PARAGRAPH 439-FURS. BRIEF OF AARON NAUMBURG, REPRESENTING THE HATTERS' FUR INDUSTRY OF THE UNITED STATES. The COMMITTEE ON WAYS AND MEANS, NEW YORK CITY, January 28, 1913. Washington, D. C. GENTLEMEN: This memorial is presented in behalf of the entire hatters' fur industry of the United States, composed of Jonas & Naumburg, New York City; H. & A.Chapal Freres & Co., Brooklyn, N. Y.; Bloch & Hirsch Fur Co., Brooklyn, N. Y.; Hitchcock, Dermody & Co., Brooklyn, N. Y.; Pellissier, Jeunes & Rivet, Brooklyn, N. Y.; H. Picard & Co., Newark, N. J.; Donner & Co., Newark, N. J.; Martin Bates, jr., & Co., South Norwalk, Conn.; American Hatters & Furriers' Co., Danbury, Conn.; J. W. Katz, Newark, N. J.; John B. Stetson Co., Philadelphia, Pa.; New England Fur Co., Fall River, Mass.; Waring Hat Manufacturing Co., Yonkers, N. Y.; Peck Fur Co., Danbury, Conn.; and Robinson Fur Co., Danbury, Conn. Its purpose is to convey, in a brief and concise statement, information for the benefit of the committee, in order that intelligent consideration may be given to those paragraphs of the existing tariff act affecting our industry. The industry is mainly centralized within a radius of 100 miles of New York City, employs over 3,500 persons in the various factories, and consists solely of removing the hair or fur from the skin of the rabbit, hare, nutria, and beaver, after opening, carding, cleaning, and other processes, and chemically treating it with a solution of nitric acid and quicksilver (or mercury), called "carroting," producing a product commonly known as hatters' furs. This product is sold to fur-felt hat manufacturers and is manufactured into fur-felt hats by a separate and distinct industry. The industry is affected under the act of August 5, 1909, by the following paragraphs: "Paragraph 439: Furs dressed on the skin, not advanced further than dyeing, but not repaired, twenty per centum ad valorem; manufactures of furs, further advanced than dressing and dyeing, when prepared for use as material, including plates, linings, and crosses, thirty-five per centum ad valorem; articles of wearing apparel of every description, partly or wholly manufactured, composed of or of which fur is the component material of chief value, fifty per centum ad valorem. Furs not on the skin, prepared for hatters' use, including fur skins carroted, twenty per centum ad valorem.' Paragraph 573: Furs, undressed. "Paragraph 574: Fur skin of all kinds not dressed in any manner and not specially provided for in this section." From the statement heretofore made it will be observed that this industry consists of various incidental treatments, including carroting, of the fur of various small animals, and it therefore is apparent that it is the skins with the fur thereon of these various animals which forms the raw material and is the basic property of our product. All of this raw material is imported from other countries, principally the cold regions of Europe and Australasia. The fur used comes almost exclusively from animals not indigenous to North American climates, nor has it been possible to breed them in any climate but that of the above-mentioned countries and still retain the commercial characteristics of the fur proper (or fiber) which solely determines the use and value in the manufacture of hatters' furs. All of our product goes into the manufacture of fur-felt hats, and is purchased by hat manufacturers. The home consumption of hatters' furs during the past 20 years has not had a decidedly wide range, only increasing in slight proportions as the increase in the manufacture of fur-felt hats became stimulated by the demand of an evergrowing population; and yet the annual value of our production has undergone marked changes, due entirely to the wide fluctuations in the values of the skins in the foreign markets. This value has been regulated by the law of supply and demand, and the highest values have doubled the lower values as the markets changed, so wide has been the range. Indeed, it is only through liberal lines of credit extended by the domestic manufacturer and the ability to make quick delivery, that we are able to maintain our advantage over the European market. The duty of 20 per cent, standing by itself, is not sufficient to protect American labor against its foreign competitor. We are prepared to furnish the committee with the real facts respecting the cost of production in European factories, and our investigation proves that the labor cost in Europe is from 45 to 59 per cent less than the labor cost in the United States, which may be confirmed by data in your possession from Consular Reports, as well as absolute statistics in our possession. The European manufacturer has this additional advantage: Their factories are located in close proximity to where the fur skins are collected, substantially all the PARAGRAPH 439-FURS. chemicals with which the fur is treated are purchaseable cheaper abroad, and they have a recognized decrease in the cost of production (rent, office expense, etc.). The duty of 20 per cent is one of the lowest rates in the present schedule on manufactured products, and is a tariff for revenue only. In order that the committee may have before it accurate information from which they may intelligently estimate what benefit the consumer would receive in the event that the entire tariff wall should be removed from our home products and hatters' furs admitted absolutely free of duty, we beg to state that the hatters' furs in the finished hat represents from 7 to 10 per cent of its selling price in the retail store, varying according to quality, and if the duty on hatters' furs were entirely removed, it would mean a saving of less than the 20 per cent duty on the cost price of this hatters' fur, equal to from 3 to 5 cents on every hat purchased at retail by the consuming public. We arrive at this conclusion from the knowledge in our possession that the cost of the fur in a hat sold at retail at $2 (the popular price in this country) is not more than from $1.84 to $2.06 per dozen. It therefore appears that a hat which is sold to the consumer at $2 contains a little over 16 cents worth of fur, and that if the duty were entirely removed the reduction to the consumer, assuming that the consumer would be the sole beneficiary, would be 20 per cent of the fur value, or about 3 cents. This condition would result if the tariff would be entirely removed; if the rate is only reduced, then the difference would be fractional. The immediate beneficiaries of any reduction in the duties would apparently be the manufacturers of hats. The benefits of home manufacture, which would be destroyed by a reduction of tariff, are so apparent to the manufacturers of hats in this country that they are a unit in opposing any such reduction. Imported hatters' fur, before it reaches the hands of the consumer in the shape of a finished hat is handled by five industries, all presumably making some profit; (1) the importer of the hatters' fur, (2) the manufacturer of the hat body or cone (in many instances an independent industry), (3) the finisher of the hat body or cone (who shapes, blocks, and trims), (4) the jobber, and finally (5) the retailer. Is there any possible chance of the consumer receiving the benefit of any change in the present tariff rate on this commodity, and is there any member of this committee who is not impressed with the glaring fact that this benefit will in no manner accrue to the consumer.? We believe that the European manufacturer may be considered a fair competitor for this market and one who must always be counted upon as a factor in the industry. Certainly the present tariff is not prohibitory, and at its best is but a revenue rate under which the industry has been maintained for upward of 50 years. It has thus almost crystallized into a compact between the Federal Government and the manufacturers of hatters' furs. The rate of 20 per cent has remained inviolate through all tariff legislation since 1862, and irrespective of the increase or decrease in the tariff on other manufactured products, the duty on hatters' furs has remained unchanged. It has been this feeling of security that has permitted the industry to make progress, and yet at all times we have felt the keen competition of European manufacturers, and this competition has resulted in a fair consumption of imported hatters' furs by the hat manufacturers of this country. We believe that we have fairly illustrated that the consuming public can receive no possible benefit by any change in the present rate on our product and it follows that if the consuming public can receive no benefit from the lowering of the rate, and as there is no prohibitive tariff resulting in a consumption of the home product to the exclusion of any imported product, no reason exists which recommends a change. There is no combination, agreement, or understanding between the manufacturers of hatters' furs in the United States; no fixed price; no set standards. The closest of competition prevails at all times, and the fluctuating market of our raw material prevents any possible understanding or agreement to maintain a set price. Indeed, European competition makes this impossible. We respectfully call your attention to the construction of paragraph 439 of the present law. The subject matter "manufactures of furs, further advanced than dressing or dyeing, when prepared for use as material, including plates, linings, and crosses, "bears no analogy to the subject of "hatters' furs," but covers an entirely separate and distinct manufacture, and one in no way related to "hatters' furs.” Indeed, "hatters' fur," in its plain interpretation signifies the fur or hair removed from the skins of such animals as the rabbit, hare, nutria, and in some few instances the beaver, prepared and chemically treated into a product called "hatters' fur," because its sole and exclusive use is for the manufacture of the fur-felt hat, and is the component part of fur-felt hats, commonly called "derbys" and "soft hats." PARAGRAPH 439-FURS. Beyond the spelling of the word "furs" itself, it has nothing in common, nor does it bear any relation to other "furs" as embraced in the various paragraphs of the tariff schedule. We therefore respectfully ask that the portion of paragraph 439 "Furs not on the skin, prepared for hatters' use, including fur skins carroted, twenty per centum ad valorem, remain intact, but as a separate paragraph. Respectfully submitted. AARON NAUMBURG, Representing Hatters' Fur Industry of the United States. BRIEF OF THE CUFF HAT CO., BETHEL, CONN. Hon. THOS. REILLY. BETHEL, CONN., December 30, 1912. DEAR SIR: I am inclosing statistics showing the importations of fur felt hats during the past 10 years. You will note that the importations are going up from year to year like a flight of stairs and that the greatest gain has been made during the past four years. It will take very little figuring on the part of anyone interested to show that if the duties imposed by the Payne-Aldrich bill are reduced at all that the foreigners will have all our business, for under the present tariff they are doubling up on us every four years. The writer urges you to give this matter your careful attention, as it is a very serious matter to the hat business, which is not prospering at the present time. Thanking you for your kind consideration of this matter, and with kindest regards, I am, Yours, very truly, Importations of fur felt hats for fiscal years ending M. T. CUFF. Dozen. 7,819 9, 034 8,817 8, 143 14, 536 19, 194 21,892 32, 714 42, 940 46,009 37,398 BRIEF OF THE WALLACE & SMITH CO., MILWAUKEE, WIS. The COMMITTEE ON WAYS AND MEANS, House of Representatives, Washington, D. C. MILWAUKEE, January 28, 1913. GENTLEMEN: Referring to paragraph 439, under Schedule N of the present tariff, we beg to call your attention to the part of the schedule referring to rough furs, such as goat plates and dog mats. These particular items are used very extensively in the manufacture of common lap robes and common coats over the entire Northwest and take the place of the cheap buffalo robes of former years. These common goat plates and goat mats are tacked together in foreign countries merely for the purpose of giving them a commercial size, and, as this tacking is absolutely worthless, it is all ripped out again and the skins are reworked in this country. Under the circumstances the mixing of these common goods with high-class furs is a great hardship to every farmer and consumer in the entire Northwest, as it raises the duty from 15 per cent under the Dingley tariff to 35 per cent under the present tariff without any benefit to anybody. We respectfully ask that the duty on this class of goods be either reduced to the old tariff or entirely abolished, as it would give the entire Northwest an article that they need badly at a lower price, as it is used almost exclusively in the Northwest for common robes for the common people. Respectfully submitted. Yours, very truly, THE WALLACE & SMITH CO., 1 Full year not yet available. The present tariff bill was passed in 1909. PARAGRAPH 439-FURS. BRIEF OF THE RUSSIA FUR & TANNING CO., MILWAUKEE, The COMMITTEE ON WAYS AND MEANS, WIS. MILWAUKEE, WIS., January 28, 1913. House of Representatives, Washington, D. C. GENTLEMEN: Referring to paragraph No. 439 under schedule N of the present tariff, we beg to petition your committee in regard to the rough furs, which are commonly known as goat and sheep "rugs" and "mats" and dog "mats" and ask that this class of furs be separated from the general class and be put by themselves with a special rating of their own. We ask this for the reason that they are of an entirely different class of material, being cheaper and rougher than what are commonly known as "fancy furs." However, on account of not having separate classification, they are included in the second part of paragraph No. 439 under "Manufactures of furs further advanced than dressing and dyeing and prepared for use as material, including plates, linings, and crosses, 35 per cent ad valorem," thus putting them on an equal basis with goods which are already prepared in the greater part for manufacture. We give you the following arguments in favor of a separate listing and reduction. Firstly. We have no ax to grind. We neither gain nor lose on account of the higher duty. The only effect which it has is to make the manufactured article cost more to the consumer, without giving to anyone any added protection whatever, as this class of furs is used only for the manufacture of carriage robes and cheap grade of men's fur coats, none of which are imported into this country in the manufactured state. Secondly. The term "rugs" and "mats" is simply the trade name for certain standard sizes of furs and has no meaning in any other sense than this. While they are not one separate skin, they are simply pieced out on the sizes with a loose stitch and basted to bring them up to the standard measurement. This stitch is absolutely worthless as far as being of any use in the manufacturing, it being necessary to rip the sewing, cut the "rugs" and "mats" apart, rematch them, and sew them before they are of marketable value, as far as manufacture is concerned. The principal reason for these rugs being imported in these sizes is because the importer in this country is better able to ascertain what amount of material he is getting than if he bought them in the regular skin shape, the skins being of variable sizes. Thirdly. It requires just as much work to manufacture a robe or coat from these "rugs" or "mats" as it would to manufacture from natural shaped skins. Fourthly. The natural shaped skins which are no further advanced than these "rugs" and "mats" can be brought in at 20 per cent, even though they may be dyed abroad. The fancy fur plates such as squirrel, etc., even though dyed can be brought in at the same rate of duty (35 per cent) as our "rugs" and "mats" which we import in the undyed state entirely. What we claim is that China goat and sheep "rugs" and "mats" and dog "mats" loosely basted together to make a standard size, not machine sewed, should be under a separate heading, so worded at 20 per cent duty. In making this appeal to your committee, we beg to impress upon you the fact that this will reduce this class of skins to the old rate of duty at which they were always entered under the old Dingley tariff, that the advance of 15 per cent made in the last revision of the tariff simply increased the cost of the manufactured article to the consumer, giving no protection to any manufacturer in this country, and that under the present tariff, it would be advantageous for us to have our raw material dyed abroad instead of in this country, as we are doing now, and importing it in the dyed state, being able to do so without any increase in the tariff rate, and it could be stated in the separate clause for China goat and sheep "rugs" and "mats" and dog "mats" loosely basted together to make a standard size, not dyed and not machine sewed, to be admitted at 20 per cent duty. This would protect us in the fancy fur schedule. We beg you to take this all into consideration and give the matter an unbiased decision. RUSSIA FUR & TANNING CO. Very truly, yours, PARAGRAPH 440. PARAGRAPH 442-HUMAN HAIR. Fans of all kinds, except common palm-leaf fans, fifty per centum ad valorem. PARAGRAPH 441. Gun wads of all descriptions, twenty per centum ad valorem. PARAGRAPH 442. Hair, human, if clean or drawn but not manufactured, twenty per centum ad valorem; manufactures of human hair, or of which human hair is the component material of chief value, not specially provided for in this section, thirty-five per centum advalorem. HUMAN HAIR. BRIEF OF ALEX. E. KLAHRE, NEW YORK, N. Y., IN RE HUMAN HAIR. The COMMITTEE ON WAYS AND MEANS, House of Representatives, Washington, D. C. NEW YORK, January 28, 1913. DEAR SIRS: We would respectfully call your attention to paragraphs 442 and 583 in the present tariff bill which relate to human hair. Paragraph 442 reads: "Hair, human, if clean or drawn but not manufactured 20 per cent. Manufactures of human hair or of which human hair is the component material of chief value not specially provided for in this section, 35 per cent.' Paragraph 583 reads: "Human hair, raw, unclean and not drawn, free." Owing to the conflicting interpretation of these paragraphs, importers have had considerable trouble in the past. In some instances duties have been imposed and in other cases hair which has been assessed as dutiable previously, has been brought in as raw material. So-called cleaned and drawn hair is regarded by the trade as raw hair, as it has to go through the identical process of washing, cleaning, bleaching, and dyeing as hair on which there has been no question raised as to it not being raw material. The cleaning and drawing in most cases is done for the purpose of complying with the sanitary laws, before shipment from foreign ports. There are employed in this city in the manufacturing of human hair into curls, switches, etc., about 10,000 persons, and although the argument may have been used that this is an industry of a luxury and not of a necessity, if a duty is imposed upon human hair, it will inure to the benefit of the foreign manufacturers and will throw out of employment in our country a large number of persons employed in this industry. In previous tariff laws the question has been raised a number of times as to what might be called raw hair, and we would call your attention to two decisions: Treasury Decision 9441, which reads as follows: "TREASURY DEPARTMENT, June 17, 1889. "Human hair, partially cleaned. Lewisohn v. Mogon. "SIR: The department is in receipt of a letter dated the 22d ultimo from the United States attorney for the southern district of New York, in which he reports the trial of the case of Leonard Lewisohn v. Daniel Mogon, collector, which was had before Hon. E. H. Lacone and a jury in the United States circuit court for said district on the 16th ultimo, which resulted in a verdict in favor of the plaintiff. The question involved was as to the proper classification of certain importations of Chinese human hair which was subjected to duty by the defendant (collector) at the rate of 30 per cent ad valorem, under the provision in Schedule N (T. I. 444) for human hair if clean or drawn, but not manufactured, but which the plaintiff claimed to be uncleaned and not drawn and to be dutiable at the rate of 20 per cent ad valorem, under a clause in the same paragraph for human hair drawn, unclean and not drawn. "The United States attorney reports that the proofs adduced in the trial showed that while the hair had been drawn to a little extent and to have been cleaned a |