We feel that humane considerations are involved in that besides the economic considerations of forcing American labor to compete with child labor abroad. In addition to that, we feel that any change in the marking section of the law is unjustified. As a matter of fact, we believe that the marking law should be strengthened and the opportunities that are now present for evasion ought to be removed. We feel that everything that enters into a commodity which has been imported ought to be so marked whether in its original form or in the manufactured form in which it has entered. We are certainly opposed to any attempt to change that law so that it will not apply to the retail commodity to be sold in the market. As for the trade-mark act, we are also opposed to the trade-mark act as it is at the present time. Under the present law, he who holds an American trade-mark has the option of permitting the importation of goods manufactured under that trade-mark. We believe that no such option should be given to the owner of the trade-mark. If it is of any value at all, since it is granted by reason of governmental authority, we believe that the privilege of granting a trade-mark should be removed and that goods manufactured over an American trade-mark should be manufactured within American territory and by American labor, and not by labor abroad. Taking up the matter of the invoices filed, at the present time invoices are not open to inspection to any one. Since labor is vitally concerned in the matter of the importations, as they so vitally affect our conditions of life and work, we feel that labor as well as the employers should be entitled to the inspection of the invoices governing the fixation of values. We therefore feel that invoices should be open to public inspection so that all may have an opportunity of ascertaining whether the values are correctly ascertained or not. That will, of course, remove a great deal of fraud that is being practiced, of undervaluation, and many of the difficulties that have been experienced up to the present time. In addition to that, we seek to be placed on a par with the importers in the matter of making appeals from appraisals when they are made. As the law is at the present time, and under the rulings of the court, it is held that no one has any financial interest in the subject matter under dispute excepting the importer and the Government itself. Under that provision there is no other authority, no other factor within our industrial life, able to present any matter of interest as to why the appraisal has not been fair or has been fair. To-day it is entirely a matter between the appraisers and the importers. We feel that labor as well as capital should be accorded the opportunity of interceding in all such questions where appeals have been had from appraisers as to valuation, so that the American public interests might be protected and so that it may not be made an importers' court, but a public court, instead of what it is to-day. BRIEF OF THE CHAMBER OF COMMERCE OF THE UNITED STATES OF AMERICA Hon. WILLIS C. HAWLEY, House of Representatives, Washington, D. C. DEAR MR. HAWLEY: Recognizing the fundamental and far-reaching importance of tariffs to American business and industry, the membership of the Chamber of Commerce of the United States has indorsed certain general principles and advances certain general views applicable to tariff legislation. Since this organization consists of over 1,700 chambers of commerce and trade associations, representing all sections and practically all phases of the Nation's industry and business, the views of its members, I trust, will be of interest to you, charged as you are with the responsibility of writing tariff legislation. This organization is not concerned with specific tariff schedules. Its interest is, rather, in principles. These principles have been determined through nation-wide referenda participated in by our members, and through resolutions adopted by accredited delegates representing our members at annual meetings of the national chamber. I invite your consideration of a brief summary of these views and principles: Protection of American industries.-We believe there should be reasonable protection for American industries that are subject to destructive competition from abroad and that are of benefit to the country as a whole or to any considerable section thereof. The term "industries," as here used, embraces not only the manufacturing industries of the Nation, but as well the great productive industries represented by our farms, our mines, and our forests. Very recently our membership, in referendum vote, reemphasized its view that agriculture should be included among the industries receiving such protection. Antidumping legislation. The sale of foreign-made goods in the markets of the United States at a price lower than the price ruling in the countries of origin, in our opinion, is unfair competition. Therefore, we suggest that the principles of the antidumping legislation of 1921 should be maintained. Export and import discriminations.-Effective recognition by Congress of the need for adequate protection should, we believe, be accompanied by recognition of the public interest in maintaining and developing our export trade. To this end our exports should have a friendly reception, free from discriminations of any kind. If discriminations occur, there should be adequate means in the law for meeting them. There should also, we believe, be means for meeting foreign discriminations bearing on essential materials which we import and which we can obtain only from abroad. Flexible rates. We not only advocate adequate protection, as set out herein, but we likewise advocate means for maintaining the effectiveness of the decisions of Congress as to the protection it wishes to afford. Such protection is necessary against changes in conditions abroad, which can not be foreseen. As the means for maintaining the effectiveness of the decisions of Congress, we advocate provisions for adjustment of rates within limits and according to standards set by Congress. We suggest that the great importance of this function makes it appropriate that it should be performed by a board having no other duties and safeguarded in every possible way from the influence of political considerations or private interest. Tariff Commission.-We recognize the fundamental necessity of fact-finding in relation to tariffs. The second referendum of our organization, submitted in 1913, recommended that the activities of the United States Tariff Commission be to gather, investigate, and tabulate technical and statistical facts pertinent to tariff schedules, both in this and other countries. The reports of the commission, our members believe, should be confined to ascertained facts and should exclude recommendations unless called for by the body having power to institute tariff legislation. The information secured by the commission should be available to either House of Congress and to the President. We believe there is need for both a tariff adjustment board, as mentioned above, and the fact-finding activities of the Tariff Commission. Tariff investigations abroad.--We suggest that if our Government is to safeguard the public revenues; if it is to make the provisions of our tariff laws effective, and if it is to protect honest merchants against unfair competition by those who would evade our tariff requirements, some investigations relating to the tariff must be conducted abroad by the United States Government. We believe, however, that our tariff laws should be framed as to assure that all such investigations made abroad should be so conducted in such a manner as to foster good international relations, having in mind particularly the ill will engendered by the provisions of existing law requiring production of books and disclosure of production cost by foreign producers, shippers, and merchants under penalty of exclusion from our markets. Foreign trade zones.—We favor legislation permitting the creation, in American ports, of foreign trade zones into which foreign materials and goods may be transported for manufacture, repacking and other necessary handling, and then shipped to foreign destinations without the expense and delay incident to passage through the customs. The establishment of such zones, by local bodies at their own expense, under approved Federal regulation, would provide part of the equipment needed by a country such as our own doing a diversified international trading business. The establishment of such zones would, we believe, inure to the benefit of American industry, American commerce, and American merchant shipping. As I have said, the views here presented are not personal views, but are the views developed and endorsed by the organization members of the Chamber of Commerce of the United States. As such you will, I am sure, give them the weight to which, in your judgment, they are entitled. Very truly yours, WILLIAM BUTTERWORTH, President. STATEMENT OF WALTER HUMPHREYS, BOSTON, MASS., REPRESENTING NATIONAL ASSOCIATION OF WOOL MANUFACTURERS [Classification and appraisement of wools] Mr. HUMPHREYS. Mr. Chairman, this brief is submitted in accordance with the offer made by the representative of the National Association of Wool Manufacturers, its vice president, Mr. Nathaniel Stevens, on February 7, 1929, when addressing your committee for wool manufacturers during the hearings on the wool schedule. He was asked by a member of your committee his opinion in regard to establishing a more scientific method of appraising wool at ports of entry. He assured the committee of the willingness of the association to present a brief. This brief is presented, I am sorry to say, not by the president. Application was made for time for him, but unfortunately he is in the hospital. I purpose, as secretary of the association, to review the question which was raised by members of your committee and ask the privilege of submitting with the brief other questions concerning administration. We believe that wool manufacturers and wool growers are in general agreement regarding the just, fair, and uniform appraisement of imported wools. Wool growers demand full protection against the importation of foreign-grown wools, and manufacturers, on their part, expect uniform administration of the tariff law to prevent unjust competition among members of their branch of the wool industry. It is obvious that if wool is imported through one customhouse on the basis of one rate of shrinkage and similar wool through another upon the basis of a different rate, or at different rates at the same port of entry, the woolgrower is not uniformly protected and there is an opportunity for increased or diminished profits for the importer and unjust subsequent gain or loss to the wool manufac turer. Claims have been made that importations have been effected upon the basis of incorrect rates of shrinkage, thus permitting the purchase of wool at unjust prices. The present law and current Treasury regulations do not require that scouring tests be made upon samples of all importations, but they do provide that in cases of disagreement between importers of wool and customs officials the shrinkage or the clean content may be determined by actual tests. Wool manufacturers do not believe that it is necessary to have all foreign wools tested in the laboratory when imported. They believe that provisions already exist which, if enlarged, will protect all. Manufacturers have a high opinion of the integrity of customs officials, conforming to that expressed by a member of your committee, on February 7, when referring to the findings of one of your subcommittees in its examination of various customs offices. At these same hearings it was noted that the representative of the woolgrowers recommended that instead of continuing the present permissive regulation concerning tests of samples of imported wool, provision be made in the tariff law to make such tests for clean content mandatory on all importations. It was understood that the purpose of the suggestion was to remove the human element in the appraisal of the clean content of wool. Wool manufacturers are of the opinion that the requiring of Scouring tests to determine the clean content will not remove the human factor. It is not practicable to test the whole of a shipment of wool. Hence samples of a predetermined quantity must be taken. Their selection must be left to the sampler and to his judgment as to whether or not they are truly representative of the entire lot. When it is realized that in fleeces, in bales, and in lots there may be greater variations in the rate of shinkage than are tolerated in estimates of expert wool buyers or exist very generally in appraisals of wool under the current law, the difficulty in choosing appropriate samples is appreciated. During certain periods of the year several shiploads of wool may arrive at a port in the same day. In any one boat the shipments frequently contain many lots. We are advised of a recent one of 900 bales containing more than 300 different lots. It is certainly true that the average importation is not far from 10 to 15 bales. It is not unusual to receive Cape wools, for example, in shipments of 100 bales in one to three-bale lots, all bearing the same mark which the collector uses for record purposes. To fulfill the requirement of laboratory tests to determine the shrinkage of wool, representative samples would have to be taken from the many small lots. Thus it would be practically necessary to crack each bale upon the wharf when taken from the ship. The shrinkage in different parts of any one fleece may vary from 5 to 10 per cent and the samples from these different parts would likewise vary, whereas the variation in the estimates of expert wool buyers is distinctly less. If tests for the shrinkage are compulsory in the case of all importations, much time, particularly in the importing season, would be required for the scouring and carbonizing tests aside from that needed for reports. This would result in retarding the business of importers and wool manufacturers who could not know the actual cost of their wools until the much delayed final customs liquidation. To make up for the wool needed for samples, importers would have to increase their importations by a corresponding amount. Also, the Government would have to pay for the quantities of wool taken for sampling since after being scoured many wools are unsuitable for the purpose for which they were purchased and can not be graded. The Government would become engaged in the wool business, having to sell this considerable quantity of wool to whatever advantage it might. To what an extent this would be, may be suggested by considering how much wool is imported annually. The yearly average of combing and clothing wools imported during the last 10 years was more than 200,000,000 pounds. If five per cent of the importations were taken for sampling, the Government's holdings of wool would have averaged 10,000,000 pounds a year, and even if the sample requirement were restricted to 1 per cent, it then would have had 2,000,000 pounds of wool a year to sell. For years, in fact so long as wool has been manufactured competitively, wools have been bought upon the basis of the estimate of wool buyers. These wool buyers assume great responsibilities and, in order to maintain their well-paid positions, they must, from experience, be able to estimate the shrinkage of wool closely. The requirement that their estimate be well within 2 per cent is not unusual. fact, it averages in the long run as low as 1 per cent and for certain wools it must be less than 1 per cent. In While we join with the woolgrowers in urging means for a just, fair, and uniform administration of the tariff law as it applies to wool, we do not believe compulsory tests of all importations are necessary, practicable, or workable. We believe the tariff law can be justly administered under such regulations as exist, but that the certainty of its fair and uniform enforcement would be promoted by providing for an administrator of the tariff on wool in the new or adjusted law. Such an administrator would travel from one port of entry to another in order to see that regulations governing wool duties are uniformly administered in every customs district. To secure a suitable officer for this purpose we recognize that it will be necessary for the Government to compete with those who need such specially trained men. Consequently, it will require the Government to provide a salary for this position comparable to that paid such specialists by the wool trade and by wool manufacturers. Such a solution of the problem will obviate the need of setting up, at each customhouse, laboratories or plants with the required personnel for scouring and carbonizing to obtain the actual clean content of samples of imported wools. The Government purchase of wool, for which full reimbursement would be impracticable, will, likewise, be unnecessary. The woolgrowers have suggested a paragraph 1101-A designed, as we understand, to embrace 44s grades wool and under. We assume that in the practical administration of this paragraph, in order to make it a practical working paragraph, a reasonable "tolerance " will be provided. The reason for this suggestion is as follows: No fleece is wholly of any one number. On a truly representative 44s, for example, there will be a certain percentage that will be coarser than the 44s, and a certain percentage on the shoulders, for example, |