Men's Sewed Straw Hats: Report of the United Stated Tariff Commission to the President of the United States (1926)United States Tariff Commission
General
Men's Sewed Straw Hats: Report of the United Stated Tariff Commission to the President of the United States (1926)
United States Tariff Commission
Hats; Straw industries
_Importers' selling expenses omitted._--Through inadvertence, but
none the less unfortunately, the selling expenses of importers were
not obtained by the commission. There was considerable testimony at
the commission's public hearing to the effect that a relatively heavy
burden rests on such importers in selling such straw hats in the United
States. (See Transcript of Public Hearing, pp. 110-116.) The American
manufacturers' costs of marketing their hats to the jobbers were secured
by the commission's representatives, but the selling expenses of
importers of foreign hats (without which Italian hats could not reach
American jobbers) were not secured: thus, the complete picture of the
competitive cost situation is not presented in the commission's report.
The significance of this omission is considerable. Under the provisions
of subdivision (c) of section 315 the statutory mandate to consider much
"advantages and disadvantages in competition" is unavoidable, and, while
it is probably not reasonable to reject the commission's findings as a
whole because of this record defect, some allowance would be reasonable
falling short of the extreme conclusions to which the data would
otherwise point.
In answer to the argument that the domestic industry has so well
withstood the competition offered by what seem to be extremely low-cost
Italian hats, it has been urged that the Italian producers are far
from their market and that jobbers prefer a source of supply more
conveniently at hand. This statement involves the admission of a
competitive disadvantage suffered by the foreign producer, which is
clearly not capable of being measured. However, the one statistically
measurable marketing disadvantage of the foreign producer, referred to,
was unfortunately neglected when the commission's data were assembled.
As has been suggested, costs secured, though not used, for the American
producer included his expense of placing his hats in condition ready for
delivery to the jobber, but only those Italian costs were obtained which
with transportation added bring the product to the docks at New York.
Importers must incur the expense of handling and reselling before the
product is ready for the jobbers. In so far as such importers perform
the jobbers' functions, the objections stated may not be valid, but any
importers' costs of reselling to jobbers should undoubtedly have been
collected and considered.
It may further be noted that some American manufacturers actually sell
their hats to retailers. Such domestic selling expenses were secured by
the commission on its schedules, and there is reason to believe that
certain overhead items in the assembled costs are probably larger than
they would otherwise be because of the imperfect allocation of selling
and manufacturing expenses.
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