or other methods of putting up. Operations such as doubling or processing are not here considered and these are separately discussed later in relation to the desirability of differential or additional duties on yarns advanced beyond the basic classification.

Counts above 120s.-It should be noted that the production in this country of yarns above 120s is very small and that imports of such counts, especially if processed by "preparing" or otherwise, are practically noncompetitive. In at least four countries, viz., Canada, Austria, Switzerland, and Belgium, the tariff provides for the free admission of yarns beyond a certain fineness which marks the limit of any real competition from domestic mills. The object in view in such countries in waiving the small revenue to be derived from duties on such fine noncompetitive yarns is of course to stimulate the lace or other domestic industry which uses such fine yarns and the advisability of such a provision in the American tariff is a matter for the consideration of Congress. If such a provision were adopted with such an object it would logically apply to counts beyond 120s. The demand is not large enough to cause much extension of the domestic manufacture of counts beyond that point, though on the fine range from 60s to 120s the American industry is developing steadily in the South as well as in the North.

Conclusion.The foregoing study, though it attempts to indicate only approximately the height of tariff duties based on the difference in costs of production, yet seems to indicate clearly that, if duties are to be levied for other than revenue purposes and are to be adapted in general to competitive conditions, there should be one rate of progression of duties, whether by individual counts or by groups of yarn counts, on the range up to and including 40s; another and somewhat steeper rate of progression of duties on counts from 41s to 100s or 120s; and that above 120s the duties should be stationary or discontinued.

DISCUSSION OF DIFFERENTIALS.

DIFFERENTIAL FOR COMBING.

The differential on combed, as compared with carded, yarn first appeared in the tariff act of 1894; it has been continued in the tariff acts of 1897, 1909, and 1913.

The United States is unique in levying this differential, for it has apparently never appeared in any foreign tariff law. Cotton yarn may be carded, may be double carded, may be combed, may be double combed, and whether a yarn has been subjected to two processes of careful carding or has been subjected to one process of ordinary combing after one process of carding is a matter that can not be

proved by any physical test. In regard to this a leading British authority on fine spinning writes:

I have consulted the spinning experts of my company on the subject of the best means of distinguishing between carded and combed yarns, and they agree with the opinion I gave you, that no mechanical test is possible and that the only method by which a decision can be arrived at is the appearance of the yarn; the combed being more even and regular in count, freer from neps and dirt, and having usually a much brighter and more polished appearance than yarn that has been carded only, and although in some cases a well-carded and a poor-combed yarn may come near together in these respects, still in the great majority of cases, with samples to guide you, I do not think you will have great difficulty in checking your imports.

The matter is also greatly simplified, at any rate in all but one of the trades with which I am acquainted, because when they are analyzed there are many counts where a combed yarn is never used and there are other counts where a combed yarn is always used, leaving only a few counts you will find it necessary to watch closely. Whether a yarn has been combed or carded is likewise not ascertainable from the price. For instance, the following quotations on 58/2 yarn are taken from a British list sent an American importer, (in May, 1917) and are typical:

This shows that difference in material or in twist or in method of putting up often offsets the factor of combing so that a carded yarn may sell at a higher price than a combed yarn, even though intended. to be used for the same work. For instance, the 58/2 carded Egyptian lisle yarn above was offered at 443d. a pound as against only 421d. for a 58/2 combed Peeler lisle yarn, made by the same company; also the 58/2 curtain yarn, carded only, was bringing slightly more than the 58/2 lisle yarn, combed, although both were made of Egyptian cotton. The addition of the process of combing in the manufacture of any particular yarn necessarily increases the total cost, more by reason of the waste made than by reason of the labor and overhead of the machine processes necessary. The addition of an extra process of carding, instead of the combing process, will make the cost of the double-carded yarn intermediate between ordinary carded and ordinary combed yarns.

The cost of combing does not necessarily vary according to the count, because it depends primarily on the percentage of waste made, and the machine can be adjusted to remove a smaller or larger amount as desired. Sometimes the very lowest count yarns, if intended for hand-embroidery or hand-knitting work of high quality, may

involve a higher combing cost than fine counts used for ordinary weaving or electrical winding. It would therefore appear that under a specific tariff any differential for combing should be at a fixed amount per pound, irrespective of the count. Under an ad valorem tariff, any difference in cost of manufacture between carded and combed yarn would be automatically taken care of by the regular ad valorem rate and an additional percentage for combed over carded yarn is in the nature of a double differential.

If the differentials are not made cumulative a differential on combing when there is also a differential on bleaching, dyeing, or coloring affects only gray yarns and if ply yarn is also provided with a differential then that on combing would affect only single gray yarns and the proportion of these imported is usually small.

Asked as to any difficulty of administration of the differential on combed yarns the customs, authorities at New York, the entry port for the majority of cotton yarns, reported:

It is not possible to distinguish between carded and combed yarns só definitely that the technical experts of this office would be willing to testify to their conclusions under oath. Where the correctness of the invoice statement of carded or combed is questioned by the experts of this office, an investigation is conducted abroad by Treasury Department officers to establish the method of manufacture of the particular yarn in question. This provision of law is very unsatisfactory, and at the tariff hearings preceding the passage of the present act the appraiser directed attention to the probability of unsatisfactory administration, and suggested the elimination of the duty-dividing line between carded and combed.

DIFFERENTIAL ON PLY YARNS.

Two or more yarns twisted together are known as twisted yarns or ply yarns. In England they are more often referred to as doubled yarns or folded yarns.

The manufacture of ply yarns involves two machine processes more than the manufacture of single yarns. In the case of coarse and medium counts these are spooling and then twisting; in the case of finer yarns they are doubling-winding and then twisting. Doublingwinding or folding, as it is sometimes called, consists of winding two ends together on a tube or cone instead of winding each end separately on to a spool as in the case of spooling; it costs slightly more but avoids the danger of "singles" (ply yarns containing one or more strands less than the required number) being made on the twister. When ply yarns are twisted together they are referred to as hawsertwisted or cable-twisted, but still fall under the more general heading of twisted or ply yarns. Ply yarns made by one twisting are often spoken of by the English as "one throw" to distinguish them from the "double throw" or cabled yarns.

1 The word "throw," as here used, is derived from the Saxon "thrawan," to twist. A similar use is to be seen in the "thrown silk" of the silk industry.

The cost of producing ply yarns from single yarn is, in the case of fine yarns at least, greater than that of spinning the yarn from the roving, that is, the labor and overhead and waste involved in the two machine processes of doubling-winding and twisting is greater than that involved in the one machine process of mule spinning. The bulk of the cotton yarns imported are ply yarns and are sold by the doubler instead of by the spinner, these firms in England being usually separate and distinct.

As the manufacture of ply yarns involves two machine processes additional to the manufacture of single yarns, if cost differences are the adopted test it would seem that ply or twisted yarns should be made dutiable at a higher rate than single yarns. A differential duty is therefore logical on ply yarns or "yarns advanced beyond the condition of singles by twisting two or more yarns together." The first term "ply yarns" is inclusive of all yarns twisted together, whether the yarns so twisted together be singles or ply yarns and therefore includes cabled yarn. If the longer definition of "yarns advanced beyond the condition of singles by twisting two or more yarns together" be adopted, it is suggested that "grouping" be not added to "twisting" as in former tariffs. (Vide remarks on "Grouped Yarns" infra.)

The production from a spooler (or doubling-winder if that be substituted), and from a twister (whether ring twister, mule twiner, or flyer twister), in pounds per day, varies according to the speed and the fineness of the count. With an increasing number of ends twisted together the weight per yard and the production in pounds per spindle is increased so that 3-ply costs less per pound than 2-ply and 4-ply costs less than 3-ply. This applies only where the single yarn is the same and the method of twisting the same. If the 3-ply happens to be made by winding three ends together and then twisting, the cost will be higher than where the spun yarn is spooled separately and two ends then twisted together on the twister.

If the duties on the single yarns are levied at a progressive rate, based on the yarn count, then the differential duties on the twisted yarns should also be progressive at a slightly higher ratio of increase.

DIFFERENTIAL ON GROUPED YARNS.

If two or more ends are wound or spooled together so that they lie parallel the product is sometimes referred to as "grouped" yarns. In the case of fine yarns for twisting it is considered preferable to thus group together the ends to be twisted, using a doubling winder, rather than to spool each separately and then twist together the ends from the spools, as in the former case there is less danger of breakage on the twisting machine. Yarns are also grouped together

for other purposes, but apparently the only grouped yarns imported, as shown by a detailed study of the invoices of 1914 and 1918, are those to be used for covering electrical wires. Electrical yarns are imported on cones having from 6 to 30 ends wound on side by side. This grouped yarn is then used as a unit in the braiding machine when covering the wires.

There is no apparent object in imposing a differential on grouped yarns. When single yarns are grouped together they still remain single yarns, and if desired can be easily separated and rewound as single yarns. In fact, although group winding is used as preliminary to other manufacture, it is not a manufacturing process, such as spinning or twisting, which can not be reversed; it is in the same category as reeling or ordinary winding of single ends, more in the nature of a putting-up process than actual manufacture. There is no differential on yarn wound singly on cones or tubes, and this being so a differential duty is not to be expected on two or more ends. wound together on cones or tubes or otherwise, particularly as the cost per pound of multiple winding is not more but usually less than the cost of single-thread winding.

Grouping is not referred to in the tariff act of 1913, but is mentioned here to clarify the situation in case it is suggested for inclusion in future as in two past tariffs.

DIFFERENTIAL ON CABLED YARN.

Cabled yarns are further advanced in manufacture than ordinary "one-throw" or single-twisted ply yarns by reason of the fact that they are made by twisting together twisted yarns. In some tariffs a special differential has been levied on cabled yarns as distinguished from ordinary ply yarns. Such an additional duty might be looked for in the case of cotton sewing thread such as the 4-cord or 6-cord, if it was desired to put these on an even basis with cotton yarn, but since sewing thread is treated separately from yarn there is not much object in having a special tax on cabled yarns as distinguished from other ply yarns. The only yarns that might come in under this heading would be harness twine and fishing-net twine. The latter is ordinarily too coarse to secure admittance even under a very low tariff, and examination in detail of the invoices of 1914 and 1918 shows that the only imports of cabled yarn consist of harness twine for making loom harness. This import does not amount to a tenth of the domestic production of cotton harness twine and is mainly of special counts or qualities needed by the silk mills, the main counts imported being 130/9 and 140/9. These fine-count harness twines are not produced in this country, and efforts have been made by silk interests to have them put on the free list. If not specially men

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