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as against America, the mixing of these composition materials, commonly called "plastic or mineral composition," being an American idea, and the manufacture of game counters, or, as we call them, poker chips," also being an American idea.

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The investment of capital in ours and the other composition manufacturers of poker chips will amount to $250,000 to $300,000, on which at the present time there is absolutely no return by reason of the fact that the largest consumption of it being of the composition cheaper grades known as "plain, embossed, and fancy engraved," all of which are made in Japan, and their importations being large enough and their prices sufficiently below the American manufacturer to use up the consumption of these game counters, all of which would be used and bought here in this country if this competition did not exist under the present unclassified tariff.

In the humble opinion of the other manufacturers and ourselves the duty should lie between 50 and 60 per cent of the invoice value, in order to give the American manufacturer and the laborer that protection that he is entitled to, and will give him the business taken away from him by this Japanese importation; and will also give the manufacturer an opportunity to reemploy the large number of hands formerly employed in this industry, and in their train the large number of female employees.

We hope that your honorable committee will fully consider and weigh carefully the representations made by us, and that they will insert into their revised tariff, under the heading of "Miscellaneous manufactured articles," a paragraph on game counters largely composed of shellac and clays, commonly known as "plastic or mineral composition game counters," at a specified duty of 50 to 60 per cent. We do not ask that the Japanese shall be barred from offering their goods in our market, but we wish a duty placed between the figures named, in order that there may be equality in the asking price of the American and Japanese manufacture.

Yours, very truly,

THE G. H. HARRIS COMPANY,
G. H. HARRIS, Secretary.

ELECTRIC SPARKLERS.

[Section 6.]

THE EASTERN TOY HOUSE WISHES ELECTRIC SPARKLERS CLASSIFIED AS "MANUFACTURED METAL NOVELTIES."

PROVIDENCE, R. I., December 6, 1908.

COMMITTEE ON WAYS AND MEANS.

GENTLEMEN: The pyrotechnic novelty commonly known as "electric sparklers," which we manufacture, which article for several years has been imported from Germany (though more recently has also been manufactured in this country), should, in our humble judg ment, be classified as "manufactured metal novelties." Our reason is based upon the fact that the component parts entering into the manufacture of this article are 87 per cent metals and 13 per cent chemicals, these proportions having been found by careful analysis.

This would clearly place electric sparklers in the class named above. Consequently the item should be taxed at 60 or 65 per cent duty. Under this fair and honest classification of imported electric sparklers in the various sizes and styles, the home industry will be reasonably protected, and should be, as the American manufacturers are competent to supply the demands of the United States. If fairly protected, their struggle against foreign invasion at the hands of European manufacturers and their resident agents in this country would be lessened.

Yours, respectfully,

WILLIAM GOLDSCHINE, Jr.,
Proprietor Eastern Toy House.

DRAWBACK.

[Section 30.]

MERCHANT & EVANS COMPANY, PHILADELPHIA, PA., OFFERS SUGGESTIONS RELATIVE TO APPLICATION OF DRAWBACK LAW TO MANUFACTURED ARTICLES.

PHILADELPHIA, PA., July 17, 1908.

Hon. SERENO E. PAYNE, Auburn, N. Y.

DEAR SIR: We take the liberty of addressing you relative to the following suggested amendment to the customs tariff, because we understand that, as chairman of the Ways and Means Committee, you are now occupied in considering a proposed revision of same. The amendment which we propose to the tariff or at any rate to the Treasury regulations governing same, ought to be really acceptable to everybody, although it did not appear to be so when Congressman Lovering, of Massachusetts, advocated it several years ago.

We propose that when a manufacturer has imported or received on certificates of importation and delivery a certain quantity of foreign material, he should be allowed the drawback of 99 per cent of the duty paid on same when he exports his manufactured articles, although said manufactured articles may have been made up of the same quantity of similar domestic material.

We know of a number of firms who could increase their foreign business under the above-changed ruling, as it would enable them to actually take advantage of the tariff provision allowing a rebate of the duty paid on imported material going into the manufacture of exported articles.

The necessity of segregating this foreign material from the domestic material in and through each department and process of manufacture under the present regulations is so troublesome and expensive for most of those who are not very large manufacturers or who do not manufacture almost entirely for export that the number of American manufacturers who find they can actually avail themselves of the aforesaid tariff provision under present regulations is comparatively small, although quite a large number of manufacturers do make application for the establishment of a rate of drawback, only to find out later that under present regulations it is not practicable for them to very frequently take advantage of the rebate of drawback granted.

We respectfully submit that a change in Treasury regulations, which we have outlined above, would not enable anyone to defraud the Government and, on the contrary, it would eliminate a tendency for an exporter to swear that his raw material was imported when quite possibly his imported raw material may very naturally have become mixed in his factory with the domestic, especially if same has to be put through a number of processes.

Commending this matter to your attention, we remain, sir,

Yours, respectfully,

MERCHANT & EVANS COMPANY,
POWELL EVANS, President.

PHILADELPHIA, PA., July 23, 1908.

Hon. SERENO E. PAYNE, Auburn, N. Y.

DEAR SIR: We thank you for your favor of the 20th informing us that ours of the 17th will be brought before the attention of your committee, and with further reference to the revision of the tariff, we respectfully suggest modification of sections 7 and 19 of the customs administrative act as far as they concern patented articles made and sold abroad at enormous profits.

The writer secured the rights in America for the Hele-Shaw patent clutch and clutch plates, and has spent considerable time and money in endeavoring to push the business, and has had to import quite a number of patented bronze clutch plates, which are of course dutiable at 45 per cent ad valorem.

Now, the manufacturers abroad charge very big prices for their patented clutches and clutch plates, and can get these prices over there for them, but the circumstances in this country are such that it is not practicable to get enormous profits on these goods, and the manufacturers of these goods in Europe (realizing this) have agreed to sell the writer these bronze patented plates at the cost of manufacture plus 10 per cent, and the goods are so invoiced to him.

But in making customs entries on these bronze plates, the writer of course having before him sections 7 and 19, etc., of the customs administrative act, is obliged to add to the purchase price of these bronze plates on his customs entries quite a considerable amount to bring them to the foreign market value, on which the duty of 45 per cent is to be assessed, and the consequence is that this duty becomes quite onerous.

Now, we respectfully suggest that a modification of the customs administrative act be made, to the effect that on importation of patented articles from abroad on which the makers abroad are able to get over there a very big profit and price, the American importer shall be allowed to use his purchase price as the basis of valuation for duty where that purchase price is, shall we say, 10 per cent above the cost of manufacture abroad.

We believe that such an amendment to the customs administrative act would afford a just and proper relief in a number of cases of similar nature to that of the writer.

Respectfully, yours,

MERCHANT & EVANS COMPANY,
POWELL EVANS, President.

Hon. SERENO E. PAYNE,

PHILADELPHIA, PA., December 2, 1908.

Chairman Committee on Ways and Means,

House of Representatives, Washington, D. C.

DEAR SIR: Referring to our letter of July 17, we regret to find ourselves unable to be present at Washington on the 4th instant, but we hope that your committee can seriously and favorably consider the aforesaid letter, copy of which we inclose you.

Whatever may be said in favor of or against changing the tariff schedules, surely everybody ought to be in favor of facilitating the obtaining of the drawback of duty on raw materials imported for the purpose of manufacturing here in America goods for a foreign market, and the writer would actually imagine that this idea would be supported even more enthusiastically by an advocate of a high duty than by opponents of same.

Everybody is agreed that whatever advantages or disadvantages a manufacturing country may have from the absence of a tariff or from a low tariff, it at any rate has the advantage of getting readily and at low cost the material for the manufacture of articles for sale in foreign countries, and the gentlemen who have for years helped to write up a high tariff for this country have as an offset relied upon the fact that this Government allows a drawback of 99 per cent of the duty paid on imported material which goes into the manufacture of exported articles.

Now if your committee would do some work with a view to simplifying the obtaining of this drawback and particularly if it would endeavor to arrange something on the lines of the attached letter of July 17 there would be real life and vitality and strength in the claim of the friends of protection that our tariff does not prevent our manufacturers from readily competing in foreign markets.

The writer regrets that owing to illness he has been unable to give time to ventilating this matter among the different manufacturers, but we have before us letters from manufacturers who are in favor of the proposition outlined in our letter of July 17, and the fact is that present regulations are troublesome and expensive for most of those who are neither large manufacturers nor manufacturers almost entirely for export, and as pointed out in the attached letter what we therein propose would not enable anyone to defraud the Government, as no man could get more drawback than 99 per cent of the duty which was paid on the imported goods, for which he would have to produce a certificate of delivery, just as he does to-day. Therefore the fact that (if, for instance, it was tin cans that he was exporting) he did not keep his domestic tin separated from his foreign, and that the particular cans that he was exporting might have been made of part of each would not work any injustice to anyone whatever, while, on the other hand, it would enable a comparatively small manufacturer and one who does not chiefly manufacture for export to have a try at the foreign market, and we are all of us agreed no matter what may be our political faith that the better the share of foreign trade that we obtain the better it is for this country.

The writer has tried to put in few words what he would have been glad to have had the pleasure of saying to your committee and feels confident that your committee will give serious consideration to this matter and not be deterred therefrom by some superficial objection,

such as may be readily raised against any first-class proposition whatever.

Yours, respectfully,

MERCHANT & EVANS COMPANY.
DOUGLAS LEESE,

Assistant Treasurer.

Hon. SERENO E. PAYNE,

PHILADELPHIA, PA., January 8, 1909.

Chairman Ways and Means Committee, Washington, D. C. DEAR SIR: Since we had the pleasure of writing you on July 17 last and also on December 2, relative to the simplifying of the matter of obtaining drawback on imported articles used by manufacturers who export their product, we have received several indorsements from American manufacturers who export to some extent, but who would be able to export to a greater extent if our suggestions were carried out. These suggestions, I understand, were more or less embodied in what is known as the "Lovering bill." We are very busy people and have not time to go around the country getting indorsements for this proposition, but we know from business experience that there must be scores of American manufacturers who are largely prevented from trying for export business by the fact that it is impracticable for them to keep their domestic and foreign material separate in all the stages of manufacture of the articles which they might otherwise export in quite large quantities.

We suggest that the present Treasury requirements that an exporter shall swear that the articles exported were made from the identical material imported is simply offering a premium to the man who is unscrupulous to the extent that he does not mind swearing to what he really does not know to be a fact, and what it might often be impracticable to make a fact, and we further suggest that those manufacturers who are too scrupulous to swear to what they do not positively know to be true are debarred from trying to get export business because the bulk of their trade being domestic it would not pay them to have separate bins and racks and separate accounts for all the foreign raw material in its various stages of manufacture, unless they were a very large concern and doing quite a large export business. The writer can not see where the Government would suffer any injustice if the domestic raw material did enter into the imported articles as long as the exporter produced certificate of delivery, etc., showing that he had received an equal amount of imported material on which the duty has been paid.

It occurs to the writer that whatever difference of opinion there may be as to this rate of duty or that rate of duty on tín plates, for instance, there ought not to be any difference as to the advisability of giving any American manufacturer a chance to get export business by obtaining his drawback in the manner indicated above, as no one could obtain a drawback on any cans exported, for instance, without producing certificate showing delivery to him of an equal quantity of imported tin plates.

Yours, truly,

MERCHANT & EVANS COMPANY, Per D. LEESE, Assistant Secretary.

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