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American manufacturers to buy a large part of their material in European markets, where the foreign manufacturers have the advantage of being on the ground.

The product of the foreign comb manufacturers has always found a market in this country, but under present conditions there is an increase in the number of sizes and styles, many of them copies of our makes, which enter our market and drive out the domestic goods. This competition is more keen and difficult to meet each year, particularly in view of the fact that the scale of wages we are required to pay has advanced.

A very considerable item of comb imports consists of fine handmade combs, which sell in all the department stores and among the dealers in better goods. Some of these goods manufactured in France are made in a manner that we could not presume to have sufficient tariff to enable us to compete. In these goods the item of hand labor figures very largely. While in France in 1904 I was informed by horn brokers and other men familiar with the business that it is the custom of the large manufacturers to prepare the horn stock up to a certain point and then farm it out to families,

who take the work home and there put upon it the fine hand labor which produces the superior article. For this work the famílies, consisting of father, mother, and several children (sometimes five or six), receive the equivalent of about $5 for a full week's work. This statement had previously been made to me by Frenchmen in this country who were familiar with the comb industry of France.

There is also a line of very cheap combs coming here from Italy, Scotland, and the Netherlands which we can hardly expect to compete with. Among these are pocket combs in cases, which are delivered in New York for $1.25 per gross, duty paid, or of a line of fine-teeth combs at ridiculously low prices.

While thousands of dollars of these goods are continually shipped here, we do not advocate such protection as would give the American manufacturers a monopoly in this market. The burden of our plea is that the tariff should be high enough to enable the American manufacturer paying decent wages to workmen, to make reasonable profits, and retain the market which legitimately belongs to them.

While there has been a large increase in the consumption of horn combs in this country, the industry has not advanced correspondingly. The decline in the cleared horn line of dressing and fine-teeth combs is particularly marked, the foreign manufacturers having this field practically to themselves, although most of our factories are equipped for this work, and if it were possible to compete could give employment to a goodly number of workmen.

If a change were made in the tariff schedule, either lowering or increasing the rates, it would not change the price of the combs to the consumer except in a limited group of the article. The price that is charged for the comb at retail in this country, for probably 75 per cent of the combs sold, is 10 cents. The only effect of lowering the duty would be to enrich the dealer at the expense of the manufacturer, and by the increase of importations reduce the output of our factories, which would result in the employment of less workmen and possibly the retirement of the industry, in which case the foreigner would undoubtedly increase his prices to this market.

On the other hand, an increase of duty would not increase the price to consumers, the revenue to the Government would probably not be materially diminished, and there would be an enlargement of the industry, which would give employment to more American labor.

Mr. James W. De Graff, representing the Noyes Comb Co., of Binghamton, N. Y., writes:

“About 15 years ago there were 11 horn-comb factories in this country, and to-day there are but 4, as the inadequate duty of 30 per cent does not allow the American manufacturer sufficient protection to enable him to compete with the low wages paid in Aberdeen, Scotland, and in Germany.

“Most of the importations into this country come from one horn-comb works in Aberdeen, Scotland. Our factory obtained a United States patent on a metal-back comb, where the back extended over the ends, forming the end teeth, which patent expired a number of years ago, and the fair market value for this article is $7.25 net, but the competing comb offered by the Aberdeen Comb Works can now be landed in New York City, freight and duty paid, for $5.70; and beg to say that this comb can not be made in America to meet the foreign price mentioned above. Taking 100 as a unit, the wages amount to 45 per cent and a superintendent's charge of 5 per cent. Notwithstanding the fact that foreign combs are brought into this market at the price mentioned above, the consumer pays exactly the same price at retail for his goods as he does for ours, as the comb can not be retailed at 5 cents, and is universally sold at 10 cents, so that the difference in cost to the wholesale merchant is absorbed by him and the retailer at the expense of American labor.



"The wage scale in the Aberdeen Comb Works, Scotland, of which we have positive information, as per attached sworn affidavit, is as follows: Managers receive salaries not exceeding $15 per week; foremen from $6 to $7.50 per week; the best workmen from $4 to $6.50 per week. Women earn an average of from $2 to $3, and boys, who must be 14 years old, start at $1 per week, and they receive this rate for a considerable period.

"As comb making is not considered a man's work in Scotland, outside of manager, foremen, machinists, and a few men for very hard work, the larger proportion of employees are women and minors.

“On the contrary, our labor is principally men, whose wages are about four times as large as the women who do similar work, and the boys employed by us receive at least four times as much as boys abroad.

“A conservative estimate of the relative amount of the labor cost as between the foreign and domestic manufacturers is that the foreign wages for the same amount of labor would be less than 334 per cent of the American wage cost. These figures relate particularly to Scotland, and are well within the facts. In other countries the rates would probably be lower.”

[Copy of affidavit.]

FRANKFORD, PHILADELPHIA, PA., December 31, 1908. I, John Rogers, of 4151 Paul Street, Frankford, Philadelphia, Pa., was in the employ of the Aberdeen Comb Works Co., Aberdeen, Scotland, for 42 years. During this time I worked in the various departments and for a number of years I was employed as foreman.

The rates of wages paid by this firm at the time my employment with the said firm ceased were as follows:

Managers, average wages not over 60 shillings, or abour $15 per week.
Foremen, average wages not over 25 to 30 shillings, or about $6 to $7.50 per week.
Men, average wages not over 16 to 27 shillings, or about $4 to $6.50 per week.
Women, average wages not over 8 to 12 shillings, or about $2 to $3 per week.

Boys, average wages not over 4 to 5 shillings, or about $1 to $2 per week; this latter rate gradually increasing as the boys reach manhood.

I have been in constant correspondence since I left Aberdeen with employees of the comb works who are my old friends and neighbors, and I am sure that rates have not advanced, but rather have decreases since that time.

John R. ROGERS, John Rogers, being duly sworn according to law, deposes and says that the facts set forth in the above statement, to which he has attached his signature, are true to the best of his knowledge and belief.

JOHN R. ROGERS. Sworn and subscribed to before me this 31st day of December, 1908. (SEAL.)


Notary Públic. Commission expires January 27, 1909. G. W. Richardson Co. and Wm. H. Noyes & Bro. Co., of Newburyport, Mass., write as follows:

“This industry is principally carried on in the States of Massachusetts, Pennsylvania, and New York, and although the various parties engaged in same have given strict attention to the details of the business and have been energetic and ingenious in inventing labor-saving devices, the business has not kept pace with the growth of the country

“This is largely due, in our opinion, to the strong competition of the foreign manufacturers, notably those of Great Britain, France, Italy, and the Netherlands, who are sending large quantities of combs to this country and underselling us, notwithstanding the present duty:

“We consider that the low wage scale and also low cost of supplies abroad is the secret of their ability to do this, and the cost of the above items is fully 50 per cent of the total cost.

“The supplementary brief recently submitted by Mr. Walton gives facts in relation to the wage scale in Scotland which are of great importance when considering what is a fair measure of protection, and we call your especial attention to same.

“As women perform much of the heavy work in Scotland, for which we employ men at a rate of $10.50 to $13.50 per week, it is clear to us that the total labor cost in Aberdeen would not exceed 30 to 33} per cent of what it is in this country.



"One of our principal items is a 7-inch metal-guard tooth comb, with a metal back of nicolene. This comb has been copied by the Aberdeen people, and is now sold in this country by them at $5.70 per gross, duty and freight paid. “A fair price for this is from $7 to $7.50 per gross. The comb retails at 10 cents."


On the basis of cost prices in Scotland a tariff of 50 per cent would merely meet the difference in wages alone, on the class of combs in general use in this country.

As stated by us in the briefs submitted to the Ways and Means Committee and printed in their tariff hearings No.36, pages 5395–5397 and in No. 47, pages 7075-7077, the proportion of labor cost in the medium goods (most commonly used) of horn combs in America is about 50 per cent of the total cost.

Take a comb that will cost in America, as example, say, $6 per gross The labor cost would be 50 per cent..

$3.00 The labor on same article in Scotland.



Which would give advantage to foreigner of......

2.00 And make their cost only...

4.00 To equal the American cost, we must add 50 per cent.


6.00 You will note that this relates to the medium grade of goods, which are made with considerable machinery, but for high-priced goods, which require more handwork, this percentage would be inadequate.

While formerly the foreign manufacturers confined themselves to the peculiar styles of their own countries which were salable here only in limited quantities for perhaps a decade, they have made a careful study of our market and methods of manufacture and have gradually imitated our largest sellers, and though their product is still somewhat crude have made great inroads on the business of American manuiacturers. This, of course, is only made possible by the low wage rate they pay.

In one style of comb known in the market as the metal end tooth comb, a comb with a nicoline (nickel-plated zinc) back and end teeth, which material they purchase lower in Europe than we can buy it here, their competition has been especially keen.

The factories of the Aberdeen Comb Co., Aberdeen, Scotland, which is a combination of the factories of Great Britain, and in this country would be denominated a trust, is especially active and determined to capture the American market.

The custom now firmly entrenched in the United States, and very largely brought about by the syndicate stores, of selling small wares at 5 or 10 cents has a determining influence on the prices the comb manufacturers can get for their goods. Except for a few styles especially well made and sold in limited quantities to a select trade it would be suicidal for us to attempt to ask prices that would not permit the goods to be retailed at 10 cents.

Owing to this trade condition a change of duty either upward or downward would have no effect upon the consumer.

In Europe we found the prices at retail varied very much, running from the equivalent of our 5 cents up to a franc (20 cents) and shilling (about 25 cents), and in most instances, especially in the cheaper combs, the retail prices are equal to our American prices.

From these facts we can fairly assume, were the Americans driven out of business from lack of sufficient duty to meet wage differences, it would not be long before the foreign prices would be advanced and the consumer here be compelled to buy inferior goods for 5 to 10 cents or pay higher prices.

The importations of horn combs have been quite large.

According to reports of the Department of Commerce and Labor, which were handed to the writer, the importations were as follows: Year ending June 30, 1911. $155,265, duty paid; year ending June 30, 1912, $130,272, duty paid.

During the latter year domestic manufìcturers were reduced in their sales in about the same proportion. These figures w uld indicate imports in excess of 25 per cent of the domestic manufactures, which clearly indicates that the present rate of duty is by no means prohibitive.

Owing to the fact that horn combs were not classified in previous tariff bills, but were imported under the general head of the “Manufactures of horn,” which included many other articles, it is impossible for a comparison with former years to be made


with any accuracy, We are inclined to believe, however, that because in the particular combs which sell most largely the foreign inanufacturers lowered their prices sufficiently to meet the difference in the rate of duty the sales have been approximately as large.

The equipment of the horn-comb manufacturers for a number of years back, while it has not been materially increased, is sufficient to produce an excess of production, and each manufacturer is necessarily seeking more business continually:" Of course the effect of this is to produce sharp competition; sometimes it takes the form of improved quality and at other times is a question of price, so that at home we have competition that would prevent any serious advance in prices. In view, however, of the large imports, and the fact that our foreign competitors are aggressive, the American manufacturer is compelled to sell as cheaply as possible in order to maintain business enough to keep the factories going.

The countries from which we find competition, all of which have the low-wage scale, are Great Britain, France, Germany, and Italy.

The Aberdeen Comb Co., of Aberdeen, Scotland, who are especially aggressive, and are making very strenuous efforts to capture the trade of this country, and who imitate our goods more than the others, are the sharpest competitors we have from foreign

Some years ago all of the important horn-comb factories in Great Britain formed a consolidation which would be denominated a trust if located in this country.

In view of all these facts, which show that our present duty is not prohibitive, that the consumer is not overcharged, and that a change of duty could not benefit the consumer but would injure the industry very seriously, compelling either loss of occupapation or lower wages to the workingman, we trust that the present duty will be retained.



P. 220.)


(Paragraph 463--Schedule N, Combs.) The WAYS AND MEANS COMMITTEE,

House of Representatives, Washington, D. C. We, the undersigned, importers and jobbers of notions, respectfully request a reduction in duty under paragraph 463 of Schedule N, especially the last two lines: “Combs composed wholly of horn, or combs of horn and metal, 50 per cent.”

We ask that this rate be reduced and suggest a reading of the clause in the paragraph as follows: “Combs composed wholly of horn, or galalith, or keronyx, 20 per cent ad valorem.'

Under the tariff act of 1897 galalith or keronyx combs were held to be dutiable at 20 per cent, and the importations during the year 1908 of these goods amounted to $54,528.

Strangled by the prohibitive act of 1909, however, the importations of these goods for the year ending June 30, 1911, fell to only $9,347. (See Imports of Merchandise,

The act of 1909 did not specify galalith or keronyx combs, but the same had been classed under the former tariff act under section 6 as non-enumerated articles at 20 per cent; but in Treasury Decision 30725, General Appraisers 4047, the United States General Appraisers held that galalith combs should be assessed at the same rate of duty as horn combs under the similitude paragraph of the present act, 481, thus imposing a duty of 50 per cent upon this cheap and universally used article.

Galalith or keronyx combs are much cheaper than rubber combs and are used very universally by the poor people who can not afford either horn or rubber goods.

The advance of the duty upon the same from 30 to 50 per cent under the act of 1909 has practically prohibited the importation of them, and as a result the home manufacturer of the cheaper grades of the dangerous celluloid comb has been enabled to greatly enlarge his business.

Imports of merchandise (p. 24) for the year ending June 30, 1912, reports the total value of imports of combs for the year to be but $86,426 and the duty thereon $13,423, more than 90 per cent of which refers to the expensive horn combs and covers the importation of all horn and metal combs including many fancy horn goods with ornamental metal trimmings used as back combs.

Under the tariff act of 1897 horn combs were assessed at only 30 per cent and the change of rate shows the effect upon importations as the following figures will demonstrate.


Referring to imports of merchandise, page 137, it appears that for the year ending June 30, 1907, the total value of importations of combs was $277,945; for the year ending June 30, 1908, $237,945; while for the year ending June 30, 1910, the importation was but $182,619.

Since 1909 the imporations have been seriously reduced and have steadily decreased ever since, to the loss of the revenue, to the injury of the home consumer who must pay the extra protection created by the increased rate to 50 per cent directly to the pockets of the American manufacturer. This it was that the Republican tarif *reduced the cost of living" and lost control of the country in consequence.

Incidentally this increase in tariff has largely improved the sale of the cellubid comb, which we charge to be a dangerous article on account of its inflammability and liability to explosion and spontaneous ignition. Many serious accidents have occurred from the use of these combs and we quote two items from the public press as follows:

(Extract from Evening Express, Oct. 17, 1911.)

“Wearing a collar and hair comb made from celluloid, a woman has met with her death by burning. She was carrying a lighted lamp upstairs, when she slipped, and the ignition of the celluloid articles caused severe burns to her head."

(Extract from Evening Gazette, Oct. 22 1912.)

"A woman named Margaret Downie, who resided at 38 Kenmure Street, Pollockshields, has succumbed in the Victoria Infirmary, Glasgow, to burning injuries received about a fortnight ago while on a visit to friends in Bo'ness. The unfortunate woman had been standing in front of the fire dressing her hair with a celluloid comb, which slipped from her grasp and fell into the fire. Instantly a flame shot up which ignited her clothing, and she sustained serious injuries about the body, arms, and head. At the time of the accident she was conveyed to the Glasgow Infirmary, where she died yesterday.'

Finally, we desire to submit statement of American sales of imported combs for the years 1906 to 1909, inclusive, and for the years 1909 to 1912, inclusive, showing a falling off of more than 50 per cent in importations and sales on account of the exces. sive duty rate under the present tariff act, as clearly set forth in Imports of Merchandise, pages 137, etc.

For all the above reasons we earnestly pray that the duty on combs be reduced as herein set forth to 20 per cent ad valorem.

Counsel for Importers and Foreign Manufacturers,

32 Broadway, New York. HOTEL New WILLARD, Washington, D. C.



(From Glasgow News of Sept. 10, 1912.)

The dangers arising from the storage of celluloid is occupying the attention of the corporation, and has resulted in an important recommendation by the fire-brigade committee in connection with the regulation and control of the storage of the infiammable material. They propose that the town clerk be instructed to forward a copy of firemaster Waddell's report to the home office.

In his report Firemaster Waddell states that the storage of celluloid is a matter requiring careful consideration. On the 16th instant he visited certain establishments in the city where large quantities of cinematograph films are kept. In one instance he found a large room, which contained 2,000,000 feet of film. He is of the opinion that the storing of films in many premises visited is most unsatisfactory, and is charged with great dangers. The firemaster urges that immediate steps be taken to have this serious state of affairs rectified.


Mr. Waddell, in a final note, adds: Some dubiety exists as to whether celluloid is really an explosive. Personally, I am convinced that celluloid is, under certain con

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