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PARAGRAPH 422-STRAW HATS, ETC.

LETTERS OF BRONSTON BROS. & CO., NEW YORK, N. Y., REGARD

ING STRAW HATS.

BRONSTON BROS. & Co.,

21-29 West Fourth Street, New York. The WAYS AND MEANS COMMITTEE,

Washington, D. C. GENTLEMEN: The importations of untrimmed blocked straw hats are, at a liberal estimate, not more than 3 per cent of the consumption in this country:

We believe that a readjustment of the hat and braid provisions would produce more revenue, admit of the employment of more labor, and effect a saving to the consumer.

The present duty on untrimmed blocked hats is 35 per cent and the same duty applies to a bleached or unbleached and unblocked hat or plateau, which works against the American labor of bleaching and blocking hats.

We are of the opinion that a more equitable duty and one which would not only fully protect the American producer, but considerably increase the revenue would be 25 per cent.

Taking a given style as illustrating the difference in cost and labor here and abroad, we present the following:

Foreign labor of bleaching, sewing, blocking, and packing costs 92 cents per dozen hats. American labor for the same items based on known operating figures and plus $0.1075 for duty on the imported braid necessary for making the hat costs $1.6975 per dozen hats, presenting an excess for American labor over the foreign of $0.7775 per dozen hats. The duty on this hat based on actual sales is $1.1375 per dozen, deducting from which the $0.7775 full difference in labor shows a further protection of $0. 36 per dozen,

The above-mentioned hat costs us after paying ocean freight, cartage, insurance, and duty $4.7875 per dozen, to which we add actual cost of labor and trimmings $2.36 per

dozen; total cost when ready for shipment on the same plane as the American, who has made his hat from the imported braid $7.1475.

The American hat made from imported braid would cost, based on price of braid abroad of, say, 64 pieces to a dozen, at $0.1125 each, $0.7175 duty, commission, freight, insurance, etc., $0.1675, labor $1.59, bleach, glue, thread, material for edge, packing, etc., $0.97, overhead $0.6360, total $4.0810, make the same addition for labor and trimmings of $2.36 and the American total cost is $6.4410.

This shows a difference in favor of the American-made hat of $0.7065 per dozen, on an initial investment of $0.8850 as against our investment of $4.7875, and the element of waste is much greater in our product by reason of breakage.

While we import the shell or body of the hat, we are American manufacturers to no small degree, and, as shown above, add for American labor and materials 50 per cent of our duty-paid landed cost to our imported material, which enables us to come before you without fear of being assailed as selfish importers wholly unmindful of American labor and investment, both of which elements are, in proportion to our business, quite as much a part of ours as of the firm who builds from the braid where we build from the shell.

Until we began the importation and finishing of these goods a few years ago, none of the foreign-made shells were imported. We beg to commend to you the following provision:

Per cent. Braids bleached and hats unbleached, unblocked, and untrimmed... Unbleached, blocked, but untrimmed, and bleached, unblocked, and untrimmed hats...

20 Untrimmed bleached blocked hats, valued at less than $10 per dozen.

25 When valued at $10 or more per dozen....

35 We feel you will not be unfriendly to our appeal for readjustment, when it appears to us capable of such, while accomplishing three material results, namely, affording full protection, increasing the revenue, and aiding a comparatively new industry. We have the honor to be, Yours, respectfully,

BRONSTON BROS. & Co.

T. S. TODD.

New York, February 17, 1919. The WAYS AND MEANS COMMITTEE,

Washington, D. C. GENTLEMEN: Supplementing our letter of January 29, we beg to say that we fear the brief of the Straw Goods Association may create an erroneous impression regard. ing the straw-bat industry, and particularly men's hats.

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PARAGRAPH 422—STRAW HATS, ETC. Our statement that the imports of men's untrimmed blocked straw hats does not exceed 3 per cent of the consumption is undoubtedly a most liberal estimate, as shown by a letter from the United States appraiser at this port under date of February 14, 1913, which reads as follows:

"Answering your letter of the 10th instant, the merchandise embraced under paragraph 422 includes hats, bonnets, hoods, plateaux, strips, composed wholly or in chief value of straw, chip, grass, palm leaf, willow, osier, rattan, Cuba bark, or manila hemp, whether wholly or partly manufactured, but not trimmed.

"This office has no record of the value of men's blocked untrimmed straw hats, but it is estimated that the value does not exceed $125,000 per annum. Respectfully,

"HENRY M. CLAPP,

"Special Deputy Appraiser." The statistics given by the above Straw Goods Association includes ladies' and children's hats of very high value, as well as Panama hats, of which there are imported, at a conservative estimate, $1,000,000. These Panamas usually cost more than $10 per dozen, and we have recommended that at or above this price they should pay the ate of 35 per cent. Hat bodies, whether woven, hand sewn, or machine sewn, are comme

mercially the the same when in the same state of development.

We beg to present our ideas by photograph inclosed, showing that the present paragraph, No. 422, “Hats, bonnets, or hoods composed of straw

whether wholly or partly manufactured, 35 per centum,' covers a much wider range than is commercially considered in one class and quite ignores the labor and development in America.

Woven or hand-sewn hat bodies are not made in this country.
No. 1. * * *

Woven unbleached unblocked hat body, No. 1A, bleached braid. Both are in a quite unfinished state, and in our judgment should pay 174. Manifestly, No. 1 should not pay the same rate as No. 3. The braid heretofore has paid 20 per cent. We suggest a reduction of 2 per cent, as the cost of bleaching here does not differ materially from that abroad.

No. 2. Bleached woven unblocked hat body, No. 2A, blocked but unbleached hat, of which the imports are small, and usually of a very coarse grade, the blocking of which is hydraulic, therefore inexpensive.

No. 3. Shows a woven hat bleached and blocked, and indicates the advancement from No. 1, and we believe should, together with No. 3A machine-sewn bleached and blocked hat body, pay 5 per cent more than No. 2 or 2A. These two are imported to the value of about $125,000.

No. 4. The trimmed hat, an articles on which we have expended from 55 to 70 per cent of our original cost for trimming and labor in this country. It is amply manifest that it should pay very considerably more duty than the shell No. 3.

Trimmed hats are largely imported under the present duty by reason of the constant solicitation by traveling salesmen representing Italian and English manufacturers, but under a readjustment of the schedule as above suggested, the duty could, we think, be reduced to 45 per cent without detriment to our industry.

The same rate of duty on a trimmed hat and on an untrimmed bleached blocked machine-sewn hat as No. 3A is illogical from every viewpoint.

Leghorns should not be separately classified, as they are capable of and subject to the same manipulations as other straw.

The readjustment we have suggested would inure to the benefit of the consumer, and would also, we believe, enable us to make larger use of imported raw materials, because we would be in a position to compete with the domestic manufacturer as to the fineness of braid, which we are unable to do at present.

Last year we paid duties of $35,000, represnting a considerable business, and which has only been possible by reason of originality of style ideas and trimmings.

The American manufacturer, producing hăts from the braid, is apparently bitterly opposed to our entrance into their hitherto exclusive field, but we plead to you our right to the creation of this new industry and deny the justice of our exclusion from operation when it represents not more than 3 per cent of the business of the country. We pray for your friendly consideration. We have the honor to be, Yours, respectfully,

BRONSTON Bros. & Co.,
T. S. TODD, Altorney.

PARAGRAPH 422-STRAW HATS, ETC.

BRIEF OF IMPORTERS ON WOVEN UNTRIMMED STRAW

HATS. The WAYS AND MEANS COMMITTEE,

House of Representatives, Washington, D. C. We, the undersigned, representing nearly all the importers of Panama hats, request that the ad valorem duty rate in paragraph 422 of Schedule N of the present tariff, in so far as it affects straw hats imported from Colombia, Ecuador, and Peru, be changed to a specific rate.

We make this request owing to the fact that no “market value,” as defined by law, can be established in any of these countries on Panama hats.

This condition has been a source of great trouble between the customs authorities and the importers, since it has been impossible for the importer to make entry of such Panama hats until the same were examined by experts and appraised in order to fix an entered value. As a result, long and expensive delays have arisen to the serious injury of the trade.

Panama hats are gathered in lots, small and large, often from remote sections of these several countries, and although the trade has been endeavoring to grade such hats under various names, it often happens when these hats are examined by the appraiser he often makes serious changes in grade, often advancing the invoice value and thereby penalizing the innocent importer who has been helpless because of there being no fixed “market value” to assign to his goods.

The exporters of Panama hats from South America do not know at the time of exportation what prices they will bring at wholesale in New York, nor does the importer know the quality of the hats imported without being allowed to inspect the same, and for that reason many of these hats are shipped to this country on consignment, and invoices are made out to the best of the shippers' knowledge and beliei.

Panama hats are made by the native Indians of Colombia, Ecuador, and Peru. The palm leaf, stripped and prepared for weaving is sold in the small towns and cities to the natives who take the material back to their houses in the country and mountains, miles away, where all the members of the family engage in the weaving of hats. It is but natural that a child of 10 will not weave as good a hat from the same material as a person of 30 years who has had long experience and as a result the one or two dozen hats woven by a family comprise many different qualities. These are purchased from time to time by a buyer, who travels through the country picking up the hats, a dozen here, 20 there, and perhaps 50 farther on, until he has all that he can carry when he returns to his principal in the town. After a number of trips the entire quantity of hats are graded and baled for shipment.

As the buyer pays different prices to different families, and as those prices vary according to demand, season, quality, and quantity, it is impossible to fix a market price; the only thing that can be said is that 500 dozen hats collected have cost the shipper $1,000, but when he comes to grade the same, 50 dozen of the hats may be of such quality that the shipper regards them worth $20 per dozen, while one dozen may be worth $100, and the other 449 dozen only worth $2 per dozen, so that in baling and shipping the hats the legal “market value” is impossible to be arrived at, and to attempt to say what has been paid for any particular bale would be equally impossible,

It is because of these existing conditions that we seek to have a specific duty placed upon Panama hats, especially those imported from Colombia, Ecuador, and Peru.

There are no “Panama hats" exported from any other country, and none of these hats are made “under water."

That is a legend only.

During the past two years many invoices have been detained, long examinations have resulted, and the importers have spent a large amount of money in the effort to establish a market value under the law, only to finally ascertain that there are hardly two persons in any of the ports of shipment who will agree as to the value of particular hats.

The average duty compiled from the figures taken from the records of the importers during the past year equals 40 cents per hat, and the value of the hats runs from $10 up to $24 per dozen. This covers the average importations of the commercial hats sold to jobbers.

There are no imports who make a specialty of bringing in hats of high values, as the market is limited, and the vast bulk of hats imported run from $12 to $14 per dozen. European countries impose a specific duty of a few cents per hat upon similar goods, regardless of value; while other countries impose a duty by weight regardless of the quality of value of the hat.

After long consultation in the trade and examination of the official records, we believe an equitable rate of duty, not to exceed 40 cents per hat, would increase the revenue of the United States, by encouraging the importations of such hats.

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PARAGRAPH 422—STRAW HATS, ETC. This would equal a duty of 35 per cent, which is the present rate, and would greatly benefit the import trade by simplifying matters and would do away with the expense and delay now resulting from uncertainty of valuation.

Importations at present are, in general, warehoused to await the results of the appraiser's report, and often times penalties are forced upon the trade in spite of their most earnest endeavor to fully comply with the law.

We therefore would request a specific duty on all woven Panama hats imported from Colombia, Ecuador, and Peru, on the basis of 40 cents each on all hats valued at $6 and not more than $30 per dozen; 75 cents each on all hats valued above $30 and not over $60 per dozen; and $2 each on all hats exceeding $60 per dozen.

We annex hereto the records of two of the largest importers covering the season of 1912, which confirm our statement that a duty of 40 cents a hat would be equitable to the trade, and certainly satisfactory to the Government. (Exhibit A.)

The Panama woven hats in demand in the United States to-day are those valued at from $6 to $60 per dozen, and that retail from $3 to $5 each after having been bleached, blocked, and trimmed in this country, and these constitute practically seven-eighths of all the importations.

Finally, it is respectfully submitted that paragraph 422 be amended to read as follows:

422. "Braids, plaits, laces, and willow sheets or squares, composed wholly or in chief value of straw, chip, grass, palm leaf, willow, osier, rattan, real horsehair, Cuba bark, or Manila hemp, suitable for making or ornamenting hats, bonnets, or hoods, not bleached, dyed, colored or stained, fifteen per centum ad valorem; if bleached, dyed, colored or stained, twenty per centum ad valorem; hats, bonnets, and hoods when imported from Colombia, Ecuador, or Peru, and composed wholly or in chief value of straw, chip, grass, palm leaf, willow, osier, rattan, Cuba bark, or Manila hemp, whether wholly or partly manufactured, but not trimmed, if valued at less than $6 per dozen, thirty-five per centum ad valorem; if trimmed, fifty per centum ad valorem; if valued at $6 per dozen and not more than $30 per dozen, 40 cents each; if valued at above $30 per dozen, and not more than $60 per dozen, 75 cents each; if valued at more than $60 per dozen, $2 each; but the terms "grass” and “straw" shall be understood to mean these substances in their natural form and structure, and not the separated fiber thereof.".

Should it be found desirable, however, to make the classification more general, the following is suggested.

422. "Braids, plaits, laces, and willow sheets or equares, composed wholly or in chief value of straw, chip, grass, palm leaf, willow, osier, rattan, real horsehair, Cuba bark, or manila hemp, suitable for making or ornamenting hats, bonnets, or hoods, not bleached, dyed, colored, or stained, fifteen per centum ad valorem; if bleached, dyed, colored, or stained, twenty per centum ad valorem; hats, bonnets, and hoods, composed wholly or in chief value of straw, chip, grass, palm leaf, willow, osier, rattan, Cuba bark, or manila hemp, whether wholly or partly manufactured, but not trimmed, if valued at less than $6 per dozen, thirty-five per centum ad valorem; if trimmed, fifty per centum ad valorem; if valued at $6 per dozen and not more than $30 per dozen, forty cents each; if valued at more than $30 per dozen and not more than $60 per dozen, seventy-five cents each; if valued at more than $60 per dozen, $2 each. But the terms 'grass' and 'straw' shall be understood to mean these substances in their natural form and structure, and not the separated fiber thereof."

If desired that the question of straw hats be made a separate one, the present paragraph 422 could remain as it is, with a supplemental clause as follows:

"Untrimmed straw hats, known as Panamas, made from straw, chip, grass, or palm leaf and valued at less than $6 per dozen, thirty-five per centum ad valorem; if valued at $6 per dozen and not more than $30 per dozen, forty cents each; if valued at more than $30 per dozen and not more than $60 per dozen, seventy-five cents each; if valued at more than $60 per dozen, $2 each." All of which is respectfully submitted.

POTTBERG, EBELING & Co.
M. CASTILLO & Co.
A. HELD.
SCHUTTE, BUNNEMANN & Co.
MECKE & Co.
CALHOUN & Co.
J. H. MENENDEZ & Co.

Lustig Bros.
(By Francis E. Hamilton, counsel, 32 Broadway, New York, N. Y.)
Dated, New York, N. Y., January 27, 1913.

PARAGRAPH 422-STRAW HATS, ETC.

List of duties paid on Panama hats during 1912.

Number of cases.

Steamer.

Number of dozen.

4 Albingia.

Trent.

...do

NNNNNNNNNNNNNNNNNNNNNNNN

2 Albingia.
Bella..

.do..
Albingia.
Altai..
Con di Gior
Thames.
Allemania..
Albingia.
Thames..
Con di Gior
Albingia.
Allemania.
Altai..
Allemania.

do.
Albingia..
Altai..
Allemnania.
Altai..
Allernania,
Allegheny:
Westerwald.
Altai.....
Westerwald.
Allemania..

.do. Altai. Albingia

Allegheny. 2 Zacapa...

Altai.. i Zacapa..

200 100 200 100 200 100 100 100 100 100 100 100 100 100 100 100 100 50 50 200

50 150

50 100 100 100 100 100 110

50 100

50 200 100 50 50 50 100 100 300 100 150 100 100 200 100 100 100 100 100 100 100 100 100 300 100 100 100 200 150 200

EXHIBIT A.

Arrived

When paid.

Invoice.

Amount of duty.

.....do.

.....do.

do Albingia.

Metapan. 6 Allemania

Westerwald. 3 Allemania. 2 Thames. 2 Clyde.. 4 Westerwald, 2 .do. 2

Zacapa.
2 Allegheny..
2 Allemania.
2 Metapan..
2 Magdalena.
2 Allemania.

Zacapa
Albingia..

Zacapa..
2 Westerwald.
2 Allemania.
2 Zacapa..
4 Westerwald.
3 .do.
4 Altai.
1 Albingia.
2 Zacapa.
2 Allemania.
3 ..do
1 Albingia
1 .do..
2 Allemania.
2 Westerwald.
2 Albingia..

do.. Altai.

do Oruba... Westerwald.

do.. Santa Marta,

Jan. 18, 1912 Jan. 23, 1912

Jan. 30, 1912
.do.

Feb. 20, 1912
Feb. 6, 1912 Feb. 29, 1912
Feb. 27, 1912 Mar. 11, 1912

.do... Mar. 13, 1912
Mar.
5, 1912

Mar. 22, 1912
Mar. 12, 1912 Mar. 30, 1912
Mar. 26, 1912 Apr. 3, 1912
Mar. 28, 1912 Apr. 5, 1912
Jan. 24, 1912 Apr. 12, 1912
Jan.

4, 1912
Mar. 28, 1912 ....do.
Mar. 26, 1912 Apr. 11, 1912
Nar. 5, 1912 Apr. 16, 1912
Apr. 15, 1912 Apr. 23, 1912
Apr. 9, 1912 Apr. 25, 1912
Apr. 15, 1912 Apr. 30, 1912
do.

May 6, 1912
Apr. 29, 1912 May 7, 1912
Apr. 9, 1912 May 15, 1912
Mar. 18, 1912 May 17, 1912
Apr. 9, 1912 .do.
May 14, 1912 May 23, 1912
Jan. 30, 1912 May 25, 1912
May 20, 1912 May 29, 1912
May 6, 1912 .do..
May 20, 1912 May 31, 1912
Feb. 19, 1912 June 3, 1912
Apr. 15, 1912 June 13, 1912
Apr. 9. 1912 June 18, 1912
Mar. 18, 1912 July 9, 1912
Jan. 30, 1912 July 9, 1912
May 24, 1912 July 10, 1912
June 4.1912 July 15, 1912
June 20, 1912 do..

do.. July 16, 1912
Aug. 19, 1912 Sept. 11, 1912
July 12, 1912 Aug. 16, 1912
Aug. 6,1912 do..
July 15, 1912 Aug. 19, 1912
June 13, 1912 do
Aug. 28, 1912 Sept. 9.1912
July 17, 1912 Sept. 7, 1912
June 17,1912 Aug. 23, 1912
July 15, 1912 ....do..
May 24, 1912 Aug. 20. 1912
Jan. 30, 1912 Aug. 19, 1912
Sept. 3, 1912 Sept. 26, 1912
Sept. 6, 1912 Ort. 3, 1912
Sept. 25. 1912 Oct. 18, 1912
Sept. 3, 1912 Oct. 22, 1912
Oct. 11.1912 ...do.
June 24, 1912 Oct. 23, 1912
Oct. 11,1912 Oct. 29. 1912
Oct. 15, 1912 Oct. 31, 1912
Oct.
7, 1912

do.
Oct. 11, 1912 Nov. 9. 1912
Oct. 15, 1912 Nov. 4,1912

Nov. 7,1912

.do..
July 22,1912 Nov. 12,1912
Oct. 11, 1912 Nov. 11, 1912
Oct. 7, 1912 Nov. 13, 1912
A pr. 15, 1912 Oct. 19, 1912
Apr. 29,1912

Nov. 15, 1912
Sept. 16, 1912

Nov. 18, 1912
Oct. 7,1912 Nov. 20,1912
June 17, 19:2 .....do
Nov. 18,1912 Nov. 23, 1912
Apr, 29, 1912 Nov. 26, 1912
Sept. 24, 1912 .do.
Oct. 28, 1912 .do
Oct. 25, 1912 ....do.
Oct. 14, 1912 Nov. 27, 1912
May 20, 1912 Nov. 30, 1912
Sept. 27, 1912

$2,678.00

1, 620.00
2,510.00
1,549.00
2, 417.00
1,738.00
1,687.00
1,775.00
1,694.00
1,177.00
1,335.00
1,482.09
1, 179.00
1,775.00
1, 213.00
1,764.00
1,200.00

888.00

888.00 3,001.00

688.00 2,182.00

688.00 2, 106.00 1,076.00 1,342.00 1,983.00 1,929.00 1,871.00

696.00 1, 212.00

604.00 2.670.00 1. 93.00 1,005.00

851.00

851.00 1,283.00 1.428.00 4.936.00 1,482.00 1,980,00 1,324,00 1.221.00 2, 708, 00 1, 697.00 1.553.00 1,380.00 1.352,00 1,551.00 1,422,00 1,348,00 1,767.00 2,059.00 5,302.00 1,403.00 1, 502.00 1,767.00 2, 296.00 2, 153.00 3, 143.00

973.00 1,631.00 1,790.00 2,088.00

096.00

754.00 1,377.00 1, 414.00 1,919.00

696.00 1,901,00 1,773.00 1,513.00 2, 291.00 1,436.00 1,670.00

50 100 100 150 50 50 100 100 100

50 100 114 120 200 100 100

$937.30 507.00 878. 50 52. 15 815.95 C08. 30 590. 15 621. 25 592. 90 411.95 467.25 518. 70 412.65 621. 25 435.05 617. 40 420.00 310.80

310. 80 1,051. 40

240.80 763. 70 240. SO 737. 10 376.60 469. 70 694.05 675. 15 654.85 243. 60 424. 20 211.40 934.55 603.60 351.75 297.85 297.85 449.05

499.80 1, 734.60

518.70 693.00 463. 40 427.35 947.80 593. 95 543. 55 483.00 473,20 542.85 497.70 471, 80 .618.45

720.65 1, 855.70

491.05 525.70 61 S. 45 SO3. 60

753. 55 1, 100.15

340. 55 570.85 626. 50 730.80 243. 60 263. 90 481.95 494.90 671.65 243. 60 665. 35 620. 55 529.55 801.85 502.60 584.50

NANNNNNNNNNNN

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