increase in the United States on account of the increased cost of living in Germany, which increased correspondingly with the cost in the United States during the past eleven years.

The remark is made in the course of the manufacturers' letter that

last summer the German manufacturers forced a strike, and after a lockout of some four weeks the work people succumbed and accepted a reduction aggregating about 25 per cent of the wages they had been receiving, and the result is the German manufacturers are on a lower basis of cost than ever before, thus enabling them to sell goods in this country at prices in marks and pfennigs 33 per cent cheaper than the lowest price quoted in the past for the same article.

This is not a statement of facts. The true circumstances are that last year, owing to the panic in the United States, which influenced and affected business throughout the world, the German market was bare of orders, and the manufacturers offered their work people the old wage schedule, which had been in force prior to 1907, telling them that they must then accept it or a cessation of manufacturing would be absolutely necessary, and a lockout occurred, the workmen eventually going back on the old wage schedule. At the same time, with respect to the wages which the manufacturers were compelled to pay in the year 1907, we beg to inform the committee that the rate of wages in that year was heretofore unknown, and it is a well-known fact that, owing to the unprecedented wages paid during that period, the German workmen would not work a full week, but were satisfied with the wages they could make at three or four days' labor, as they were mak

ing more by working a portion of the week than they had prior to that time made by a full week's labor.

The next proposition taken up by the manufacturers is contained in the assertion that "there has always been more or less undervaluation, notwithstanding the best efforts of the local appraisers to prevent same, but to-day the German manufacturers, through a system of averaging their selling prices, have brought it to apparent perfection."

This claim we absolutely deny, and we defy the National Association of Hosiery and Underwear Manufacturers to prove the assertion. We have been visiting the foreign markets for many years and have never been approached by a manufacturer to invoice goods at one price and sell them at another and pay the difference in cash. This is an allegation of violation of the tariff law that is gratuitous and is impliedly made against a large number of very responsible houses engaged in the importation of cotton hosiery. The houses engaged in the importation of hosiery are such well-known and reputable firms as

Lord & Taylor, New York.

Brown, Durrell Company, New York
and Boston.

Fredk. Vietor & Achelis, New York.
Arnold, Constable Company, New York.
H. B. Claflin & Co., New York.

Henry Schiff & Co., New York.
Marshall Field & Co., Chicago.
Carson, Pirie, Scott & Co., Chicago.
Ely, Walker & Co., St. Louis.
Rice, Stix Company, St. Louis.
Levi Strauss & Co., San Francisco.

These concerns are not only reputable, but in their respective communities are regarded as merchants of highest character, and allegation of this description should not be made against any of them. There are also other houses equally reputable, any one of which could refute the assertions that their importations of cotton hosiery are undervalued. Besides the names of the hosiery importers stated above, the balance of importations are principally in the hands of the large retail firms, who buy their goods from the foreign manufacturer, and these are such concerns as

Stern Brothers, New York.

R. H. Macy & Co., New York.

John Wanamaker, New York and Phila- Abraham & Straus, Brooklyn. delphia.

B. Altman & Co., New York.

James McCreery & Co., New York.
Strawbridge & Clothier, Philadelphia.

and others of similar size and like character of commercial reputation.

We would submit also that the allegation discussed is a criticism upon the appraisers in customs-houses. These men are not determined by the values fixed in the invoices, but their judgment on values is the result of long experience and careful information furnished by the American consuls and special Treasury agents, whose special business it is to detect such frauds as are charged in the manufacturers' letter.

The manufacturers' letter contains the further statement that the cotton-hosiery industry of the United States is in the hands of 500 separate and distinct manufacturers, and that the value of the annual product is $50,000,000, but no information is given as to how many of these manufacturers made full-fashioned hosiery, or what percentage of the total production such manufacturers produced.` It is our understanding that 85 per cent or more of the hosiery manufactured in the United States is seamless hosiery, and all the seam