tion of cocoanut oil varies from 10 to 60 per cent, depending upon the

quality of the soap.

For the reasons above set forth we submit a duty of one-fourth of 1 cent per pound of cocoanut oil would be fair and just.

Respectfully submitted.

MCGOWAN, SERVEN & MOHUN.

THE INDIA REFINING COMPANY AND THE NUCOA BUTTER COMPANY PROTEST AGAINST THE PLACING OF A DUTY ON COCOANUT OIL.

Hon. SERENO E. PAYNE,

NEW YORK CITY, December 1, 1908.

Chairman Committee on Ways and Means,

House of Representatives, Washington, D. C.:

We have been advised that on November 10 Mr. Barry Mohun appeared before your committee on the hearing of Schedule A-chemicals, oils, and paints and asked the imposition of a small duty on cocoanut oil. We have read the statement of Mr. Barry Mohun as it appears in the first print of the tariff hearings, and we now beg to be allowed to present to your committee a few facts and figures on this subject as reasons why the cocoanut oil of commerce should remain duty free.

A duty of one-half a cent per pound on foreign-made cocoanut oil has been suggested. The only object of such a duty would be to promote a copra-crushing industry in this country. Presuming this object were accomplished, and copra were crushed successfully and at a profit in this country, the only parties benefited would be the capitalists who had invested their money in the enterprise and the labor employed. As against these two benefits, all the soap makers and all the cocoanut-oil refiners in this country would pay one-half cent per pound more for their cocoanut oil, and, as a consequence, the American public would pay higher prices for soap and refined cocoanut-oil products.

It must be understood that copra, the dried meat of the cocoanut, is valuable only on account of the oil it contains and the poonac, or cocoanut cake, which is produced as a by-product in copra crushing. Copra contains from 50 to 60 per cent of oil, and a little less than 20,000 tons of cocoanut oil are imported annually into this country. For this calculation it may be taken that copra yields half of its weight of oil, and that this country consumes 20,000 tons of cocoanut oil per annum. If, therefore, all the cocoanut oil to be used in this country were produced from copra crushed in this country, 40,000 tons of copra would have to be imported, as against the 20,000 tons of oil at present imported. This would mean that the German and English steamship lines would benefit by the freight on a further 20,000 tons weight.

Furthermore, 20,000 tons of poonac, having been produced in this country, would be shipped back to Europe, which is the only market for it. We have in the last five years imported several small lots of poonac with the hope of developing a market for it, but with no more

success than the English copra crushers, who find their only market for poonac in Germany and France.

Copra crushing in this country, then, would lead to the payment of freight inward on a further 20,000 tons of material and freight outward on a like amount. The freight on cocoanut oil from eastern points-Colombo, East Indies, etc.-to New York is figured at 30 shillings per 14 English hundredweight, which is, roughly, one-half cent per pound. This would represent on 20.000 tons $200,000. Then, again, the shipment of 20.000 tons of poonac back to Europe, figuring that the freight eastward would be no higher than it is westward, would represent, at $4 per ton, another $80,000.

One result, therefore, of supplying soap makers and cocoanut-oil refiners in the United States with cocoanut oil made from copra crushed in the United States would be an advantage to English and German steamship lines of, roughly, $280,000 per annum.

The most up-to-date copra-crushing factory in the world is one recently installed in London. This plant has a capacity of 371⁄2 tons of oil per day. We have full particulars of the cost of the production of the oil in this plant, but in order to be quite up to date we wrote to London after reading Mr. Barry Mohun's statement and asked for a cabled reply as to the actual cost of the labor per ton of cocoanut oil produced. On November 30 we received their cabled reply, which is to the effect that the labor cost is 13 shillings per ton of oil. Thirteen shillings is, roughly, $3.25, so that the advantage to American labor in crushing copra in this country would be $3.25 per ton on 20,000 tons of oil, or $65,000, whereas the consumer would pay, on the basis of one-half cent per pound duty, $200,000. This advantage to American labor would be paid by every user of soap and refined cocoanut-oil products in the country, as also would the freight advantage to English and German steamship lines of $280,000, as calculated above.

As a business proposition it does not seem reasonable to find $65,000 worth of labor for American workmen and at the same time offer $200,000 to $280.000 to foreign steamship lines.

Apart from the above aspect of the proposition it should be borne in mind that the manufacture of refined cocoanut oil and refined cocoanut-oil products was introduced into this country subsequent to the very clear and decided rulings in the cases of all protests in which importers of refined cocoanut oil sought to introduce the article free of duty, it being also taken for granted that cocoanut oil would remain on the free list. Any alteration of the tariff on cocoa-butter substitutes, under which heading are classed refined cocoanut oil and refined cocoanut-oil products, or the imposition of any duty upon crude cocoanut oil would be manifestly unfair to American manufacturers.

Cocoanut oil already costs the American users 11 shillings 3 pence per gross ton, or a little over one-eighth cent per pound more than it costs the European user, on account of higher sea freight. The manufacturers of refined cocoanut oil and refined cocoanut-oil products in the United States, although they have so far been protected by a duty of 3 cents per pound, as it appears in the tariff, have had no opportunities to make even reasonable profits. Competition has sprung up rapidly, and there are now three large manu

facturers in this country, representing an investment of large sums of money, and the competition between them has forced down the selling price of their products to practically the same figure at which the European manufacturers sell their products in Europe, where there is a large demand for them, and, until the American public has been further educated to the use of refined cocoanut-oil products and the demand for them overtakes the supply, there will be little opportunity for American manufacturers to obtain part or all of the benefit of the 3 cents per pound duty or to make reasonable profits on their investments.

It should also be remembered that if a duty is imposed upon crude cocoanut oil it will seriously hurt the copra crushing industry in the Philippine Islands. The American crushers of copra in the Philippine Islands have not yet overcome the technical difficulties, and, there is no doubt that if a duty were assessed upon their product coming into this country it would completely stifle their efforts of the last few years.

It therefore seems to us that there are many and good reasons why crude cocoanut oil should remain upon the free list. We venture to take this opportunity of calling to your attention the fact. that there has been considerable confusion in New York in protest cases before the Board of Appraisers and also before the United States circuit court of Oregon, caused by the brief wording of paragraph 282, tariff act 1897, which fails to clearly specify that refined cocoanut oil and refined cocoanut-oil products take the same duty as cocoa butterine. It has been repeatedly ruled that refined cocoanut oil and refined cocoanut-oil products are cocoa butter substitutes and dutiable at 3 cents per pound.

In conclusion, therefore, we respect fully recommend:

First, that there be no imposition of duty on cocoanut oil.

Second, that paragraph 282, tariff act 1897, be extended and made to read "cocoa butter or cocoa butterine, including refined cocoanut oil, and refined cocoanut-oil products."

THE NUCOA BUTTER COMPANY, By FRANK HEMINGWAY,

Vice-President.

Figures gathered after drawing up the foregoing brief. World's

production of copra in 1906:

These figures show only 28 per cent of the world's copra as coming from the Philippines, and not 50 per cent, as suggested by Mr. Barry Mohun.

Copra is packed for shipment in bales weighing 560 pounds, each known as "candies."

Poonac selling for about 14 cents per pound.

Prices paid for copra in London.

Attached is a list showing the range of prices for copra of different makes from 1906 to 1908.

Cocoa butter dutiable.

We are advised by the counsel of the Treasury Department, appraiser's warehouse, New York, that Judge Martin, of the United States circuit court, in the case of Fuerst Bros. & Co. v. the United States, yesterday affirmed the decision of the Board of General Appraisers.

The merchandise in controversy was assessed for duty by the collector at 3 cents per pound under the provision for "cocoa butterine" in paragraph 282 of the tariff act. This assessment was sustained by the Board of General Appraisers. The importers claimed free entry as cocoanut oil under paragraph 626 of the act.

Cocoanut oil is a raw material, used for manufacturing purposes exclusively, and is not a product of this country, and any tax upon it would be solely a tax for revenue only.

COD LIVER OIL.

COMMITTEE ON WAYS AND MEANS,

NEW YORK, December 1, 1908.

Washington, D. C.

GENTLEMEN: Dingley tariff 1897, Schedule A, chemicals, oils, paints. Paragraph 34, cod liver oil, 15 cents per gallon.

It is hereby recommended that the present duty of 15 cents per gallon on foreign refined cod liver oil ought to be changed to a duty of 10 cents per gallon for the following reason:

That refined cod liver oil to our knowledge is not manufactured in the United States, therefore everyone is obliged to import from abroad this article so necessary for use in innumerable food and medicinal compounds for man and beast. Cod liver oil is obtained from selected liver of the cod fish caught on the coast of Norway and Newfoundland.

Respectfully submitted.

SCOTT & BOWNE.

COMPOUNDS OF PYROXYLIN.

CERTAIN MANUFACTURERS OF CELLULOID AND OTHER COMPOUNDS OF PYROXYLIN RECOMMEND NEW CLASSIFICATION.

NEW YORK CITY, November 30, 1908.

COMMITTEE ON WAYS AND MEANS,

Washington, D. C.

GENTLEMEN: The undersigned, as manufacturers of "compounds of pyroxylin" (known under registered trade names as "celluloid," "fiberloid," "pyralin," etc.), and of articles made therefrom, are directly affected by the provisions of the tariff as set forth in Schedule A, paragraph 17, and desire to lay their case before your committee, that it may be considered in connection with the hearings now being held, permission to file such a statement having been given by letter signed by the clerk of your committee under date of November 11,

last.

Assuming that your committee has contemplated any change in the existing rates of the present paragraph had the question been presented to us at any recent time prior to a month ago, we should have frankly stated that we would not object to a moderate reduction on the two first classes of material embraced in the paragraph, namely, "collodion and all compounds of pyroxylin" and "rolled or in sheets," as since the present tariff went into effect we have by expenditure of large sums of money so improved our processes, helped lately by the removal of the tax from denatured alcohol, that we felt we had a fighting chance to preserve our trade. We would also have been satisfied to have the present duty on the third class embraced in the paragraph, namely, " if in finished or partly finished articles," etc., remain as it is, as in spite of the constantly increasing importation of such articles we felt we could probably hold the business which we are now doing.