Men's Sewed Straw Hats
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UNITED STATES TARIFF COMMISSION
WASHINGTON
MEN'S SEWED STRAW HATS
REPORT
OF THE
UNITED STATES TARIFF COMMISSION
TO THE
PRESIDENT OF THE UNITED STATES
INVESTIGATION OF THE COSTS OF PRODUCTION OF
MEN'S SEWED STRAW HATS IN THE UNITED
STATES AND IN THE PRINCIPAL
COMPETING FOREIGN
COUNTRIES
WITH APPENDIX
PROCLAMATION BY THE PRESIDENT
WASHINGTON
GOVERNMENT PRINTING OFFICE
1926
UNITED STATES TARIFF COMMISSION
Office: Eighth and E Streets NW., Washington, D. C.
COMMISSIONERS
THOMAS O. MARVIN, _Chairman_.
ALFRED P. DENNIS, _Vice Chairman_.
EDWARD P. COSTIGAN.
HENRY H. GLASSIE.
A. H. BALDWIN.
EDGAR B. BROSSARD.
JOHN F. BETHUNE, _Secretary_.
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CONTENTS
Page
Introductory:
Reference to files 1
Rates of duty 1
History of investigation 1
Scope of investigation 2
Information obtained in the investigation:
Domestic production 2
Kinds of hats produced 3
Organization 3
Labor conditions 3
Imports 4
Effect of imports 6
Principal competing country 7
Foreign production--
Types of hats produced 8
Organization 8
Working hours and wages 8
Costs of production--
Methods of obtaining cost data 9
Description of cost items--
Material 9
Labor 9
Overhead 9
Selling expense--
(_a_) Domestic 9
(_b_) Foreign 9
Tables showing cost comparisons 10
Competitive conditions--
Transportation and marketing costs 11
Formal statement of conclusions 11
Summary of conclusions 13
Separate statement of Commissioner Costigan, in part concurring
and in part dissenting, in the investigation of men's sewed
straw hats:
Both higher and lower duties indicated by the commission's
cost figures 15
Determining the dividing line for tariff purposes between
higher and lower priced hats 15
Some omissions from and doubtful features in the
commission's report 16
Representativeness of samples 16
Importers' selling expenses omitted 17
Deficiencies in comparative overhead data 18
Appendix:
Proclamation by the President 21
LETTER OF TRANSMITTAL
JULY 17, 1925.
The PRESIDENT,
_The White House_,
_Washington, D. C._
MY DEAR MR. PRESIDENT: Herewith I have the honor to transmit the report
of the Tariff Commission in the investigation, for the purposes of
section 315 of the tariff act of 1922, of the costs of production in the
United States and in the principal competing foreign country of men's
sewed straw hats. Included in the report is a "Separate statement of
Commissioner Costigan, in part concurring and in part dissenting, in the
investigation of men's sewed straw hats."
Respectfully,
THOMAS O. MARVIN,
_Chairman_.
UNITED STATES TARIFF COMMISSION
WASHINGTON
MEN'S SEWED STRAW HATS
JULY 17, 1925.
_To the President_:
The United States Tariff Commission respectfully submits the following
report upon an investigation of the differences in costs of production
of men's sewed straw hats in the United States and in competing foreign
countries, for the purposes of section 315 of Title III of the tariff
act of 1922.
INTRODUCTORY
_Reference to files._--The basic documents in connection with the
investigation on men's sewed straw hats are in the files of the Tariff
Commission and are available to the President. They include the
transcripts of the public hearings and the original cost schedules and
other data. These include confidential data, the disclosure of which is
forbidden by section 708 of the revenue act of 1916:
SEC. 708. It shall be unlawful for any member of the United
States Tariff Commission, or for any employee, agent, or clerk of
said commission, or any other officer or employee of the United
States, to divulge, or to make known in any manner whatever not
provided for by law, to any person, the trade secrets or processes
of any person, firm, copartnership, corporation, or association
embraced in any examination or investigation conducted by said
commission, or by order of said commission, or by order of any
member thereof. * * *
_Rates of duty:_
Act of 1922--Not blocked or trimmed } 60 per cent. } Par. 1406.
Blocked or trimmed } }
Act of 1913--Not blocked or trimmed } 25 per cent. } Par. 335.
Blocked or trimmed } 40 per cent. }
Act of 1909--Not trimmed } 35 per cent. } Par. 422.
Trimmed } 50 per cent. }
_History of the investigation._--On May 29, 1924, the commission ordered
an investigation of men's sewed straw hats for the purposes of section
315 of Title III of the tariff act of 1922, and on the same date ordered
a preliminary hearing for June 12, 1924.
An application was received from the National Association of Men's Straw
Hat Manufacturers of America requesting an investigation looking toward
an increase in the rate of duty on men's sewed straw hats, now dutiable
at 60 per cent ad valorem under paragraph 1406 of the tariff act of 1922.
The domestic field work was carried on during the period August to
October, 1924, and the foreign work in Italy and England during the
period October, 1924, to February, 1925. After due notice, as prescribed
by law, public hearings were held in the offices of the commission on
June 12, 1924, and on May 4, 1925. The latter hearing was continued on
May 14, 15, and 16, 1925. Oral argument was waived and the date for
filing briefs was set for June 6, 1925.
_Scope of the investigation._--Costs of production were obtained for
hats sold in the straw hat season of 1924 by companies whose fiscal
years ended at or about June 30, 1924. This period was the latest for
which cost data could be obtained at the time the investigation was
made.
Domestic costs were obtained from 19 concerns in Maryland, New York,
Connecticut, and Massachusetts. The total production of these concerns
amounted to 718,265 dozen hats. Of this number, 553,253 dozen were men's
sewed straw hats. The 19 concerns produce approximately 85 per cent of
the men's sewed straw hats in the United States and include makers of
cheap, medium, and high-priced hats. They include nonmembers as well as
members of the national association.
Costs were obtained in Italy from five concerns and in England from
three concerns exporting men's sewed straw hats to the United States.
Both domestic and foreign straw hat factories are characterized by lack
of standardization in production. Variations exist in the quality of
the hats manufactured by different establishments, because of variations
in the type and quality of the braid, in the quality of the trimming
materials, such as leather sweat and silk bands, and in the amount
of hand labor employed in the finishing processes. Because of these
variations, it was considered inadvisable to compare the average costs
of production of all hats of the domestic concerns with the average of
all foreign hats. Evidence submitted at the preliminary hearing and data
in the possession of the commission indicated that competition between
domestic and foreign straw hats centered chiefly on three types, split
sennits of 13/15 millimeter braid, improved sennits of 16/18 millimeter
braid, and flatfoot sennits of 16/18 millimeter braid. The commission's
cost comparisons were therefore confined to hats of these
specifications.
INFORMATION OBTAINED IN THE INVESTIGATION
From the commission's investigation of men's sewed straw hats, conducted
as indicated above, the following information has been obtained:
DOMESTIC PRODUCTION
The manufacture of men's straw hats has been conducted on a commercial
scale in the United States for upward of 50 years. The industry is
centered in and around New York City, in a number of cities in
Massachusetts and Connecticut, and in Baltimore, Md. Statistics of
production of men's sewed straw hats are not available, since the census
of manufactures does not distinguish between men's and women's hats nor
between sewed hats and woven hats. Domestic manufacturers estimate that
the value of the men's straw hats produced in 1914 was $12,000,000, or
about 45 per cent of the total production of all straw hats. In 1920
the value of the total production of men's straw hats was estimated at
$20,000,000, of which about $12,000,000 was men's sewed hats. At the
preliminary hearing it was estimated that the average annual production
of men's sewed straw hats in recent years amounted to 800,000 dozen.
There are about 40 manufacturers of men's sewed straw hats in the United
States. The majority are well established firms.
The production of men's sewed straw hats for the season 1923-24 of 19
factories for which costs were obtained was 553,253 dozen. The factories
may be classified as follows:
TABLE 1.--_Domestic straw-hat factories grouped according to annual
production_
------------------------------------+--------+------------+----------
| Number | Production | Per cent
| | | of total
------------------------------------+--------+------------+----------
| | _Dozen_ |
Group I. Factories with annual | | |
production of | | |
50,000 dozen and over | 4 | 265,767 | 48.0
Group II. Factories with annual | | |
production of | | |
25,000-49,000 dozen | 4 | 122,936 | 22.2
Group III. Factories with annual | | |
production of less | | |
than 25,000 dozen | 11 | 164,550 | 29.8
+--------+------------+----------
Total production | | 553,253 | 100.0
------------------------------------+--------+------------+----------
_Kinds of hats produced._--There are two general types of men's straw
hats produced by the domestic manufacturers:
(1) Woven hats, such as panamas, etc. The bodies of these hats are
imported in the rough and are shaped, finished, and trimmed in this
country.
(2) Sewed hats. All of the operations necessary in the manufacture
of a sewed straw hat, with the exception of plaiting the braids, are
performed in the United States. This investigation relates to sewed
hats only.
_Organization of production._--The manufacture of straw hats is
essentially a factory business and with few exceptions each concern
carries on all of the major operations connected with the production of
hats in a single establishment. Plaiting of straw braid is a separate
industry, the domestic hat manufacturers being dependent upon foreign
sources for their supply of braids. The bleaching of straw braids is
performed by some of the hat manufacturers in their own establishments;
others have the bleaching done by outside concerns which specialize in
this class of work. Some firms make the tips (the inside linings of the
hats) in their own establishments; others buy the complete tip, or have
certain operations, such as printing or stamping, performed by outside
shops.
_Labor conditions._--The hours of labor of employees in domestic straw
hat factories in 1923-24 varied from 42 to 54 weekly. Wages are based
both on piece and time work. Time wages ranged from $15 to $40 per week,
according to the character of the work performed.
The production of straw hats is to some extent seasonal. Orders are
received in the late summer for delivery in the following spring.
Production on these orders begins in September and the factories are
usually busiest in the early months of the year. The summer is a
slack season and factories operate with reduced labor force or close
altogether for several weeks. The following table shows the monthly
variations in the total number of employees of 18 domestic factories
in the season 1923-24:
TABLE 2.--_Employees in 18 domestic straw-hat factories, season of
1923-24_
---------------+-----------++----------------+-----------
| Number of || | Number of
Month | employees || Month | employees
---------------+-----------++----------------+-----------
1923 | || 1924 |
July | 1,116 || January | 3,331
August | 1,775 || February | 3,371
September | 2,542 || March | 3,403
October | 2,765 || April | 3,380
November | 3,221 || May | 3,117
December | 3,291 || June | 1,871
---------------+-----------++----------------+-----------
IMPORTS
The quantities and values of sewed straw hats imported into the United
States were not separately shown in official statistics prior to the
tariff act of 1922, in which sewed straw hats were given a separate
classification.
Table 3 shows the imports for consumption of sewed straw hats from the
principal countries of origin, by months, for the calendar years 1923
and 1924. Total imports increased from 93,309 dozen in 1923, valued at
$779,989, to 164,041 dozen in 1924, valued at $1,179,929, a gain of
approximately 75 per cent in quantity and 50 per cent in value.
TABLE 3.--_Imports for consumption of men's sewed straw hats[1] from
Italy, England, Germany, and other countries, by months, calendar years
1923 and 1924_
(Source: Foreign Commerce and Navigation of the United States)
-------------+----------+----------+----------+----------+------------
| Italy | England | Germany | Other | Total
| | | | countries|
| | | | [2] |
+----------+----------+----------+----------+------------
Month | 1923 | 1923 | 1923 | 1923 | 1923
-------------+----------+----------+----------+----------+------------
| _Number_ | _Number_ | _Number_ | _Number_ | _Number_
January | 51,225 | 9,734 | 2,460 | 26,606 | 90,025
February | 53,644 | 9,235 | 8 | 4,756 | 67,643
March | 54,102 | 55,920 | 7,420 | 51,305 | 168,747
April | 66,552 | 46,222 | 1,931 | 84,684 | 199,389
May | 78,602 | 68,989 | 80 | 31,888 | 179,559
June | 38,658 | 42,776 | 1,960 | 4,414 | 87,808
July | 23,049 | 6,717 | 848 | 11,685 | 42,299
August | 1,796 | 1,250 | 1,504 | 1,041 | 5,591
September | 120 | 960 | 1,272 | 102 | 2,474
October | 53,129 | 396 | 3,411 | 331 | 57,267
November | 77,962 | 2,718 | 8,929 | 7,524 | 97,133
December | 78,372 | 1,647 | 21,334 | 20,415 | 121,768
+----------+----------+----------+----------+------------
Total number | 577,211 | 246,584 | 51,157 | 244,751 | 1,119,703
Dozen | 48,101 | 20,549 | 4,263 | 20,396 | 93,309
+==========+==========+==========+==========+============
| | | | |
Total Value | $289,215 | $256,769 | $32,503 | $201,502 | $779,989
| | | | |
Average | | | | |
value per | | | | |
dozen | $6.01 | $12.50 | $7.62 | $9.88 | $8.36
+==========+==========+==========+==========+============
Per cent | | | | |
of hats | | | | |
imported | | | | |
from each | | | | |
country | 51.50 | 22.00 | 4.60 | 21.90 | 100.0
-------------+----------+----------+----------+----------+------------
-------------+----------+----------+----------+----------+------------
| Italy | England | Germany | Other | Total
| | | | countries|
| | | | [2] |
+----------+----------+----------+----------+------------
Month | 1924 | 1924 | 1924 | 1924 | 1924
-------------+----------+----------+----------+----------+------------
| _Number_ | _Number_ | _Number_ | _Number_ | _Number_
January | 35,754 | 50,087 | 19,829 | 34,754 | 140,424
February | 114,644 | 35,024 | 25,372 | 57,429 | 232,469
March | 97,899 | 46,435 | 50,126 | 40,669 | 235,129
April | 192,007 | 119,031 | 85,421 | 49,935 | 446,394
May | 113,593 | 54,874 | 85,884 | 34,047 | 288,398
June | 59,840 | 37,208 | 6,873 | 14,769 | 118,690
July | 22,505 | 1,533 | 720 | 41,367 | 66,125
August | 4,000 | 820 | 2,795 | 41,689 | 49,304
September | 427 | 706 | 7,377 | 10,550 | 19,060
October | 37,809 | 318 | 4,541 | 34,528 | 77,196
November | 82,313 | 2,640 | 959 | 44,471 | 130,383
December | 100,353 | 4,723 | 5,332 | 54,516 | 164,924
+----------+----------+----------+----------+------------
Total number | 861,144 | 353,399 | 295,229 | 458,724 | 1,968,496
Dozen | 71,762 | 29,450 | 24,602 | 38,227 | 164,041
+----------+----------+----------+----------+------------
| | | | |
Total Value | $427,706 | $282,402 | $180,054 | $289,767 | $1,179,929
| | | | |
Average | | | | |
value per | | | | |
dozen | $5.96 | $9.59 | $7.32 | $7.57 | $7.19
+==========+==========+==========+==========+============
Per cent | | | | |
of hats | | | | |
imported | | | | |
from each | | | | |
country | 43.75 | 17.95 | 15.00 | 23.30 | 100.00
-------------+----------+----------+----------+----------+------------
[1: Including men's, women's, and children's.]
[2: Including withdrawals from warehouse.]
A comparison of the imports for the first four months of 1925 with those
for the corresponding period in 1924 is shown in Table 4. A significant
feature of this table is the increase in imports from Italy and the
decrease of imports from both the United Kingdom and Germany. It should
be noted also that the average foreign[a] value per dozen of Italian
hats decreased while the average foreign[a] value of hats imported from
England and other countries increased.
[Footnote a: Values upon which duties were assessed as computed from
data given in Foreign Commerce and Navigation of the United States.]
TABLE 4.--_Imports for consumption of men's sewed straw hats[1] from
Italy, United Kingdom, Germany, and other countries, by months,
January-April, inclusive, 1924 and 1925._
(Source: Foreign Commerce and Navigation of the United States)
------------+----------+----------+----------+-----------+-----------
| Italy | United | Germany | Other | Total
| | Kingdom | | countries |
| | | | [2] |
+----------+----------+----------+-----------+-----------
Month | 1924 | 1924 | 1924 | 1924 | 1924
------------+----------+----------+----------+-----------+-----------
| _Number_ | _Number_ | _Number_ | _Number_ | _Number_
January | 35,754 | 50,087 | 19,829 | 34,754 | 140,424
February | 114,644 | 35,024 | 25,372 | 57,429 | 232,469
March | 97,899 | 46,435 | 50,126 | 40,669 | 235,129
April | 192,007 | 119,031 | 85,421 | 49,935 | 446,394
+----------+----------+----------+-----------+-----------
Total number| 440,304 | 250,577 | 180,748 | 182,787 | 1,054,416
Dozen | 36,692 | 20,882 | 15,062 | 15,232 | 87,868
+==========+==========+==========+===========+===========
| | | | |
Total value | $228,452 | $201,291 | $102,366 | $123,775 | $655,884
| | | | |
Average | | | | |
value | | | | |
per dozen | 6.23 | 9.64 | 6.80 | 8.13 | 7.46
+==========+==========+==========+===========+===========
Per cent | | | | |
of hats | | | | |
imported | | | | |
from each | | | | |
country | 41.76 | 23.76 | 17.14 | 17.34 | 100.00
------------+----------+----------+----------+-----------+-----------
------------+----------+----------+----------+-----------+-----------
| Italy | United | Germany | Other | Total
| | Kingdom | | countries |
| | | | [2] |
+----------+----------+----------+-----------+-----------
Month | 1925 | 1925 | 1925 | 1925 | 1925
------------+----------+----------+----------+-----------+-----------
| _Number_ | _Number_ | _Number_ | _Number_ | _Number_
January | 212,292 | 8,995 | 12,070 | 6,104 | 239,461
February | 189,736 | 31,776 | 7,697 | 22,580 | 251,789
March | 207,218 | 61,755 | 3,828 | 24,482 | 297,283
April | 260,145 | 45,711 | 40,479 | 10,545 | 356,880
+----------+----------+----------+-----------+-----------
Total number| 869,391 | 148,237 | 64,074 | 63,711 | 1,145,413
Dozen | 72,449 | 12,353 | 5,340 | 5,309 | 95,451
+==========+==========+==========+===========+===========
| | | | |
Total value | $395,298 | $161,422 | $40,923 | $78,222 | $675,865
| | | | |
Average | | | | |
value | | | | |
per dozen | 5.46 | 13.07 | 7.66 | 14.73 | 7.08
+==========+==========+==========+===========+===========
Per cent | | | | |
of hats | | | | |
imported | | | | |
from each | | | | |
country | 75.90 | 12.94 | 5.60 | 5.56 | 100.00
------------+----------+----------+----------+-----------+-----------
[1: Including men's, women's, and children's.]
[2: Including withdrawals from warehouse.]