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PARAGRAPH 591-RUBBER.

only. Many oils, minerals, etc., produced in this country are used in the manufacture of rubber goods. Rubber manufacture is very largely dependent upon these substances, so that if the industry was suddenly seriously affected by legislation there would be confusion in the linseed, cottonseed, and castor-oil markets. Merchants dealing with such dissimilar substances as wax, naphtha, sulphur, talc, turpentine, and even copper and cotton would also be affected by any radical change in the rubber industry.

Of all grades of crude rubber, approximately 25 per cent thereof is devoted to the manufacture of mechanical goods, such as rubber hose, packing, and the like, 30 per cent for buggy, truck, and automobile tires, 30 per cent for rubber footwear, rubber clothing, and the like, and 15 per cent for druggists' sundries, surgical goods, etc. Thus 80 to 85 per cent of crude rubber is used in the manufacture of articles of utility, and any tax imposed falls not on luxuries but on necessities.

There are 275 rubber factories in the United States, divided as follows: Massachusetts, 55; New Jersey, 58; Pennsylvania, 14; Washington, 1; New Hampshire, 1; Rhode Island, 10; Ohio, 35; California, 3; New York, 49; Connecticut, 17; Missouri, 2; Illinois, 9; Michigan, 2; Indiana, 2; Delaware, 1; Minnesota, 1; Wisconsin, 4: South Carolina, 1; Oregon, 1.

The Thirteenth Census of the United States shows that in 1909, 57,487 people were employed and engaged in the manufacture of rubber goods industry; that salaried employees were paid $8,205,000; that wages paid were $25,620,000; that cost of materials was $126,274,000, and that the total value of products was the sum of $202,886,000. These figures, however, while showing a very large industry affected by proposed legislation, by no manner are representative of the situation at the present time. The development of the rubber industry from the point of consumption alone is apparent to every observer. New stores where rubber goods of different kinds are sold are daily coming into existence. New kinds of goods where rubber is used are daily coming into consumption. The consumption of these goods is so different and so much larger to-day that the figures of two years ago are decidedly misleading. In the last two years the strides in this business have been enormous. My own judgment is that instead of 57,500 there is nearer 90,000 people employed; that instead of the salaries of salaried employees being $8,125,000 it is nearer $12,000,000; that instead of the wages being about $25,500,000 it is more than double that now. These figures, however, are but a surmise, and they are the best that I can submit. Accurate figures can not be given at this time. These are, however, but infant industries groping their way to a safe basis, interference with which by the imposition of a tax hitherto unimposed is calculated to be, if not disastrous, disconcerting, especially as you would, by imposing a tax on raw material used in these industries, place in competition with these new, struggling, and rapidly growing businesses the work of the cheap labor of foreign countries and the untaxed raw material of those countries. There is another consideration I desire to call to your and your committee's attention in regard to this proposed fixed tax of 5 cents per pound on crude rubber. The production of rubber is constantly fluctuating and it is impossible to control it. All that can be obtained can be readily used. Rubber does not follow the general economic laws of production for reasons too numerous to state. The reading of any book on rubber production will give these reasons. The course of market prices influences the production of crude rubber far less than the price of any other staple. The principal reason is largely geographical inasmuch as native rubber is almost in its entirety produced in localities so far distant from the centers of commerce that the course of the market is only known after the production has been accomplished. It is largely dependent, too, upon the native African negro and the native South American Indian, both of whom are not to be depended upon for any regular labor. Para rubber, the purest grade, has fluctuated within the past two years from 95 cents per pound to $2.85 per pound. That of itself tells the story and shows that the fluctuations are beyond the control of any interests in this country or of any other country. The manufacturer is now, because of these fluctuations, already bound to take considerable risks in the purchase of his raw materials. Considering these violent fluctuations in value, the placing of a fixed duty on crude rubber would render it practically beyond the power of the manufacturer to calculate, within any reasonable degree of certainty, the cost of the production of his manufactured article. In this country, through our mechanical ingenuity, we are producing a better grade of goods than are made in countries where there is no tax on the crude rubber, and we are able, because of our superiority in manufacture in many lines, to meet the manufacturers of those countries at the same price and furnish a better quality of article. It is because of this that our export business is constantly growing. If this tax is imposed, the manufacturer will have to cut down the quality of his goods and he can not then meet the

PARAGRAPH 591-RUBBER.

foreign manufacturer on his own ground. Finally, contrast the cost of material to the value of the product, as shown in the figures of the Thirteenth United States Census and you will conclude that there are few industries where the cost of material bears such a high proportion to the value of the manufactured product. The percentage is about 60 per cent. Impose a tax on the raw material and you will impose an additional burden that no other line of manufactured goods is bearing, so far as I know, and bear in mind that in doing so it is for no protective purpose, since crude rubber is not produced in this country. The tax does not return in any way to the inhabitants of this country. It is taken bodily out of the pockets of manufacturers who are already bearing in their line a disproportionate cost of material, who, in their turn, must naturally shift this increased burden on the consumer.

In conclusion, I desire to emphasize these points: (1) That the imposition of this proposed tax would not result in sufficient revenue to meet the deficit created by a reduction in the tariff on wool. (2) That the imposition of this proposed tax would not create more than a revenue of $5,000,000, which again is uncertain because the commercial elimination of pontianak would affect the importation of other grades of rubber. (3) That the ultimate effect of such tax would be to shift the burden from one commodity to another without resulting in any benefit to the public, but on the contrary impose immeasurable hardship on the manufacturer, the employee, and wage earner in this industry. (4) That the imposition of this tax would affect our large and growing export trade, coming in competition with various countries where no tax is imposed. (5) That it being a proposed tax on raw material not in any way produced in this country, it can not be for protective purposes. Respectfully submitted.

FREDERIC C. HOOD, President Rubber Club of America.

TELEGRAMS CONCERNING CRUDE RUBBER.

Hon. FRANCIS BURTON HARRISON,

NEW HAVEN, CONN., February 23, 1912.

House of Representatives, Washington, D. C.: Referring to our conversation of February 14 regarding proposed import tax on crude rubber 100 per cent of my company's business is rubber footwear, which is a necessity. In 1911 40 per cent of output was exported. No European countries pay import duty on crude rubber, except Russia, where I understand tax is rebated to Russian companies as outlined in section 25, tariff act of August 5, 1909; drawback system is expensive to manufacturer and would be particularly complicated; applied to manufacturer of rubber we can not expect to hold our foreign business with a tax on our crude material, and I respectfully urge that raw rubber be left on free list. H. STUART HOTCHKISS.

Hon. JOHN A. THAYER,

BOSTON, MASS., February 23, 1912.

House of Representatives, Washington, D. C.: We are the largest single rubber footwear manufacturers in this country. We do a considerable export business, especially in England. The proposed import duty on our principal raw material, namely, rubber, would be a serious blow to us. It would ruin our export trade and would necessitate raising prices on our product, which is consumed mostly by those people of this country who can least afford to pay the increased price. May we ask you to help against this proposed duty.

Hon. JAMES M. CURLEY,

FREDERIC C. HOOD, Treasurer of Hood Rubber Co.

BOSTON, MASS., February 23, 1912.

House of Representatives, Washington, D. C. The Rubber Club of America learns with dismay that an import duty is proposed on crude rubber. On behalf of the Rubber Club America representing in its membership the entire rubber industry of the country, I beg most respectfully to protest against such proposed duty on our raw material. Rubber goods to-day are an essential for all classes of people, especially the poorer classes, and the proposed duty

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PARAGRAPH 591-RUBBER.

would be a great hardship in the increased cost to the consumer throughout this country and would also ruin our export trade on manufactured goods. The club would like to send its representatives to Washington to be heard on this subject. FREDERIC C. HOOD, President of Rubber Club of America.

SUGGESTIONS REGARDING SCRAP RUBBER.

Hon. OSCAR W. UNDERWOOD,

House of Representatives, Washington, D. C

AKRON, OHIO, February 12, 1913.

DEAR SIR: We have had brought to our attention paragraph 591 of the present law, in which appears the words: "Scrap rubber, fit only for remanufacture and which has been worn out by use, to be admitted free of duty." The words: "Worn out by use," in our opinion should be eliminated, as there is a great deal of scrap rubber, fit only for reclaiming purposes, consisting of trimmings, mold rinds, and that kind of scrap, accruing every day in a rubber factory that are dutiable under the present law. It is just as logical to assume that scrap rubber which has been worn is dutiable as it is that which has not been worn is dutiable.

We use approximately 40,000,000 pounds of scrap rubber per year, a percentage of which is imported. This is used for nothing but for the purpose of making reclaimed rubber, and is distinctly raw material to be used for manufacturing purposes and, in our opinion, all scrap rubber should be admitted absolutely free of duty.

The amount of this material that could be diverted to other uses is so immaterial when compared with the total volume that it is too much the case of the great number of legitimate users being penalized on account of a possible-although not probable-abuse of free entry.

Very truly, yours,

THE PHILADELPHIA RUBBER WORKS Co.,
J. S. LOWMAN, Vice President.

TRENTON, N. J., February 12, 1913.

Hon. OSCAR W. UNDERWOOD,

Washington. D. C.

DEAR SIR: In your paragraph 591 of the present law a provision is made for scrap rubber, whereas all scrap rubber that is worn out by use and fit only for remanufacturing purposes is admitted free of duty.

Such scrap rubber referred to consists mostly of old rubber shoes, rubber hose, etc., which of course is only scrap waste, and is admitted free of duty.

The phrase "which has been worn out by use" excludes from the paragraph such scrap waste as overflow from molds and other new scrap waste which can not be used as a new product and is only fit to be ground up and used for remanufacturing purposes. According to the wording of the law, which has been in effect for more than 25 years, all scrap rubber, whether worn out by use or otherwise, is admitted free of duty. The appraisers are now appraising such material that is not worn out by use as unenumerated waste, and accordingly assess a 10 per cent duty on same.

In view of the fact that new waste rubber and old waste rubber are the same and can only be ground up for remanufacturing purposes, we think that the assessment of 10 per cent duty is unfair, and we would be pleased to have you remove the words "which has been worn out by use" from paragraph 591, and any assistance which you can render us in this respect will be greatly appreciated.

Yours, respectfully,

Hon. E. J. HILL, M. C.,

TRENTON SCRAP RUBBER SUPPLY CO.,
I. FINEBURG, Manager.

UNITED STATES RUBBER Co., Naugatuck, Conn., January 29, 1913.

House of Representatives, Washington, D. C.

MY DEAR MR. HILL: I have this day signed a petition addressed to the Ways and Means Committee of the House of Representatives praying for a change in the wording

PARAGRAPH 591-RUBBER.

of the law in regard to admission of scrap or waste rubber, and it would please me very much if you could see your way clear to advocate the change as represented in this petition, which is signed by a number of the rubber reclaimers of the country as well as by some scrap rubber dealers.

The words to be eliminated, as the petition indicates, are "worn out by use." We recently imported a lot of old rubbers, or at least they were bought as old rubbers, and when they were examined at the custom house to our surprise it was discovered that a large majority of them were rubber shoes which had been burned in a fire abroad, and were fit only for remanufacture. They had never been worn, but they were in such condition that it was absolutely impossible to use them as new shoes, nevertheless, under the strict construction of the law we were assessed a 10 per cent duty on the consignment, the duty amounting to between $300 and $400. I believe this was such a literal construction of the law that it amounted to an absurdity. They were really not as good for our purpose as shoes which had been "worn out by use. They were fit only for remanufacture, but, not having been worn out by use, they were classed as new scrap rubber.

Occasionally in shipments which we have received from abroad, dealers on the other side either intentionally or inadvertently put in scraps of new clippings, and if same is discovered by the inspectors at the port of New York, the material is at once assessed on the basis of 10 per cent duty for the whole consignment. There has been so much of this recently in the exact enforcement of the law according to the letter that it has worked real hardship on dealers as well as manufacturers, and it is for this purpose that we are asking the Ways and Means Committee to change the wording, so that waste rubber which is "fit only for remanufacture" may be admitted duty free, the same as rubber which has been worn out by use.

Anything you can do to bring about the change requested would be heartily appreciated.

Yours, very sincerely,

WM. T. RODENBACH, Manager.

BRIEF OF THE VOORHEES RUBBER MANUFACTURING CO., JERSEY CITY, N. J.

JERSEY CITY, N. J., January 14, 1913.

The CHAIRMAN WAYS AND MEANS COMMITTEE,

House of Representatives, Washington, D. C.

DEAR SIR: There has been so much said in the papers recently concerning the revision of the tariff that we are reminded of the suggestion made some months ago that there be a duty placed on crude rubber in order to make up in a measure for the loss of revenue due to a decreased rate on sugar.

We are manufacturers, but at the same time are believers in a revision of the tariff on a downward scale, but we can hardly understand a plan which contemplates placing duties on raw materials which it is absolutely impossible to produce in this country and which have not heretofore been taxed.

We understand that the plan of taxing crude rubber was one of Senator Aldrich's projects.

The line of business in which we form a part consists in the manufacture of mechanical rubber goods, this term comprehending the manufacture of belting for mill and conveying purposes; hose for water, steam, air, and fire department purposes; pump valves, packings for steam joints, and a great many other articles of similar character which are used by manufacturers, miners, etc. By what stretch of the imagination such a crude line could be included under the head of luxuries we can not comprehend. Besides this, a number of manufacturers have been for years developing an export trade, and in this branch they compete with German, English, and French manufacturers, particularly German. They can meet this competition notwithstanding the cheaper cost of labor in the countries mentioned, but should the duty upon the crude article be imposed, this outlet for American goods would be destroyed. With crude rubber on the free list we have no fear of competition.

If there is any ground for our fear that a duty is to be placed upon crude rubber, will you kindly advise and give us an opportunity to make a suitable protest?

Yours, truly,

VOORHEES RUBBER MFG. CO.,
JNO. J. VOORHEES, President.

PARAGRAPH 593-IODINE.

PARAGRAPH 592.

Indigo.

See American Cotton Manufacturing Association, page 5759; Badische Co., page 5775.

PARAGRAPH 593.

Iodine, crude.

IODINE.

PHILADELPHIA, January 31, 1913.

The Hon. OSCAR UNDERWOOD,

Chairman Committee on Ways and Means,

House of Representatives, Washington, D. C.

DEAR SIR: We earnestly urge retention on the free list of the following items for the reason that if made dutiable the unit of cost must, of necessity, be greater in this country than in other countries, where these materials are not taxed by an import duty.

Paragraph 482, acid benzoic.-This is the raw material of chief value in the manufacture of benzoate of soda.

Paragraph 593, iodine, crude.-This is the principal crude material in the manufacture of iodine resublimed, potassium iodide, iodoform, and other iodides. It is not produced in this country-Chili, Norway, and Japan being the principal countries of production.

Paragraph 610, lemon juice, lime juice, and sour orange juice.-Of these, concentrated lime juice, used in the manufacture of citric acid, is imported from the West Indies. It is not produced in this country.

Paragraph 613, citrate of lime.-This article is produced in, and imported from, Sicily and the West Indies. It is not made in this country.

Paragraph 655, carbonate of potash, crude or refined. This article is not manufactured in this country, but is a product of Germany by reason of Germany's preeminence in potash production. It is the crude material in the manufacture of nearly all salts of potash.

Paragraphs 679, cloves and clove stems.-Principal source of production is the Island of Zanzibar. Cloves are used, not only as a spice, but also enter largely into the manufacture of oil of cloves, which is, in turn, further converted into other products. Respectfully submitted.

POWERS-WEIGHTMAN-ROSENGARTEN CO.,
A. G. ROSENgarten, Treasurer.

PARAGRAPH 594.
Ipecac.

PARAGRAPH 595.

Iridium, osmium, palladium, rhodium, and ruthenium and native combinations thereof with one another or with platinum.

PARAGRAPH 596.

Ivory tusks in their natural state or cut vertically across the grain only, with the bark left intact, and vegetable ivory in its natural state.

PARAGRAPH 597.

Jalap.

PARAGRAPH 598.

Jet, unmanufactured.

PARAGRAPH 599.

Joss stick, or Joss light.

PARAGRAPH 600.

Junk, old.

PARAGRAPH 601.

Kelp.

PARAGRAPH 602.

Kieserite.

PARAGRAPH 603.

Kindling wood.

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