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Industries Assistance Commission - Reports - Miscellaneous manufacturing - Group G: Writing and marking equipment, 15 December 1981


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The Parliament of the Commonwealth of Australia

MISCELLANEOUS MANUFACTURING

Group G: Writing and Marking Equipment

Industries Assistance Commission Report

15 December 1981

Presented by Command 21 April 1982 Ordered to be printed 5 May 1982

Parliamentary Paper No. 106/1982

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INDUSTRIES A SSISTA N CE COM M ISSION REPORT

M I S C E L L A N E O U S M A N U F A C T U R I N G Group G: W r i t i n g a n d M a r k i n g

E q u i p m e n t

15 DECEMBER 1981 No. 291

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INDUSTRIES ASSISTANCE COMMISSION REPORT

MISCELLANEOUS MANUFACTURING GROUP G : WRITING AND MARKING EQUIPMENT

15 DECEMBER 1981

AUSTRALIAN GOVERNMENT PUBLISHING SERVICE

CANBERRA 1981

© Commonwealth of Australia 1981

Printed by C.J. THOMPSON, Commonwealth Government Printer, Canberra

INDUSTRIES ASSISTANCE COMMISSION REPORT

MISCELLANEOUS MANUFACTURING - GROUP B

THE HONOURABLE THE MINISTER FOR BUSINESS AND CONSUMER AFFAIRS

I forward the Commission's report on "Miscellaneous Manufacturing Group G" made in accordance with the reference of 8 June 1979 under Section 23 of the Industries Assistance Commission Act 1973.

K.B. Mourant Secretary

17 December 1981

For the purposes of the inquiry and report on these matters, in accordance with Section 19 of the Industries Assistance Commission Act 1973, the powers of the Commission have been exercised by:

R.G. MAULDON Commissioner

J.W. CAHILL Associate Commissioner

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CONTENTS

Page

1 . SUMMARY 1

2. INTRODUCTION 3

3. INDUSTRY AND MARKET INFORMATION 4

4. WRITING EQUIPMENT 11

5. MARKING EQUIPMENT 28

6. REPORTING REQUIREMENTS 37

7. RECOMMENDATIONS 39

APPENDIXES

A. TERMS OF REFERENCE 40

B. TARIFF PROVISIONS 42

C. WITNESSES, REQUESTS AND SUGGESTIONS, ABBREVIATIONS 48

D. IMPORTS CLEARED FOR HOME CONSUMPTION 56

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1 . SUMMARY

This report covers a wide range of writing and marking equipment such as porous tip pens, hall point pens, pencils, crayons, chalks, ribbons for office machinery and certain parts and accessories. The goods fall within tariff items 98.03, 98.04, 98.05, 98.07, 9 8 .0 8 and 98.09»

The local industry producing these goods employed about 1000 people in 1979-80 and had sales of about $33 million. Ball point pens and fountain pens accounted for about 50 per cent of the sales of locally produced writing and marking equipment in 1979-80. Other important categories of local production are ribbons for office machinery, pencils encased in wood and porous tip pens.

The current assistance to goods covered by this report has developed over many years and, in terms of ad valorem duty equivalents, ranges from zero to at least 32 per cent.

The Commission's recommendations involve replacement of existing combination specific/ad valorem duties with ad valorem duties, reductions in assistance where it is relatively high and alignment and simplification of assistance for related goods and production activities.

In developing these recommendations the Commission had regard to the policy guidelines set out in its Act. The guidelines draw attention to the Government's desire to promote the well-being of the community and, among other things, to achieve sustained growth through balanced industry

development, improve the efficiency of resource use, facilitate adjustment to change while having due regard to the capacity of the economy to sustain change, recognise the interests of consumers, and ensure consistency between industry assistance and other policies.

The Commission considers that community well-being would be promoted by improving the allocation of productive resources by reducing the dispersion in assistance to related production activities and to goods which can be put to similar uses. Diversity of protection disadvantages the production and consumption of goods produced by industries, including those under

reference in this report, which are relatively lightly assisted. These are industries on which the existing structure of assistance imposes the greatest burdens through higher material and factor costs.

The Commission's approach to removing disparities in assistance involves recommending reductions in existing levels of assistance which are relatively high. This approach is consistent with the Government's stated general policy approach for manufacturing industry. The Government has

stated that industry needs to be more specialised and less reliant on assistance and that, as a long term objective, the Australian community will be best served by a manufacturing sector with a structure requiring minimum levels of Government support.

The following schedule lists the main categories of goods covered by this report, the existing General rates of duty, and the Commission’s recommendations.

1 White Paper on Manufacturing Industry, AGPS, Canberra, 1977.

Tariff Item Brief Description

Existing General Rate (%) Recommended

Rate (%)

98.03 Pens, pen holders, propelling pencils, certain parts and fittings therefor 10-30 (in some cases

a rate of

$0.08 or $0.15 per doz may apply)

20

98.04 Pen nibs and nib points Free, and

2

Minimum

98.05.1 Pencils 19 20

9 8 .0 5 .2 Pencil leads 6 Minimum

98.05.9 Crayons, pastels, drawing charcoals, chalks Free, and 2

Minimum

98.07 Date, sealing or numbering stamps, etc. 13 Minimum

9 8 .08.1 Ink-pads 32 20

9 8 .08.1 Typewriter and similar ribbons of textile material 32 25 on

implement­ ation ; 20 after

one year

98.08.9 Typewriter and similar ribbons of other than textile material 21 20

98.09 Sealing wax; copying pastes 17 Minimum

The Commission considers that pencils of Brazilian origin are causing injury to the Australian industry producing pencils. In the Commission's view, the extent of injury is sufficient to warrant removal of the developing country margin of preference for pencils of Brazilian origin.

The Commission's recommendations are not expected to have any significant effect on the level of activity and employment in the production of goods covered by this report.

2

2. INTRODUCTION 2.1 Origin And Scope Of Reference

This report on writing and marking equipment is part of a broader inquiry into 'Miscellaneous Manufacturing'. The reference, dated 8 June 1979, is one of the concluding parts of the Tariff Review program. The full text of the reference is set out in Appendix A.

This report covers a wide range of writing equipment such as ball point pens, fountain pens, porous tip pens, pencils, crayons, chalks and pastels (tariff items 98.03 and 98.05)· It also covers parts and fittings for the above goods including refills for ball point pens, pen nibs and nib points, barrels for pens and pencils and ink flow regulators (98.03, 98.04 and 98.05). The report also considers a range of marking equipment such as

date, sealing and numbering stamps (9 8 .0 7 ), ribbons for office machinery and ink-pads (9 8 .0 8 ) and sealing wax and copying pastes (98.09)·

Section 3 describes broad industry and market information for goods under consideration in this report. Sections 4 and 5 deal more specifically with writing equipment and with marking equipment respectively.

2.2 Tariff Provisions

Tariff provisions are set out in Appendix B and are summarised in the relevant product sections of the report. It should be noted that on and from 1 July 1981 all margins of preference accorded imports from the UK and the Republic of Ireland have been terminated. Goods which are the produce

or manufacture of these countries now attract the applicable General rates.

2.3 Evidence, Witnesses And Abbreviations

Evidence was received on these goods at public hearings at Sydney on 16 October 1980 and at Melbourne on 31 October 1980. To give interested parties an opportunity to comment on the Commission's draft report, further public hearings were held at Melbourne on 9 November 1981, and at Sydney on 18-19 November 1981.

A list of witnesses is set out in Appendix C. Requests and suggestions and applicable abbreviations are also listed in Appendix C.

The Commission received evidence from five manufacturers of writing implements (Biro Bic, Faber-Caste11, Staedtler, Columbia and Parker) and one importer of writing implements, Gillette. Evidence was also received from four manufacturers of office machinery ribbons (Carmassey, Columbia,

Karbonkraft and Moore) and one importer of ribbons (Brother). Evidence was also given by a number of suppliers of materials to local manufacturers of goods under consideration (APM, Boxton and Carr, Dow Chemical and Nylex).

No evidence was received on the other goods covered by this report.

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3

3. INDUSTRY AND MARKET INFORMATION

Table 1 sets out structural characteristics of the local industry producing the goods under consideration in this report. In 1979-80 there were 29 establishments mainly engaged in the production of writing and marking equipment under reference. These establishments had a turnover of about $37 million and employed about 950 people. Over 90 per cent of the value of

sales of locally produced goods by these establishments was of writing and marking equipment and these establishments produced over 90 per cent of the Australian production of those goods in 1979-80.

Official statistics relating to production and sales and transfers out of the writing and marking equipment under reference are set out in Table 2 for the five years 1975-76 to 1979-80. Official production and sales figures are only separately published for ball point pens and fountain pens and refills for ball point pens. For the remaining goods under reference only statistics on the value of sales and transfers out are collected. In order to preserve confidentiality, information on these goods is published under "other".

The Commission received statistical evidence on domestic production of ball point pens, porous tip pens, pencils and ribbons for office machinery. In the absence of a breakdown in the official statistics the Commission was unable to determine the extent, if any, of local production of other writing and marking equipment under reference. Evidence suggests that there is some production of desk sets, propelling pencils, fountain pens, chalks, crayons and pastels.

In 1979-80 sales and transfers out of ball point pens and fountain pens accounted for about 50 per cent of the value of sales of all locally produced writing and marking equipment under reference.

While the volume of production of ball point pens and fountain pens fluctuated over the period under review, the value of sales and transfers out of these goods increased on average by about 14 per cent per year from 1975-76 to 1979-80. Production of refills for ball point pens declined by about 50 per cent in quantity terms over the period under review.

The value of sales and transfers out of other writing and marking equipment increased on average by 8 per cent per year from 1975-76 to 1979-80.

4

TABLE 1 : STRUCTURAL CHARACTERISTICS OF ESTABLISHMENTS PRODUCING WRITING AND MARKING EQUIPMENT, 1977-78 TO 1979-80

Year Establishments3

Average total employment

Wages and salaries Turnover Purchases

No. No. $ '0 0 0 $ '0 0 0 $' 000

1977-78 41 1 123 9 130 36 108 15 848

1 978-79 31 1 002 8 926 34 563 15 596

1979-80 29 949 9 262 36 707 18 753

Value added

$ ' 0 0 0

19 680

17 393

19 056

Special­ isation ratio* 3

%

89

82

94

Coverage ratio0

%

88

88

93

a Mainly engaged in the production of goods falling under ABS commodity codes 902.01, 902.11 and 902.19 (wood encased pencils, automatic and propelling pencils and refills for propelling pencils); 902.21, 902.25 and 902.31 (ball point pens and fountain pens and refills for ball point pens); 902.41 (plastic pen and pencil barrels); 902.51 (pen holders); 908.11 (chalk); 909-01 (crayons) and 9 8 0 .8 9 (other - includes porous tip pens, ribbons for office machinery, stamps and ink pads). b The proportion of total output of these establishments accounted for by the writing and marking equipment under reference. c The proportion of the value of total output of the writing and marking equipment under reference produced by these

establishments.

SOURCE: ABS (Special compilation).

TABIE 2 : PRODUCTION AND SALES AND TRANSFERS OUT OF WRITING AND MARKING EQUIPMENT, 1975-76 TO 1979-80

1975-76 1976-77 1977-78

Product- Sales and Product- Sales and Product- Sales and

ion transfers out ion transfers out ion transfers out

Quantity Quantity Value Quantity Quantity Value Quantity Quantity Value

Ball point pens and fountain pens

'0 0 0

70 440

'0 0 0

72 285

$ '0 0 0

9 810

'0 0 0

81 056

'0 0 0

80 167

$ '0 0 0

11 673

'0 0 0

73 034

’000

66 762

Refills for ball point pens 6 325 7 071 1 406 5 238 4 843 1 449 3 336 3 069

Other3 10 242 12 461

TOTAL 21 458 25 583

$'000

13 065

1 414

13 227

27 706

1978-79 1979-80

Product- Sales and Product- Sales and

ion transfers out ion transfers out

Quantity Quantity Value Quantity Quantity Value

'0 0 0 '0 0 0 $ '0 0 0 '0 0 0 Ό 0 0 $ '0 0 0

Ball point pens and fountain pens 70 442 71 626 14 443 83 136 82 148 16 369

Refills for ball point pens 3 871 3 742 1 410 3 054 na b

Other3 12 967 16 236

TOTAL 28 820 32 605

a Includes pencils, porous tip pens, refills for propelling pencils, plastic pen and pencil barrels and chalk, ribbons for office machinery, stamps and ink pads.

SOURCE: ABS, Manufacturing Commodities - Principal Articles Produced, Catalogue No. 8303.0

Tables 3 and 4 summarise imports cleared for home consumption of writing and marking equipment under reference for the five years 1976-77 to 1980­ 81 . Details are given in Appendix D.

The value of imports of writing implements doubled over the period 1977-78 to 1980-81 to about $28 million, or by about 19 per cent per year. Porous tip pens constitute the largest single category of imports accounting for about 24 per cent of the total value of imports of writing implements in

1980-81. Other important categories were: ball point pens and pencils (22 per cent), parts for ball point pens and pencils (15 per cent), parts for other types of pens (7 per cent), pencils encased in wood (7 per cent), other pens (6 per cent), pencil leads (4 per cent) and crayons, pastels and

chalks (4 per cent).

Imports of writing implements and parts under by-law amounted to $6.9 million in 1980-81 or approximately 24 per cent of the total value of imports of writing implements and parts. The bulk of these by-law entries were parts and fittings such as pencil leads; nibs used in the manufacture

of porous tip pens; parts and fittings, other than ink cartridges, used in the manufacture or repair of fountain pens or propelling pencils; ball pen points used in the manufacture of ball point pens; porous ink reservoirs of a kind used in the manufacture of porous tip pens; and pen nibs and nib points. These imports amounted to $5.3 million or 77 per cent of total by­ law entries. The remaining entries were pens and pencils which have

specialised uses, eg clutch pencils used by architects, draftsmen etc.; pen kits used in electromechanical plotters; lettering pens used for lettering on plans, maps etc.; and lithographic film opaquing pens. Imports under by-law of these pens and pencils amounted to $1 .5 million or about 23 per

cent of by-law entries.

V

The value of imports of marking equipment under reference has also risen steadily, the increase averaging 28 per cent per year from 1 9 7 7 -7 8 to 1980-81. In that year the main categories of imports were ribbons of other than textile materials (43 per cent), stamps and composing sticks (28 per cent) and computer ribbons of textile materials (17 per cent). Imports under by-law amounted to $2 .6 million or about 27 per cent of the total value of imports of marking equipment in 1980-81. The bulk of these by-law

entries were various types of stamps, seals, pricers or labelling appliances entering under tariff item 98.07. By-law entry is also accorded to some types of inkers or ink rolls and ribbon (tariff item 9 8 .0 8 ) and fingerprint lifters and sealing wax (tariff item 9 8 .0 9 ).

7

1979-80 1980-31'

Value Quantity Value Quantity Value

'0 0 0 $ ' 0 0 0 '0 0 0 $ ' 0 0 0

56

58

3

403

10

149

10

321 195

23

16

3

559

39

3 496

54

19

259 145

3 532 27 449 4 580 43 842 6 399

619 7 075 669 9 243 841

20 2 516 127

4 135

(continued on next page)

TABLE 4 : IMPORTS OF MARKING EQUIPMENT CLEARED FOR HOME CONSUMPTION 1976-77 TO 1980-81 ($’000)

Stat code 1976-77 1977-78 1978-79 1979-80 1980-81a

2 635

1 607

824

a Preliminary. b Date, sealing or numbering stamps, and the like (including devices for printing or embossing labels), designed for operating in the hand; hand-operated composing sticks and hand printing sets incorporating such composing sticks.

c From 1-7-77 included in other (now Stat key 70) d Sealing wax (including bottle sealing wax) in sticks, cakes or similar forms, copying pastes with a base of gelatin, whether or not on a paper or textile backing.

SOURCE: Compiled from information supplied by ABS.

4. WRITING EQUIPMENT

This section of the report covers writing implements and parts and fittings falling within tariff items 98.03, 98.04 and 98.05· The Commission received evidence on local production of hall point pens, porous tip pens, fountain pens, wood encased pencils and propelling pencils. It appears that there is also some local manufacture of chalks, crayons and pastels. Sections 4.1 and 4.2 cover in some detail ball point pens, fountain pens, porous tip pens and pencils encased in wood. The term "porous" tip is used to cover pens commonly referred to as felt tip, fibre tip or markers.

Section 4.3 presents the Commission's conclusions on all writing equipment under reference.

4.1 Ball Point Pens, Fountain Pens And Porous Tip Pens 4.1.1 Introduction

This section covers ball point pens falling within tariff items 98.03-3, fountain pens falling within tariff items 9 8 .0 3 .2 and 9 8 .0 3 .9 and porous tip pens falling within tariff item 9 8 .0 3 .9 .

4.1.2 Industry and market information

The Commission received evidence from three manufacturers of ball point pens - Biro Bic, Faber-Castell and Staedtler. The latter two companies also produce porous tip pens. Production is generally concentrated on cheap disposable pens, although there is some production and/or assembly of more expensive items. Each of these manufacturers imports a range of

writing products, generally of a more specialised and/or expensive nature, which are sold as complements to the locally produced items.

Ball pen points and porous ink reservoirs used in the production of ball point pens and porous tip pens respectively are imported under by-law (2 per cent). The writing ink and pastes are generally imported but are sourced locally in some instances. Apart from these items, most inputs are products of Australian manufacturers including plastic resins used in the manufacture of the barrel and refill tube, packaging and, less frequently,

purchases of injection moulding machines, skin wrapping machines, and moulds for injection moulding machines.

Evidence was received from Parker which currently imports components into Australia and fully assembles products locally. With the exception of the ball point ink, all components are imported under by-law (2 per cent). Parker competes in the refillable (or non-disposable) segment of the

writing instrument market. Its products include fountain pens, ball pens, floating ball pens, porous tip pens and propelling pencils.

Evidence was also received from Gillette which imports a range of fully assembled writing instruments in bulk. All packaging, including gift boxes and/or blister cards, is undertaken by Gillette in Australia with many packaging items being manufactured in-plant using injection moulding

equipment, blistering equipment etc.

Official statistics for the production and sale of ball point pens and fountain pens are shown in Table 5. The Commission believes that production of fountain pens, particularly in quantity terms, would not be significant.

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TABLE 5 : PRODUCTION AND SALES AND TRANSFERS OUT BY LOCAL MANUFACTURERS AND ASSEMBLERS OF BALL POINT PENS AND FOUNTAIN PENS, 1975-76 TO 1979-80

Year Production

Change on previous year

Sales and transfers outa Change on previous year Quantity Value

'0 0 0 % '0 0 0 $ '0 0 0 %

1975-76 70 440 72 285 9 810 -

1976-77 81 056 + 15 80 167 11 673 + 19

1977-78 73 034 -10 66 762 13 065 +12

1978-79 70 442 - 4 71 626 14 443 + 11

1979-80 83 136 +18 82 148 16 369 +13

a Includes export sales.

SOURCE: ABS, Manufacturing Commodities - Principal Articles Produced, Catalogue No. 8303.0.

While production of ball point pens and fountain pens in quantity terms fluctuated over the five year period there was a steady rise in the value of sales and transfers out. The average unit value of sales increased from 13*5 cents in 1975-76 to 2 0 .2 cents in 1978-79, but declined slightly to 19*9 cents in 1979-80. As the goods included in the table range from cheap disposable ball point pens to expensive non-disposable ball point pens and

fountain pens, these average unit values provide only a rough guide to the general movement in prices over the five years. Production of ball point pens by Biro Bic, Faber-Castell and Staedtler accounted for about 85 per cent of the total production of ball point pens and fountain pens shown above.

Production of porous tip pens is not recorded separately in official statistics and data supplied by the two local manufacturers which gave evidence (Faber-Castell and Staedtler) cannot be disclosed for reasons of confidentiality. The Commission understands that there are a few other small manufacturers of porous tip pens. Production in quantity terms of porous tip pens by Faber-Castell and Staedtler increased by 17 per cent in 1978-79, 15 per cent in 1 979-80 and 4 per cent in 1980-8 1 .

Imports of ball point pens and porous tip pens are summarised in Table 6 .

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TABLE 6 : IMPORTS OF BALL POINT PENS, FOUNTAIN PENS AND POROUS TIP PENS CLEARED FOR HOME CONSUMPTION, 1976-77 TO 1980-81 ('000)

Description 1976-77 1977-78 1978-79 1979-80 1980-8 1 a

Ball Point Pens 21 757 27 210 29 044 27 449 43 842

Fountain Pens 302 181 122 386 652

Porous Tip Pens - writing 3 367 5 634 7 759 5 866 11 724

- other 64 596 53 698 45 314 54 641 41 677

Sub-total 67 963 59 331 53 073 60 507 53 401

TOTAL 90 022 86 722 82 239 88 342 97 895

a Preliminary.

SOURCE : Compiled by information supplied by ABS.

In total, imports of pens remained relatively constant in quantity terms during the period under review. Imports of ball point pens and porous tip pens used for writing have increased since 1976-77, while imports of other porous tip pens have declined.

In 1980-81, the major sources of imports of ball point pens in quantity terms were USA (23 per cent), Philippines (17 per cent), Japan (15 per cent), New Zealand (13 per cent) and France (10 per cent). Duty free imports from developing countries accounted for about 30 per cent of the volume of imports of ball point pens in 1980-81 compared with about 15 per

cent in 1976-77. The increase in imports from developing country sources has been mainly due to imports from the Philippines which rose from 129 000 units in 1976-77 to 7*5 million units or 17 per cent of total imports in 1980-8 1 .

Japan has been by far the dominant source of porous tip pens, accounting for between 55 and 80 per cent of imports in quantity terms during the period under review. Imports from Italy and Taiwan have increased in recent years but this trend has been more than matched by a significant

decline in imports from Japan since 1976-77. Imports of porous tip pens from developing countries have increased steadily from about 5 per cent of total imports of all types of porous tip pens in 1976-77 to about 18 per cent in 1980-81. Imports from Taiwan have accounted for most of this

increase, rising from 4 per cent of total imports to 16 per cent over the period.

The apparent local market in quantity terms for ball point pens and fountain pens is shown in Table 7.

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TABLE 7 : APPARENT LOCAL MARKET FOR BALL POINT PENS AND FOUNTAIN PENS, 1976-77 TO 1979-80 ('000)

1976-77 1977-78 1978-79 1979-80

Imports 22 059 27 391 29 166 27 835

Sales of Locally Produced Ball Point Pens and Fountain Pens® 80 167 66 762 71 626 82 148

TOTAL 102 226 94 153 100 792 109 983

a Includes exports.

SOURCE: ABS, Manufacturing Commodities - Principal Articles Produced, Catalogue No. 8303.0. Imports compiled from information supplied by ABS.

The local industry's share of the market for ball point pens and fountain pens declined from 78 per cent in 1 9 7 6 -7 7 to 71 per cent in 1 9 7 7 -7 8 and 1978-79 and then increased to 75 per cent in 1979-80.

Because sales and transfers out of locally produced porous tip pens are not recorded separately in the official statistics the Commission was unable to estimate the apparent market for porous tip pens. However, on the basis of import clearances data and confidential evidence supplied by the two manufacturers which gave evidence, it appears that apparent market supplies

of porous tip pens fluctuated during the four years to 1980-8 1 , largely as a result of fluctuations in imports of porous tip pens (other than writing porous tip pens). Imports supplied the bulk of this market although the share of the market held by the two manufacturers increased during this period.

Little statistical information is available on the market for writing instruments in Australia and there is little agreement on market segmentation. Gillette said that the market was comprised of three distinct segments:

. the disposable pen market covering pens selling in the up to $1 retail price range;

• the user segment of the market which covers pens retailing between $1 and $1 0 ; and

. the gift section of the market covering pens with a retail value exceeding $1 0 .

Parker said that the market was comprised of basically two segments - the disposable or throwaway segment and the refillable or non-disposable segment. Parker's products range in price from $4.95 to $975.00 per unit retail with the vast majority of sales occurring in the $4 .9 5 to $ 2 0 .0 0

retail segment. As refills for these pens sell at $2.00 retail, the company considered that it competed in the $2 .0 0 retail plus market segment whereas the disposable or throwaway segment was comprised of pens retailing at $2 .0 0 and less.

14

Local production by Biro Bic, Staedtler and Faber-Castell is concentrated in the disposable segment of the market. Parker said that it believed its products accounted for approximately 50 per cent of the non-disposable market segment by value, with another assembler, Sheaffer, having a further

20-25 per cent. It believed that importers such as Gillette, Cross, Waterman, Mont Blanc and several others collectively had an estimated 20 per cent value share.

The porous tip market is comprised of basically two segments - the 'fine liner' metal enclosed tip writing pen segment and the colouring pen and marker segment of the market. Evidence suggests that local production is concentrated in the area of colouring pens and, to a lesser extent, markers.

The degree of substitutability between the various types of ball point pens and porous tip pens varies considerably. Faber-Castell said that cheap colouring or project marker porous pens have been on the market for many years but that recent technological developments had led to the production

of porous tip pens in competition with ball point pens. The company said that there was not complete substitutability between the two as ball point pens and porous tip pens had different specialist applications. For example, ball point pens were said to be best used when carbon copies are required, while porous tip pens are best for ease of writing. However, Faber-Castell said that the new developments in porous tip pens had depressed the potential of the ball point pen market.

4.1.3 Existing assistance

Complete ball point pens (tariff item 98.03*3) are dutiable at 17 per cent or, if higher, $0.15 per dozen General; 9 per cent or, if higher, $0.15 per dozen less 7.5 per cent of value for duty (VFD) Canada; 2 per cent, or if higher, $0.15 per dozen less 15 per cent of VFD New Zealand and Free from

developing countries.

Assembled refills, and ball point pens and ball point pencils without the refill (tariff item 98.03.4) are dutiable at 17 per cent or, if higher, $0.08 per dozen General; 9 per cent or, if higher, $0.08 per dozen less 7.5 per cent VFD Canada; 2 per cent or, if higher, $0.08 per dozen less 15 per

cent of VFD New Zealand; and Free from developing countries.

Parts and fittings (tariff item 98.03.5) are dutiable at 17 per cent General, 9 per cent Canada, 2 per cent New Zealand and Free from developing countries.

Porous tip pens (tariff item 98.03.9) are dutiable at 10 per cent General, and Free from Canada, New Zealand and developing countries.

Fountain pens in fancy boxes (tariff item 98.03.2) are dutiable at 30 per cent General, 17 per cent Canada, 10 per cent from developing countries and Free New Zealand. Other fountain pens (98.03.9) are dutiable at 10 per cent General and Free from Canada, New Zealand and developing countries.

The Commission normally uses two measures to assess the effect of a given tariff rate, namely the nominal rate and the effective rate. The nominal rate of assistance measures the extent to which the tariff allows the gross returns per unit of output to producers to increase relative to the

(hypothetical) situation of no assistance. When assistance arises solely

15

from the imposition of a tariff, nominal rates are equivalent to the tariff rate expressed in landed duty free (ldf) terms. The nominal rate in this case is equal to the tariff rate multiplied by the ratio of the free on board (fob) price to the ldf price. As this ratio is high in the case of

the goods under consideration, the nominal rate roughly corresponds to the tariff rate.

The effective rate is a measure of the net assistance provided to a production process. It takes into account both the subsidy effects of assistance on an industry's output and any tax effects resulting from assistance on its inputs. The effective rate of assistance is defined as the percentage increase (or decrease) in value added per unit of output afforded by the assistance structure. A comparison of the effective rates of assistance accorded different activities gives a better indication of the extent to which production activities are assisted by the Government than one based on the rates listed in the Customs Tariff.

In the case of ball point pens the local industry is protected by combination specific/ad valorem duties. The average ad valorem incidence of the duty paid on imports of ball point pens from General sources was 17.1 per cent in 1980-81. This does not necessarily indicate the full protective incidence of the assistance structure as the specific rate may be shutting out cheap imports from General sources. However, evidence

suggests that the price of the cheapest ball point pens from General sources would not be much lower than the cut-off point of 88 cents per dozen where the specific rate comes into effect. The Commission understands that developing countries are globally the cheapest source of ball point pens and the bulk of imports from these sources are priced at above 75 cents per dozen. The Commission therefore believes that the protective incidence of the specific rate would not be greater than 20 per cent. Thus, nominal assistance against imports from General sources would be about the same as that accorded on average to manufacturing (estimated to be 15 per cent in 1980-81“ ^). Local production, however, is facing increasing competition from duty free imports from developing country sources.

Local manufacturers import the points for ball point pens under by-law (2 per cent). Most of the remaining inputs for disposable ball point pens are subject to duties ranging from about 15 to over 50 per cent for some types of plastic resins. The Commission estimates that the effective rate of assistance accorded to the production of disposable ball point pens against imports from General sources was about 15 per cent to 20 per cent. This is below the average effective assistance available to manufacturing generally

(estimated at 24 per cent for 1980-81^). Ad hoc by-laws are available for components for ball point pens (excluding springs, refills and parts therefor) having a retail price in excess of $2.50. As a result, effective assistance to the assembly of these goods would be higher than that available on average to manufacturing.

2 3

See IAC, Annual Report 1980-81, pp. 62-7, AGPS, Canberra. Ibid.

In the case of porous tip pens the nominal rate is below 10 per cent which is lower than the average for manufacturing generally. Local manufacturers import the porous ink reservoirs under by-law (2 per cent). The remaining inputs are similar to those used in the production of ball point pens and

incur duties ranging from about 15 per cent to over 50 per cent for some types of plastic resins. The Commission estimates that the effective rate of assistance accorded to the manufacture of porous tip pens would be less than 10 per cent which is considerably below the average for manufacturing generally.

Parts and fittings used in the production of fountains pens and propelling pencils are accorded by-law entry, resulting in effective assistance for the assembly of these goods being higher than that available on average to manufacturing.

4.1.4 Requests

Biro Bic requested that ball point pens be dutiable at a rate of 25 cents per dozen and that all developing country preferences be removed. Faber- Castell requested that ball point pens from all sources (except Papua New Guinea and New Zealand) be dutiable at 20 per cent or, if higher, 25 cents per dozen and that porous tip pens from all sources (except Papua New Guinea, developing countries and New Zealand) also be dutiable at 20 per

cent. Staedtler requested a General rate of 25 per cent for these goods and opposed cancellation of by-laws covering parts used in the local production of ball point and porous tip pens and markers. Gillette requested that all ball point pens, ball point pen refills and porous point

pens having a value for duty not exceeding 50 cents be dutiable at 20 per cent, while those having a value for duty exceeding 50 cents be dutiable at minimum rates. Parker requested a duty of 20 per cent on all pens and pencils and the retention of existing by-laws for parts and fittings.

In support of their requests, manufacturers generally argued that they were disadvantaged by high costs of labour and raw materials in Australia. Plastic resins used by the industry are dutiable from 22.5 per cent to over 50 per cent, ink at 25 per cent, components at 17 per cent and packaging at

25 per cent. With regard to imports from developing countries, local manufacturers said that they were directly disadvantaged by the tariff structure as they had to pay duties on raw materials while imports of finished goods from developing countries entered duty free. It was argued

that low priced imports from developing countries had depressed prices, and that imports were only being kept at present levels because local manufacturers were meeting this competition at the expense of the profitability of their operations.

Biro Bic and Faber-Castell were particularly concerned about imports of disposable pens by Gillette from the Philippines which, they claimed, were selling at prices well below the Australian equivalent. Faber-Castell also claimed that, apart from the Philippines damage, there was evidence that

some ball point pens of developing country origin were being dumped into the Australian market and retailing at $2 per pack of 50 pens. Biro Bic argued that the three tests for injury or threat of injury had been met - ie developing country imports compete directly against local production,

import penetration has been on a continuous basis rather than on a single occasion and, as total imports from developing countries constituted 12 per cent of the market in 1980-8 1 , injury was not 'insignificant'.

17

'■i'll

1 1

With regard to porous tip pens Faber-Castell said that it was concerned about competition from both developed and developing countries as there had been a substantial increase in imports from Italy and from Taiwan. The company said that it appeared that Japanese manufacturers were setting up manufacturing or manufacture under contract in Taiwan. At the draft report hearing, Faber-Castell said that imports were surging into the lower value

segment of the colouring pen market where local production was concentrated. The company said that it had recently been informed by its major Australian customers that its prices were not competitive with Taiwan manufacturers.

Biro Bic said that most Australian manufacturers operated in the lower value section of the market and that a flat rate of 25 cents per dozen on ball point pens from all sources would serve to protect local manufacturers, while having little effect on higher valued imports. Faber-

Castell argued that a common rate of duty on ball point pens and porous tip pens from all sources would eliminate distortions to the buying patterns caused by the existing varying rates of duty and would allow the company to diversify production into a wider range of porous tip pens. Staedtler

argued that there was a great deal of common industry involvement across various writing products and that a common rate of 25 per cent for ball point pens and markers (and pencils) would minimise disparities in assistance levels between these goods and also many other stationery

products. Parker said it intended to build its Australian operations into the major Parker supply point and central administration point for Asia and the Pacific. The company said that a rate of 20 per cent on writing instruments and retention of existing by-laws on parts and fittings would enable it to continue its assembly operations in Australia and achieve its domestic and export targets.

Both Biro Bic and Faber-Castell said that without the requested level of protection they would give serious consideration to the closure of manufacturing facilities and to importing all their requirements. Biro Bic

said that if it were forced to withdraw from the local manufacture of ball point pens, approximately 50 people would be retrenched while Faber-Castell said that approximately 110 persons would be dismissed leaving a total personnel employed of only 29· Parker said that the removal of the tariff would necessitate closure of the local assembly operation and a loss of 77 employees.

Gillette said that the local industry producing ball point pens was efficient and profitable and although there had been a Developing Country rate of Free for some years, the Australian manufacturers, particularly Biro Bic, had maintained a dominant share of the market. In support of its requests for minimum rates for certain pens having a value for duty exceeding 50 cents Australian, Gillette pointed to the existence of the by­ law for components for pens with a retail value in excess of $2.50 as proof that local manufacturers have concentrated their efforts in the lower value segment of the market (Gillette said that pens having a value for duty of 50 cents or more would, without exception, have a retail value exceeding $2.50) . Gillette said it had discontinued the importation of disposable pens from the Philippines and was curently importing them from the USA at

the General rate of duty. The company said it had no plans to recommence importation of major quantities of pens from the Philippines.

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4.2 Pencils

4.2.1 Introduction

This section covers pencils (encased in wood) and pencil leads which fall within tariff items 9 8 .05 .1 and 9 8 .0 5 .2 respectively.

4.2.2 Industry and market information

In a joint submission, the two local manufacturers of pencils, Columbia and Staedtler, indicated that the manufacture of pencils in Australia was a long established activity with production having commenced prior to World War II. Both manufacturers produce a range of black lead and colour pencils. They also market a range of other locally manufactured and

imported writing products such as high quality colour pencils, markers, and technical pens and pencils.

Local manufacturers import Californian incense cedar slats (not under reference) from the USA and pencil leads under by-law (2 per cent). These materials constitute the major cost materials component in the ex-factory price of locally made pencils. Activities undertaken in Australia include

assembling the lead slips and cedar slats, glueing and cutting the slats, dipping the pencils in paint and packaging.

At the time of the public hearings, local producers employed in excess of 150 persons in the production, administration and sales of wood-encased pencils. Of these, approximately 75 per cent were directly employed in the

production of pencils, although a small proportion were also engaged in the production of other goods.

Evidence was also received from Faber-Castell which is a major importer of pencil leads and pencils. The company imports colour pencils from an affiliated company in Brazil (duty free under developing country preference) and also imports a range of professional and commercial pencils

from General sources at 19 per cent duty. It employs approximately 12 persons in the packaging of imports for distribution in the Australian market.

Official statistics of production and sales of pencils are not separately published. Evidence indicated that Australian production of pencils in quantity terms increased marginally during the four years to 1 9 7 9 -8 0 but declined by about 10 per cent in 1980-8 1 .

Until recently import statistics for pencils were only collected in value terms. Import clearances by country of origin are summarised in Table 8 .

Imports of pencils in value terms fluctuated during the five year period under review. They increased by around 53 per cent in the two years to 1978-79, decreased by 5 per cent in 1979-80 and increased by 50 per cent in 1980-81. The proportion of imports accounted for by Brazil increased from

14 per cent in 1976-77 to 40 per cent in 1980-81 while the share held by Japan decreased from 31 per cent in 1976-77 to 15 per cent in 1980-81.

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TABLE 8 : IMPORTS OF PENCILS (ENCASED IN WOOD) CLEARED FOR HOME CONSUMPTION, 1976-77 TO 1980-81 ($’0 0 0 )

Country of origin 1976-77 1977-78 1978-79 1979-80 1980-8 1a

Brazil 127 281 483 456 812

Germany FR 81 104 121 140 206

Ireland - 10 127 111 204

Japan 288 446 229 149 317

Taiwan 53 55 78 92 175

UK 296 340 230 290 163

Other* 3 88 118 161 124 174

TOTAL 932 1354 1429 1364 2051

a Preliminary. b Including A/Govt and By-law, both of which are minimal. NOTE: Table may not add due to rounding.

SOURCE: Compiled from information supplied by ABS.

In the absence of data on imports in quantity terms the Commission could only estimate the size of the market in value terms since 1976-77· These estimates showed that the market for pencils increased by 26 per cent in value terms in 1977-78, by 7 per cent in 1978-79, by 10 per cent in

1979- 80, and by 18 per cent in 1980-81. It is estimated that the share held by local manufacturers remained relatively constant at around 65 per cent during the four years to 1979-80 but declined to about 57 per cent in

1980- 81. ‘

Local manufacturers estimated that the size of the market in volume terms in 1979-80 was about 128 million pencils of which local manufacturers accounted for approximately 64 per cent. However, the Commission believes that this overstates the size of the market. On the basis of confidential evidence and recent import statistics which are available in quantity

terms, the Commission estimated that the market in 1980-81 was in the vicinity of 110 million units.

The local industry said that there had been a steady increase in demand for pencils during the last decade and that factors contributing to this had been the growth in population in certain age brackets and the emphasis placed on further technical and higher education in the 1970s. This growth was expected to continue in the future with wastage being a contributing

factor as consumers use less of each pencil purchased before it is discarded and a new one obtained. At the draft report hearing, the local industry said that it did not believe the market would repeat its past volume growth for some time and that demographic changes were inducing slower growth in the colour pencil segment of the market.

20

Local manufacturers believed that the demand for pencils was largely price elastic. It was argued that a supplier of pencils which had traditionally marketed a high quality product could suddenly lose its market if another supplier offered pencils of acceptable quality, at a cheaper price.

4.2.3 Existing assistance

Pencils (tariff item 98.05.1) are dutiable at 19 per cent General, 11 per cent Canada and Free from Hew Zealand and developing countries. Pencils leads (tariff item 98.05.2), which are dutiable at 6 per cent General, are currently accorded by-law entry (2 per cent).

The nominal rate of assistance against imports of black lead and coloured pencils from General sources is about the same as that accorded on average to manufacturing. With regard to colour pencils at the cheaper end of the range, the local industry's major competition is currently from duty free

imports from Brazil. The nominal rate of assistance against these imports would be zero.

The effective rate of assistance measures the net assistance provided to the production process after taking account of any taxing affect arising from tariffs on inputs. In the case of pencils this tax effect is minimal because the main cost components, namely the pencil leads and the wood

slats are imported under by-law (2 per cent). As a result, the effective assistance provided by the tariff rate is relatively high (estimated at around 35 per cent) in comparison with the average available to manufacturing generally. However, against imports of duty free coloured

pencils from Brazil, effective assistance would be negative.

4.2.4 Requests

Columbia and Staedtler requested that the duty on pencils (tariff item 98.05.1) be increased to 25 per cent ad valorem and that the developing country preference be removed from pencils imported from Brazil. Local manufacturers also requested that the substantive rate on imports of

Californian incense cedar slats (tariff item 4 4 .14 .9 - not under reference) and pencil leads (tariff item 98.05.2) be reduced to Free plus 2 per cent.

Faber-Castell requested duty free entry of pencil leads and no increase in the duties on pencils. At the draft report hearing, the company opposed the Commission's proposal that Brazil should lose its developing country status.

In support of its requests, the industry argued that an increase in the General rate of assistance and a substantial increase in assistance against imports of pencils from Brazil was required to ensure that programs being undertaken by local manufacturers were not placed in jeopardy. It

was stated that Columbia was part way through a substantial re-structuring program designed to improve its production techniques and reduce overheads, Staedtler had completed a capital investment program in June 1979 that had improved its technical efficiency and both companies were currently

installing computers to aid their operations. At the draft report hearing, the local industry also argued that a duty of 25 per cent would remove disparities in assistance between pencils and other writing/stationery products which both manufacturers either produced and/or

distributed.

21

Columbia and Staedtler claimed that there had been a dramatic increase in imports of low priced colour pencils from Brazil and that local manufacturers were now facing the threat of significant injury. Both Columbia and Staedtler said that they had been forced to reduce profit margins in order to retain market share and that substantial orders were being lost to importers. In supplementary evidence, Columbia said it had

suffered injury in the past year in the form of loss of orders, consequent loss of production and employment, depressed margins and consequent loss of profit. The company said it had lost the Coles' colour pencil business which had been worth about 10 per cent of total pencil sales and had also lost substantial sales to other retail outlets such as newsagents and discount stores. In total, Columbia’s sales of colour pencils during the six months to December 1980 were 22 per cent down on the level recorded for the corresponding period of the previous year. The company said that the loss of the Coles' business was only now beginning to take effect and that production of colour pencils in the six months to June 1981 was only 35 per cent of the level recorded for the same period in the previous year.

Both manufacturers argued that they required pencil volume to sustain their total production operations and that if the erosion in sales and hence production volumes were to continue they would have to scale operations down and move to the importation of substitutable pencils. They argued that approximately 100 people could ultimately be retrenched.

Faber-Castell denied that imports of colour pencils from Brazil were causing unfair competition for local manufacturers at the cheaper end of the range. It argued that the Brazilian imports were not undercutting the Australian pencils at the trade and retail levels, and claimed that Brazilian pencils had merely displaced other imported pencils in the market. Faber-Castell argued that the growth in sales of Brazilian pencils

was largely due to increased demand for packs of 36 different coloured pencils which the company had recently introduced into the lower/school quality end of the market. Faber-Castell said that the local manufacturers only supplied sets of 12 and 24 different coloured pencils to this segment of the market. In support of its case for retention of the preference, Faber-Castell also argued that Brazil was currently experiencing inflation at the rate of 120 per cent to 160 per cent per annum and that much of the increase in value of imports was due to this factor. At the draft report hearing, Faber-Castell argued that Australian manufacturers were now providing an acceptable product and were well under way to regaining their lost market share. As a result Faber-Castell claimed it was now losing substantial orders. The company suggested that the Commission review the forward order position of the local producers.

4.3 Conclusions

Writing implements falling within tariff items 98.03 to 98.05 are currently subject to a wide range of duties. General rates range from Free and 2 per cent for crayons, pastels and chalks, 10 per cent for porous tip pens, 17 per cent (or a specific rate) for ball point pens to 30 per cent for certain fountain pens, pen and pencil sets, and propelling pencils and sliding pencils.

Local production is concentrated in the manufacture of disposable ball point pens, porous tip pens and pencils, while there is some assembly of propelling pencils, and fountain pens and non-disposable ball point pens. As most of the materials used in the production of disposable ball point and porous tip pens are subject to tariffs ranging from about

22

15 per cent to over 30 per cent for some types of plastic resins, the effective assistance provided hy the above tariff rates are relatively low compared with-that available on average to manufacturing generally. Most

of the remaining activity in the industry is basically of an assembly nature. In the case of pencils, propelling pencils, fountain pens and ball point pens having a value in excess of $2 .5 0 retail the major components are imported under by-law (2 per cent). As a result, the effective

protection provided to these activities is relatively high compared with the manufacturing average.

As part of its general approach to assistance issues and in accordance with its policy guidelines, the Commission is concerned with reducing disparities in assistance which exist between similar production activities and similar consumption goods. Large disparities in assistance can result

in losses in economic efficiency, particularly where activities compete closely for specialised resources such as labour with particular skills, capital equipment and material inputs. Less diverse assistance provides a more neutral economic climate in which producers’ decisions are

determined more by market place incentives than the pattern of protection. More uniform assistance to goods which are substitutes in consumption leaves the underlying pattern of market prices largely unchanged and thus consumption choices are more determined by consumer preferences than the

structure of assistance.

Pencils, porous tip pens, ball point pens, fountain pens and other writing equipment substitute to some degree in end uses. For example, fountain pens, ball point pens and porous tip pens are substitutable for writing on paper; coloured pencils, porous tip pens, crayons and pastels can all be used for children's 'colouring-in'; porous tip pens and chalk would substitute (indirectly) for white board or black board use.

In the main area of production, ie disposable ball point pens and porous tip pens, producers use similar raw materials such as plastic resins, inks and packaging, and the evidence indicated that there is some commonality of production techniques between the two, for example, the fabrication of the plastic barrels.

Currently, specific rates of duty may apply to ball point pens, to assembled refills, and to ball point pens without the refill. The level of assistance provided by a specific rate is often difficult to evaluate and varies over time. More importantly, a specific rate provides higher rates

of assistance to the lower priced products. Biro Bic suggested that a specific rate was appropriate because local production was concentrated in the cheaper end of the market and that a specific rate would not affect imports of higher price goods. However, the Commission believes that there

is some degree of competition between all the pens under reference and that consumption efficiency would be promoted by a uniform ad valorem rate across all types of writing implements.

Staedtler and Columbia argued that a rate of 25 per cent would remove disparities in assistance between pens and pencils and a range of writing/stationery products, currently dutiable at 25 per cent, which both manufacturers produce and/or distribute. However, the Commission considers

that the production links (ie material inputs and production processes) between stationery products and the goods under reference are not significant and that production distortions would not result from different

nominal rates on these goods.

23

The Commission considers that production and consumption efficiency would he enhanced if duties on all types of pens and pencils were uniform, and recommends a rate of 20 per cent. Goods entering under tariff item 98.04 (pen nibs and nib points) and tariff item 98.05.9 (ie crayons, pastels, drawing charcoals and various types of chalks) are currently dutiable at 2 per cent and the Commission recommends that minimum rates apply.^ Pencil leads falling within tariff item 9 8 .0 5 .2 are currently dutiable at 6 per cent, but are accorded by-law entry (2 per cent). The Commission recommends these goods be dutiable at minimum rates. Some other parts and

fittings used solely or principally in the production of writing implements are not produced in Australia and are accorded entry under by-law. As a major review of the by-law system is currently being undertaken, the Commission does not propose to make any recommendations in relation to

these by-laws at this stage. The Commission recommends that a rate of 20 per cent apply to other parts and fittings. With regard to the main area of local activity (disposable ball point pens and porous tip pens) these recommendations should ensure that the assembly of these goods in Australia is assisted at roughly the same rate as the production of the same items from raw materials.

Implementation of the Commission's recommendations would result in a narrowing in assistance for writing equipment, in terms of both nominal and effective rates of assistance. They would provide nominal assistance to most writing equipment under reference similar to that accorded on average

to manufacturing industry. In the case of disposable porous tip pens and ball point pens a duty of 20 per cent would provide effective assistance which is slightly below that available to manufacturing generally. Effective assistance to pencils, propelling pencils, fountain pens and non­ disposable ball point pens would still be relatively high compared with that available on average to manufacturing because major components used in

the assembly of these goods would continue to be accorded entry under by-law (2 per cent).

A uniform duty of 20 per cent would retain existing assistance to the production of ball point pens and pencils, and increase assistance available to the production of porous tip pens where some increase in activity and employment could occur. The recommendations also reduce assistance for the assembly of fountain pens and propelling pencils which could result in some minor loss of activity in these areas.

The Commission received a number of requests for the removal of the preferential treatment accorded to certain developing countries. The Australian tariff preference system is designed to assist developing countries overcome disadvantages they may experience in competing with other suppliers in the Australian market. The system permits specified products imported from developing countries to enter Australia at rates of duty below the relevant General rates providing that such imports do not, or would not, cause or threaten injury to Australian industry.

These preferences may be modified or withdrawn by the Government in circumstances where injury or threat of injury to Australian industry occurs and/or when developing countries are considered to have become competitive with overseas suppliers. However, the Government has asked the

4 Where minimum rates are recommended in this report it is intended that a rate of duty of "Free" should apply subject to international commitments or other relevant Government decisions.

24

Commission not to base its suggestions or recommendations for withdrawal or modification of a developing country preference on the competitive need criterion. In evidence to the Commission^, the Departments of Trade and Resources and Industry and Commerce together stated that "the reason for

this is that the application of competitive need in any particular case, in the absence of injury, may involve the consideration of factors other than purely economic considerations, particularly Government policy objectives in the trade relations area". It is the Government's intention, therefore, that any Australian industry, which is concerned about imports from developing countries at concessional rates, should base its case to the Commission on injury or threat of injury.

Previous reports by the Commission on developing country preferences have discussed criteria for evaluation of injury or threat of injury. Injury can be reflected by one or more factors, such as a decline in the volume or value of production or sales, a decline in capacity utilisation, reduction

in employment or a decline in profitability. Imports or potential imports, at developing country preferential rates, would need to be shown to be a significant contributory factor causing such changes. Based on evidence provided by the Department of Trade and Resources at earlier inquiries, the

Commission has generally considered that injury would need to be, or threaten to be, not insignificant, apply to the major part of the industry and be evident on a continuing basis rather than on a single occasion, to warrant withdrawal or modification of developing country preferences.

Biro Bic and Faber-Castell requested the removal of all developing country preferences from imports of ball point pens. Biro Bic argued that the increase in imports from developing countries had been on a continuous basis, that they competed directly against local ball pen production and

that their share of the market was not 'insignificant'. Faber-Castell argued that it was suffering injury in the form of reduced profit margins.

Imports from developing countries of ball point pens have increased steadily in recent years, rising from 3*5 million units in 1976-77 (.15 per cent of imports) to 13 -5 million units in 1980-81 (30 per cent of imports). Imports from the Philippines accounted for most of this increase rising from 129 000 units in 1976-77 to 7.5 million units in 1980-81 (17 per cent of imports). However, imports from these sources still only accounted for a small proportion of the total market for these goods. Assuming that the market for ball point pens and fountain pens in 1980-81 was not less than

it was in 1979-80 (ie 110 million units), it is estimated that imports of ball point pens from the Philippines accounted for about 7 per cent of this market in 1980-8 1 , with total imports from developing countries accounting for about 12 per cent. At the draft report hearing, Gillette said it had

ceased importing its disposable pens from the Philippines. On the basis of available information the Commission does not consider that imports of ball point pens from developing country sources are causing or threatening injury.

Faber-Castell requested the removal of the preference from imports of porous tip pens from Taiwan on the ground that these imports were threatening injury. Faber-Castell argued that imports from Taiwan were surging into the lower value end of the market for colouring pens in which

the company competed and that, as a result, it faced the prospect of loss of sales, a reduction in the benefits of economy of scale and an absolute loss of profitability.

5 Statement of 20 August 1980 reproduced in IAC, Annual Report 1980-81, pp. 280-1, AGPS, Canberra.

25

Because sales and production of locally produced porous tip pens are not recorded separately in official statistics, the Commission was unable to estimate the total market for porous tip pens. Information supplied by two

local producers, Faber-Castell and Staedtler, cannot be disclosed for reasons of confidentiality. However, on the basis of available information, it appears that the market for porous tip pens (excluding writing porous tip pens) has fluctuated in recent years, largely as a result of fluctuations in the level of imports. Production by each of Faber-Castell and Staedtler has increased in each year since 1977-78. Although total imports of porous tip pens (other than writing porous tip pens) fluctuated during the period under review, imports from Taiwan increased steadily, rising from 3.4 million units in 1 977-78 (7 per cent of imports) to 7 million units in 1980-81 (17 per cent of imports.) On the basis of available information, however, the Commission does not consider

that these imports are currently causing injury as total imports have fallen overall and Faber-Castell and Staedtler have increased production and their share of the market. The Commission also does not consider that the threat of injury is significant.

Imports of coloured pencils from Brazil have increased rapidly in recent years. The Commission estimated that the total market for pencils encased in wood in 1980-81 was in the vicinity of 110 million units and that coloured pencils accounted for roughly 60 per cent of this market. On the basis of these estimates, imports of coloured pencils from Brazil in

1980-81 accounted for about 15 per cent of the total market for pencils encased in wood and almost 30 per cent of the market for coloured pencils. Faber-Castell, the importer of coloured pencils from Brazil, argued that the increase in imports had occurred largely in a market area (ie 36 different colours 'school quality') not catered for by Australian producers. At the draft report hearing, the company argued that the local producers were now providing an acceptable product and that Faber-Castell was now losing substantial orders.

The two local producers, Columbia and Staedtler, said they were suffering injury in the form of reduced profit margins, loss of orders and consequent loss of production. On the basis of confidential evidence supplied by the two firms, the Commission estimates that the volume of total Australian production of pencils encased in wood fell by about 10 per cent in 1980-81 from the level recorded in the previous year. Most of this loss occurred in coloured pencils during the six months to June 1981 when production was only 50 per cent of the level recorded for the corresponding period of the previous year. The Commission has concluded that imports of coloured pencils from Brazil have caused injury to the local industry and, on the basis of confidential information supplied by local producers at the draft report hearing, the Commission considers that this injury has continued

into the current financial year.

The Commission suggests therefore that the developing country preference be removed from imports of pencils from Brazil falling within tariff item 98.05.1. The Commission suggests that the preference be removed completely because it considers that pencils from Brazil could continue to cause

injury if the preference were only partly withdrawn.

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The margins of preference available to imports from developing countries range from 10 percentage points to 20 percentage points. The Commission is recommending a uniform tariff for all pens and pencils from General sources and, having regard to the Government's desire for tariff simplification,

suggests that a uniform rate of 5 per cent apply to all imports from developing countries, except for pencils from Brazil, and goods for which the Commission recommends minimum rates.

Goods of New Zealand origin are currently dutiable at rates ranging from Free to 12.5 per cent which provide margins of preference ranging up to 30 percentage points. In relation to imports from New Zealand, the Commission is required to suggest the lowest rate consistent with both protection of

Australian industries and with reasonable competition between Australian and New Zealand products. It is also required to maintain a margin of preference which as a minimum shall be the lowest of 15 percentage points or the margins operative at 31.1.73 or 30.11.77. Most imports from New

Zealand enter under tariff item 98.03.3 statistical code 14 (ball point pens) and are currently dutiable at 2 per cent or, if higher, $0.15 per dozen less 15 per cent of value. The ad valorem equivalent of the duty paid on these imports in 1980-81 was about 5 per cent. As most imports

enter under this sub-item, the Commission suggests that, having regard to the objective of tariff simplification, a uniform rate of 5 per cent should apply to all imports from New Zealand. This would provide a margin of preference of 15 percentage points to all goods of New Zealand origin

(except those for which the Commission recommends minimum rates).

The Commission suggests that writing equipment under reference of Papua New Guinea origin be dutiable at minimum rates. It appears that goods under consideration in this section are not of significant trade interest to Canada. The Commission suggests that goods of Canadian origin be dutiable at rates equal to the applicable General rates.

5. MARKING EQUIPMENT 5.1 Ink-Pads And Ribbons For Office Machinery 5.1.1 Introduction

This section covers ink-pads and typewriter and similar ribbons of textile material falling within tariff item 9 8 .0 8 .1 , and typewriter and similar ribbons of other than textile material falling within tariff item 98.08.9·

Evidence on ribbons was given jointly by Columbia, Carmassey and Karbonkraft, three local manufacturers; independently by another local manufacturer, Moore; and by Brother, an importer. No evidence was received on ink-pads.

5.1.2 Industry and market

Columbia, Carmassey and Karbonkraft estimated that between them they accounted for 90 per cent of local production of ribbons for office machinery. Columbia produces both fabric and film ribbons and also a range of writing and stationery materials. Carmassey and Karbonkraft produce fabric ribbons only. These two companies are also manufacturers of carbon copying papers and converters/processors of copying film. Moore produces computer ribbons.

Ribbons are manufactured in Australia from imported textile fabric, film and spools. Processes undertaken in Australia include inking the fabric and coating and slitting of the film, with the former being wound onto spools and the latter usually wound around a core. Most fabric ribbons are

then wrapped ready for distribution, whilst the film ribbons are "stuffed" into casettes and packaged. Cassettes are sourced from overseas and locally.

Fabric ribbons are most often manufactured for older-style manual typewriters, electric typewriters and more recently for micro-computers, while film ribbons are made for electric typewriters, word processing machines and computers.

At the time of the 1980 public hearings Columbia, Carmassey and Karbonkraft directly employed a total of 75 people in the manufacture of ribbons while total employment by these three companies was about 210. Moore claimed to be the largest manufacturer of business forms in Australia and employed about 900 people throughout Australia - 8 of these were employed in the manufacture of computer ribbons.

Since the initial round of public hearings, Bowater has amalgamated its Karbonkraft Division with Ramsey and Hall Pty Ltd, a small ribbon manufacturer in Victoria which it recently purchased. The company intends to integrate its ribbon production at the latter's factory with production

facilities being moved from Botany in New South Wales.

Production and sales of locally produced ribbons for the five years 1976-77 to 1980-81 are shown in Table 9 -

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TABLE 9 : PRODUCTION AND SALES BY LOCAL MANUFACTURERS OF RIBBONS, 1976-77 TO 1980-81 ($'Q00)

1976-77 1977-78 1978-79 1979-80 1980-81

Production 1193 1809 1936 2330 2684

Sales 1746 2651 2536 2889 3547

SOURCE : Evidence.

Production and sales of ribbons in value terms rose over the period under review. Production increased by 52 per cent in 1977-78, by only 7 per cent in 1978-79 and then by 20 per cent and 15 per cent in 1 9 7 9 -8 0 and 1980-81 respectively. As most manufacture has been carried out to order in the

past, a similar pattern was reflected in relation to sales. The value of sales of ribbons declined by 4 per cent in 1978-79 and then increased by 14 per cent in 1 9 7 9 -8 0 and 23 per cent in 1980-8 1 .

Import clearances of ribbons from 1976-77 to 1980-81 are shown in Table 10.

TABLE 10 : IMPORT CLEARANCES OF RIBBONS, 1976-77 TO 1980-81 ( $ ’0 0 0 )

1976-77 1977-78 1978-79 1979-80 1980-8 1 a

Ribbons made of textile material . computer nsr 658 1069 1475 1607

. other 963b 579 831 880 824

Other 1221 201 6 2753 3230 4110

TOTAL 2184 3253 4653 5585 6541

a Preliminary. b Including computer ribbons. nsr - not separately recorded.

SOURCE : Compiled from information supplied by ABS.

Imports of ribbons were only recorded in value terms during the five years to 1980-81. The total value of imports increased rapidly during this period, rising by 49 per cent in 1977-7 8 , 43 per cent in 1978-79, 20 per cent in 1979-80, and 17 per cent in 1980-81. The value of imports of

ribbons made of textile material (other than computer ribbons) declined slightly during this period while computer ribbons (of textile material) and other types of ribbons showed substantial growth.

Imports of ribbons are sourced mainly from General sources, the USA being the dominant supplier accounting for about 47 per cent of imports in 1980- 81.

29

Evidence was given by only one importer, that is Brother. This company, which is an importer and distributor of products manufactured by its Japanese parent company including typewriters, typewriter ribbons, sewing machines and knitting machines, employs two persons in connection with goods under consideration.

As imports were not recorded in quantity terms during the period under review the Commission was only able to estimate the size of the market for ribbons in value terms for the five years from 1976-77 to 1980-81. The estimates are set out in Table 11.

TABLE 11 : MARKET ($’0 0 0 ) SUPPLIES OF RIBBONS, 1976-77 TO 1980-81

1976-77 1977-78 1978-79 1979-80 1980-81

Imports (fob) 2 184 3 253 4 653 5 585 6 541

Duty paid 508 721 1 057 1 273 1 507

Freight and insurance3 218 325 465 558 654

Total imports 2 910 4 299 6 175 7 416 8 702

Production 1 193 1 809 1 936 2 330 2 684

TOTAL 4 103 6 108 8 111 9 746 11 386

a Estimated at a rate of 10 per cent of the fob value of imports.

SOURCE: Estimated from data set out in Tables 9 and 10.

Market supplies in value terms increased significantly during the five years to 1980-81 , rising by 49 per cent in 1977-7 8 , 33 per cent in 1978-79, 20 per cent in 1 979-80 and 17 per cent in 1980-81. During this period the share of the market held by local producers fell from about 30 per cent to

about 24 per cent.

The local industry said that technological developments had led to significant changes in the type of equipment using the ribbons under reference, for example, the growing acceptance of mini-computers and word

processors. Demand for such new equipment was still relatively small in Australia but the local industry expected it to increase significantly in line with trends overseas. As a result, the local industry expected rates

of growth of up to 30 per cent per annum in some sectors of the market.

At the 1 980 public hearings, local producers said that they had not been major suppliers to these areas and they identified certain barriers which may hinder their participation in the future. For example, the ribbon requirements for new office equipment systems, such as mini-computers, word

processors and later model electric typewriters, are often satisfied by the manufacturers. At the same time, many manufacturers of computer hardware are not interested in the on-going supply of ribbons and the local industry

said that it was currently examining the feasibility of manufacturing its own cassettes, especially those designed specifically for use in word processors. However, many cassette types are covered by patents and the

local industry said that securing agreements to manufacture them locally was proving difficult.

30

At the draft report public hearing the local industry argued that many of these barriers to new markets were being overcome. The industry said that it had successfully convinced some computer hardware suppliers of the advantages of local sourcing of ribbons, such as regular and immediate

supply. Cassettes could now be sourced from a local custom plastics moulder and problems associated with the overseas sourcing of certain other cassette types had been overcome. As a result, the industry said it was

now in a better position to participate in the high growth areas of the market - Columbia had commenced production of word processor ribbons and most of the growth experienced by local producers in 1979-80 and 1980-81 had been due to increased sales of micro and mini-computer ribbons.

5.1.3 Existing assistance

Textile ribbons and ink-pads falling within tariff item 98.08.1 are currently dutiable at 32 per cent General, 15 per cent Canada, 10 per cent from developing countries, and 9 per cent for textile ribbons and 7 per cent for ink-pads from New Zealand. All other ribbons fall within tariff

item 98.08.9 and are dutiable at 21 per cent General, 13 per cent Canada, 10 per cent from developing countries and 6 per cent from New Zealand.

Nearly all the materials used in the production of fabric and film ribbons (eg woven piecegoods used in the manufacture of inked fabric ribbons and polyethelene/polyester film used in the manufacture of coated film ribbon, spools and cassettes) are imported under by-law (2 per cent). As a

consequence, the above assistance structure provides local producers of ribbons with high effective rates of assistance ranging from about 35 per cent to about 60 per cent. Since the initial hearings Columbia has commenced sourcing cassettes from a local custom plastic moulder. The effective rate of assistance for ribbons packed in locally sourced

cassettes would be lower (at around the average available to manufacturing generally) than those identified above, because of the additional value added in Australia and the fact that plastic resins used in the production

of these cassettes are subject to relatively high rates of duty.

5.1.4 Requests .

Columbia, Karbonkraft and Carmassey jointly requested that fabric ribbons falling to tariff item 98.08.1 and film ribbons falling to item 98.08.9 be dutiable at a General rate of 30 per cent. Alternatively, if the Commission believes that 30 per cent is unacceptable as a long term rate of assistance, these companies requested that ribbon currently falling to both

tariff items 9 8 .08 .1 and 98.08.9 be dutiable at 30 per cent for two years from the date of implementation, then phasing to 25 per cent. Moore requested that computer ribbons falling to tariff item 9 8 .0 8 .1 be dutiable at 40 per cent General, New Zealand 20 per cent and 10 per cent from developing countries. Brother requested that cassette ribbons for portable

typewriters - fabric ribbons (9 8 .0 8 .1 ), fabric and carbon ribbons (98.08.9), and carbon ribbons (98.08.9) to a width of 14.3 mm be admitted duty free.

Columbia, Carmassey and Karbonkraft argued that they required assistance because European, Japanese and American manufacturers had the advantage of high volume domestic markets and were therefore able to operate high speed and highly productive capital equipment which could not be viably operated

in Australia. They also maintained it would be extremely difficult to obtain such equipment as it was generally developed and made in-house by overseas ribbon manufacturers. There are very few suppliers of spools and fabrics used in the manufacture of ribbons and local producers argued that overseas manufacturers were further advantaged because of their close proximity to these materials suppliers.

Despite high effective assistance the local industry argued that there were compelling reasons for maintaining current levels of assistance. Firstly, most employees engaged in the production of ribbons are women who would have substantial difficulties in finding alternative employment. Secondly, whilst all three producers make other products, they require the throughput volumes of ribbons to spread manufacturing labour and overheads. They argued that any reduction in ribbon volumes would therefore bring the

viability of their total operations into question. Thirdly, consumers would not benefit, in the way of lower prices, from a reduction in duties because increases in demand would tend to ensure each importer a profitable portion of the market, without the need to resort to pricing policies designed to increase market shares. Fourthly, users with old equipment,

those with low demand or those with highly specialised needs, would have extreme difficulty in obtaining supplies of ribbons if local manufacturers were forced to phase out their production activities. As a result, end users would be left with little alternative other than to dispense with

their current office equipment and undertake the procurement of new expensive machinery.

Finally, the local industry argued that the levels of assistance requested would enable it to move into new product areas, expand production and reduce unit costs.

At the draft report hearing, the local industry requested a long term rate of 25 per cent for all types of ribbons. The industry argued that the Commission's proposal of a rate of 20 per cent meant a substantial reduction in assistance to those areas where production was concentrated

(ie fabric ribbon) and would probably lead to significant sales damage, at a time when the industry was achieving dramatic increases in production and sales volume and value. With·regard to the high growth areas of the market

(ie micro and mini-computer ribbons), the local industry said that the increased price competitiveness of imported fabric ribbon would encourage hardware suppliers to return the sourcing of such ribbons to the original overseas manufacturers. It was argued that this would hinder the

industry's efforts to participate in the high growth areas of the market and reduce its unit costs.

The local industry also argued that a long term rate of 25 per cent would remove disparities in assistance between ribbons and other products produced by the industry. All three companies produce coated copying and

carbon papers, while Columbia and the Bowater Group also produce a range of stationery products. All these goods are currently dutiable at 25 per cent.

32

In support of its request for duty free entry of certain types of cassette ribbons to a width of 14-3 ran for portable typewriters, Brother argued that these ribbons could not be economically produced and assembled in Australia. Furthermore, the company claimed that any reduction in the price of cassette ribbons following an elimination of duty would not attract customers to the cassette model of portable typewriter rather than

the spool model because of the significant price differences between the two models.

5.2 Other Office Equipment

This section covers goods falling within tariff items 98.07 and 98.09· Ho evidence was given on these goods, although the Commission understands that there is local manufacture of stamps and marking devices.

Imports of these goods are dutiable at the rates shown below:

Tariff Item Description General Rate

98.07 Date, sealing or numbering

stamps, hand-operated

% 13

composing sticks and hand printing sets incorporating such composing sticks.

DC: Free

98.09 Sealing wax in sticks, cakes

or similar forms; copying pastes 17

with a basis of gelatin, whether or not on a paper or textile backing.

DC : 10

A summary of imports of these goods is set out in Table 4. Imports of goods under tariff item 98.07 increased steadily throughout the period from $1 .2 million in 1976-77 to $2 .6 million in 1980-8 1 , while imports under tariff item 98.09 have been minimal. In recent years most imports under

these tariff items have come in under by-law (2 per cent duty).

5-3 Conclusions

This section covers marking equipment falling within tariff items 98.07, 98.08 and 98.09. Goods under consideration include various types of stamps and marking devices, ink-pads, ribbons used in office machinery, sealing wax and copying pastes. Imports of these goods are dutiable at General

rates ranging from 13 per cent for stamps and marking devices to 32 per cent for ink-pads and ribbons made of textile material.

Evidence received by the Commission on the goods under reference related only to various types of ribbons used in office machinery. Imports of these goods are mainly from General sources and are dutiable at 32 per cent for ribbons made of textile material and 21 per cent for other types of

ribbons. Most of the raw materials used in the manufacture of ribbons (fabric, film and spools) are imported under by-law (2 per cent). As a result, effective assistance provided by the duties is high in relation to that currently available to manufacturing generally. Despite high nominal

and effective assistance the local producers have only supplied a small share (about 30 per cent) of the market in recent years.

33

The market for ribbons has grown significantly in recent years. Technological developments have led to significant changes in types of office machinery using ribbons and opened up new market sections for ribbon manufacturers, particularly the supply of ribbons used in mini-computers

and word processors. The local industry (Columbia, Karbonkraft and Carmassey) said that a long term rate of 25 per cent would enable it to participate in the growth sectors of the ribbon market and to overcome, through higher production volumes, some of the disadvantages that it currently faced.

Although a rate of 25 per cent still provides higher than average levels of effective assistance, the local industry argued that there were compelling reasons to support continuation of this assistance. Although all three producers make other products, it was argued that any reduction in ribbon volumes would bring the viability of their total operations into question. Most of the employees engaged in the production of ribbon are women and it was claimed that they would have problems finding alternative employment if retrenched.

The Commission does not consider that employment in the industry should be encouraged by maintaining tariffs which are high, or raising tariffs which are moderate, for goods not currently produced. It considers that production for newer sections of the market should be assisted at levels of protection closer to the average for manufacturing industry. The Government has stated that, as a long term objective, the Australian community will be best served by a manufacturing sector with a structure requiring minimum levels of government support. In line with this objective the Commission is concerned that resources should not be encouraged into activities requiring high assistance for longer term viability.

It was also argued that consumers would not benefit from any tariff reductions. Because of the growth in the market, it was claimed that importers would not pass on the reductions to end-users. This implies that importers are in a monopoly position and that new importers could not enter the market. However, evidence suggests that this is not the case and normal competition should ensure that reductions are passed on.

The industry believed that some consumers could be penalised by tariff reductions as users of older equipment would have difficulty in obtaining supplies of ribbons if local manufacturers were forced to phase out their production activities and would have to dispense with their older office equipment. The Commission considers that ribbons for older office machinery will be supplied by local manufacturers and/or importers for as

long as it is profitable to do so. As demand for these types of ribbons dwindles, it may become in the interests of one or two suppliers to meet this total demand. If demand diminishes to the extent that it is no longer profitable to supply these ribbons then the cost to the community of

replacing this equipment would probably not be significant.

Finally, the industry argued that a long term duty of 25 per cent would remove disparities in assistance between ribbons and other stationery products manufactured by the industry which are currently dutiable at 25 per cent. Although many of the products under consideration in this report are sold alongside other stationery products, the Commission does not

consider them to he competitive in consumption or production. Most of the stationery products manufactured by the local industry are paper based and are subject to duties on their inputs, whereas the ribbons under reference are largely manufactured from textile material and film which are imported under by-law (2 per cent). Thus, the Commission does not believe that

production distortions would arise from differing nominal rates on these products. The Commission considers that local ribbon production should be assisted at rates more in line with those available to manufacturing in general. This would encourage a more efficient use of resorces.

The degree of substitutability between the various types of ribbons under reference varies considerably. However, some ribbons entering under tariff item 98.08.1 (dutiable at 32 per cent General) are in direct competition

with other ribbons entering under 9 0 .0 8 .9 (dutiable at 21 per cent General). On the production side, with the exception of some cassettes all the main materials used in the production of fabric and film ribbons (fabric, film and spools) are imported under by-law. With regard to the

activities undertaken in Australia, similar raw materials are used in the processing of the ribbons, eg inks, packaging. The Commission, therefore, considers that production and consumption efficiency would be promoted by a

uniform tariff rate. The Commission recommends that all goods falling within tariff item 9 8 .0 8 , including ink-pads, be dutiable at 20 per cent. This would provide nominal assistance roughly equivalent to that available on average to manufacturing but will still provide effective assistance

which is higher than that available to manufacturing industry in general.

The recommendation entails the reduction of protection to the production of ribbons made of textile material (from 32 per cent to 20 per cent) but the retention of about the existing assistance on other ribbons. As the local industry is currently undergoing a period of restructuring, the Commission recommends that the rates applying to ribbons made of textile material be phased down to 20 per cent in two steps. The Commission recommends that a duty of 25 per cent apply on implementation of the report to those goods, and that the rate be reduced to 20 per cent after one year.

The effects of these recommendations are difficult to assess. Clearly, producers of textile material ribbons would be subject to increased competitive pressure. However, as stated above, the level of activity and employment in the industry has been affected, and will continue to be affected, by a number of factors other than tariffs, particularly

technological changes in the types of equipment using ribbons. The industry stated that these developments had the potential to greatly alter the structure of the industry and the type of product currently made. Local producers have recently made or are in the process of making certain

rationalisations and investments which have led to increased sales of ribbons. As the major producer, Columbia, has experienced significant growth in the area of film ribbons which are already dutiable at 21 per cent, there is no reason to believe that production of all types of

ribbons would not be viable at a rate of 20 per cent.

The developing country rate for tariff item 98.08 is currently 10 per cent, providing a margin of preference of 20 percentage points for some goods under reference and about 10 percentage points for others. Generally, the Commission is requested to maintain margins of preference to developing

countries unless imports from these sources are causing or threatening to

35

cause injury to local producers. As imports from developing countries under tariff item 98.08 are minimal, the Commission suggests that minimum rates apply to all such imports.

In relation to imports from New Zealand the Commission generally is required to suggest the lowest rate consistent with both the protection of Australian industries and with reasonable competition between Australian and New Zealand products. The Commission is also required to maintain a margin of preference which as a minimum shall be the lowest of 1 5 per cent or the margins operative at 31.1.73 or 30.11.77. Imports of goods under

tariff item 98.08 from New Zealand are dutiable at rates ranging from 6 per cent to 9 per cent. Having regard to the objective of tariff simplification, the Commission suggests that a uniform rate of 5 per cent apply to goods falling within tariff item 98.08. This would provide a margin of preference of 1 5 percentage points for all goods of New Zealand

origin.

The Commission suggests that ribbons of Papua New Guinea origin be dutiable at minimum rates. As ribbons under reference are not of significant trade interest to Canada, the Commission suggests that ribbons of Canadian origin be dutiable at the applicable recommended General rates.

Brother requested duty free entry of certain types of cassette ribbons for portable typewriters on the grounds that these ribbons could not be economically produced in Australia and that any reduction in the price of these cassettes would not affect the demand for portable cassette

typewriters which are considerably more expensive than the spool models. However, the Commission considers that all typewriters are substitutable to some degree and any factor which would make one model relatively cheaper to maintain than another could influence the purchasing decisions of

consumers. The Commission considers there is no reason why users of cassette ribbons for typewriters should be exempted from a tax which applies to all other types of ribbons.

The Commission did not receive any evidence on goods falling within tariff items 98.07 and 98.09, although the Commission understands that there is local manufacture of stamps and marking devices. Existing duties on goods falling within these tariff items are 13 per cent on tariff item 9 8 .0 7 and 17 per cent on tariff item 98.09· As most of the imports under these

tariff items already enter under by-law (2 per cent) the Commission recommends that these goods be dutiable at minimum rates.

36

6 . REPORTING REQUIREMENTS 6 .1 Section 23A Requirements

Section 23A of the Industries Assistance Commission Act requires the Commission to report on the following matters:

a The level of assistance required to ensure that the level of activity and employment in the industry or group or groups of industries to which the report relates is not less than that which existed at the time when the reference was made (in this case, 8 June 1979)·

b Reasons for not recommending assistance that would ensure that the level of industry activity and employment is not less than that at 8 June 1979·

The level of activity and employment in any industry is determined not only by the level of assistance but by factors such as changes in demand for products, changes in productivity and technology, marketing techniques etc.

However, with regard to the industry producing writing implements under reference, the Commission anticipates that activity and employment would be maintained under its recommendations. The Commission considers that activity and employment in the production of ribbons and other marking

equipment would be maintained under existing rates of duty. In view of the growth in sales of Australian produced ribbons in the past two years, and the expected continuing growth in the market, it is likely that activity and employment would be maintained under lower levels of assistance. There

could, however, be some increase in the competitive pressure on textile ribbons under the Commission's recommendations.

The reasons for the Commission's recommendations are set out in Sections 4.3 and 5-3.

c Whether, in the view of the Commission, the structure of the industry or of the group or groups of industries can be improved and, if so, the manner in which, and the measures by which, the improvements can be achieved and

the consequences of such improvements.

The Commission received only very limited evidence on the structure of the industries under reference and is not in a position to make any positive comments on these aspects. With regard to the industry producing writing implements the major part of production appears to be efficient and economic and the recommendations are designed to promote a concentration of activity in these areas. There appears to be some excess capacity within

the industry producing ribbons for office machinery and the implementation of the recommendations could lead to some rationalisation in this area.

d The probable economic and social consequences of the Commission's recommendations and the employment consequences both generally and in particular regions.

These are discussed, where information is available, in various sections of the report. In summary, the Commission expects no significant adverse effects to result from the implementation of its recommendations. In a few areas under reference, some contraction in activity and employment may take

37

place. However, the Commission anticipates that there could be an expansion of activities in other areas under review. Moore believed that it would have to discontinue manufacture of ribbons in Australia if assistance were reduced. This would affect eight people who are employed by the company in Wodonga. The Commission is not aware of any other regional consequences which could arise from implementation of its recommendations.

6 .2 Tariff Simplification

Implementation of the Commission's recommendations would allow a significant simplification of the Customs Tariff. The Commission has recommended a uniform rate of duty for all pens and pencils, ribbons for office machinery and ink-pads. Minimum rates have been recommended for all

the remaining goods under reference. The recommendations therefore permit the amalgamation of several tariff sub-items. Such amalgamation would not be possible for tariff item 9 8 .0 8 until after one year from implementation of the recommendations.

38

7. RECOMMENDATIONS

The Industries Assistance Commission recommends that goods under reference be dutiable as follows:

Goods falling within tariff item Rate

98.04 )

9 8 .0 5 .2 ) 98.05.9 ) Minimum

98.07 )

98.09 )

98.05 )

98.05.1 ) 20%

ex 9 8 .08.1 - ink pads)

98.08.9 )

ex 9 8 .08.1 - typewriter and similar On implementation 25/

ribbons of textile material After one year 2 0$

Attention is drawn to the Commission's suggestions and comments relating to:

. rates of duty for goods of developing country, New Zealand, Papua New Guinea and Canadian origin;

. by-law; and

. tariff simplification.

R.G. MAULDON Commissioner

J.W. CAHILL Associate Commissioner

CANBERRA, AUSTRALIAN CAPITAL TERRITORY 15 DECEMBER 1981

39

TERMS OF REFERENCE

APPENDIX A

MISCELLANEOUS MANUFACTURING

INDUSTRIES ASSISTANCE COMMISSION ACT 1973

I, WALLACE CLYDE FIFE, Minister for Business and Consumer Affairs, hereby:

(1) in pursuance of my powers under Section 23(1) of the Industries Assistance Commission Act 1973, refer the following matter to the Industries Assistance Commission for inquiry and report by 31 December 1981:

whether assistance should be provided to the industry concerned with the production in Australia of goods of a kind falling within the following items or parts of items in Schedule 1 to the Customs Tariff Act 1966, as proposed to be altered:

(a) candles and other goods falling within item 34.06; (b) matches, pyrotechnics, and other goods falling within an item in Chapter 36;

(c) plaiting materials and other goods falling within item 46.02; (d) basketwork, wickerwork and other articles falling within item 46.03; (e) walking sticks and the like and parts therefor falling

within items 6 6 .0 2 and 66.03-2; (f) prepared feathers, down, human hair, and articles thereof falling within an item of chapter 67, other than item 67.01.1; (g) articles of stone, of plaster, of cement, of mica and of

similar materials, falling within an item of Chapter 68 (other than items 68.09, 68.13 or 68.14.1); (h) ceramic products falling within an item of Chapter 69 (other than items 69.07, 6 9 .0 8 , 6 9 .11 or 69-12); (i) insulated electric wire, cable, bars, strip and the like,

fitted with connectors, falling within item 8 5 .2 3 -2 ; (j) transport containers falling within item 86.08; (k) ammunition and parts therefor, falling within items 93.07.1, 93.07.2 or 93.07.3; (l) hand sieves and hand riddles falling within item 96.06; (m) dolls, other toys and working models falling within items

9 7 .0 2 or 97.03; (n) fairground amusements and other goods falling within item 97.08; (0 ) buttons and button moulds, studs and other goods falling

within item 9 8 .0 1 ; (p) slide fasteners and parts therefor falling within item 98.02; (q) writing equipment, sealing wax and other goods falling

within items 98.03, 98.04, 98.05, 98.07, 9 8 .0 8 or 98.09; (r) combs, hair slides and the like falling within item 98.12;

(s) tailors dummies and other lay figures falling within item 9 8 .1 6 ; or (t) paintings, drawings and pastels falling within item 99.01

and, if so, the nature and extent of such assistance.

(2) specify that the Commission be free to take evidence and, where necessary, to make recommendations on any matters relevant to its inquiry under the reference.

MINISTER FOR BUSINESS AND CONSUMER AFFAIRS

8 June 1979

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APPENDIX B

TARIFF PROVISIONS Goods under reference the produce or mmanufacture of Hew Zealand are free of duty except where indicated in the NEW ZEALAND RATE SCHEDULE.

CUSTOMS TARIFF

Rates of Duty

Item Goods General Preferential

98.03 FOUNTAIN PENS, STYLOGRAPH PENS AND PENCILS (INCLUDING BALL POINT PENS AND PENCILS) AND OTHER PENS, PEN­ HOLDERS AND SIMILAR HOLDERS, PROPELLING PENCILS AND SLIDING PENCILS; PARTS AND FITTINGS THERE­ FOR NOT FALLING WITHIN 98.04 OR 98.05:

98.03.1 - Pen and pencil sets for school use 22.5% 22.5%

DC: 10% PNG: Free

CAN: 7.5%

98.03.2 - Goods, as follows: (a) fountain pens in fancy boxes; (b) pen and pencil sets, NSA; (c) propelling pencils and sliding

pencils other than clutch pencils of a kind used by draftsmen, architects or engineers, including parts and

fittings of a kind used solely or principally therewith

30%

DC: 10%

17%

PNG: Free

98.03.3 - Ball point pens and ball point pencils, complete 17%, or, if higher,

$0.15 per doz

DC: Free

9%; or, if higher, $0.15 per doz, less 7.5% of V PNG: Free

98.03.4 - Goods, as follows: (a) assembled refills; (b) ball point pens and ball point pencils, without the refill

17%, or, if higher, $0.08 per doz

DC: Free

9%; or, if higher, $0.08 per doz, less 7-5% of V

PNG: Free

42

TARIFF PROVISIONS (Cont'd)

CUSTOMS TARIFF

Rates of Duty

Item Goods General Preferential

98.03.5 - Parts and fittings of a kind used solely or principally with ball * point pens or ball point pencils, NSA

17?

DC: Free

9%

PNG: Free

98.03.9 - Other 10% Free, and

2%

PNG: Free

DC: Free CAN: Free

98.04 PEN NIBS AND NIB POINTS Free,

and 2%

Free, and 2%

DC: Free PNG: Free

98.05 PENCILS (OTHER THAN PENCILS FALLING WITHIN 98.03), PENCIL LEADS, SLATE PENCILS, CRAYONS AND PASTELS, DRAWING CHARCOALS AND WRITING AND DRAWING CHALKS;

TAILORS' AND BILLIARDS CHALKS:

98.05.1 - Pencils other than slate pencils 19% DC: Free

11%

PNG: Free

98.05.2 - Pencil leads 6% Free,

and 2%

PNG: Free

DC: Free CAN: Free

98.05.9 - Other Free,

and 2%

Free, and 2%

DC: Free PNG: Free

98.07 DATE, SEALING OR NUMBERING STAMPS, AND THE LIKE (INCLUDING DEVICES FOR PRINTING OR EMBOSSING LABELS),

13%

DC: Free

13%

PNG: Free

DESIGNED FOR OPERATING IN THE HAND; HAND-OPERATED COMPOSING STICKS AND HAND PRINTING SETS INCORPORATING SUCH COMPOSING STICKS

43

TARIFF PROVISIONS (Cont'd)

CUSTOMS TARIFF

Rates of Duty

Item Goods General Preferential

9 8 .0 8 TYPEWRITER AND SIMILAR RIBBONS, WHETHER OR NOT ON SPOOLS; INK- PADS, WITH OR WITHOUT BOXES:

9 8 .08 .1 - Goods, as follows: 32% 15%

(a) ink-pads; (b) typewriter and similar DC: 10% PNG: Free

ribbons of textile material

98.08.9 - Other 21% 13%

DC: 10% PNG: Free

98.09 SEALING WAX (INCLUDING BOTTLE-SEALING WAX) IN STICKS, CAKES OR SIMILAR FORMS; COPYING PASTES WITH A BASIS

17% 17%

OF GELATIN, WHETHER OR NOT ON A PAPER OR TEXTILE BACKING DC: 10% PNG: Free

TARIFF PROVISIONS Cont'd NEW ZEALAND RATE SCHEDULE

Item Goods N.Z.Rate

98.03.1 All goods 2.5%

9 8 .0 3 .2 Goods, as follows: Free

(a) fountain pens (b) propelling or in fancy boxes; sliding pencils

Remainder 12.5%

98.03.3 All goods 2%; or, if higher,

$0.15 per doz, less 15% of V

98.03.4 All goods 2%; or, if higher,

$0.08 per doz, less 15% of V

98.03.5 All goods 2%

9 8 .08.1 Ink pads 1%

Remainder 9%

98.08.9 All goods 6%

98.09 All goods 2%

TARIFF PROVISIONS Cont'd

CONSOLIDATED BY-LAW REFERENCES

Tariff By-law

Reference Description of Goods Provision

98.03 Nibs, (so called) of a kind used in the manufacture 19

of porous tip pens

98.03 Parts and fittings, other than ink cartridges, for 19

use in the manufacture or repair of fountain pens or propelling pencils, under security

98.03 Pencils, clutch, having a lead enclosed in a 19

retractable sliding sleeve and held by a three dog collet chuck, of a kind used by architects, draftsman, engineers and the like

98.03 Pen kits, liquid ink, spring controlled ink flow, 19

travel adjustable, non rotating solenoid driven, of a kind used in electromechanical plotters

98.03

Pens: Lettering, pens, of a kind used for lettering on 19 plans, maps and the like

98.03 Lithographic film opaquing pens 19

98.03 Points, ball pen, being an assembly consisting of a 19

housing and a stainless steel or tungsten carbide ball, of a kind used in the manufacture of refills for ball point pens

98.03 Reservoirs, ink porous, of a kind used in the 19

manufacture of porous tip pens

98.04 Goods to which 98.04 applies 19

98.05 Crayons or pencils, temperature indicating, being 19 coloured sticks similar to crayons, the marks of which change colour at specified temperatures

98.05 Goods to which 98.05.200 applies 19

98.07 Labelling appliances, hand operated, self serving, 19 for the printing or embossing of plastic or metal tape or strip and the like. For the purpose of this by-law, if the tape or strip moves forward itself after the printing or embossing of a character ready for the printing or embossing of the next character, the appliance is to be regarded as self serving. An appliance does not necessarily have to contain a reservoir of tape to be regarded as self serving

98.07 Pricers, hand held, of a kind used to print and 19

apply pressure adhesive price tags

TARIFF PROVISIONS Cont'd

CONSOLIDATED BY-LAW REFERENCES Cont’d

Tariff Reference Description of Goods

By-law Provision

98.07 Seal making machines, designed to impress a circular common seal on documents 19

98.07 Seals, of a kind used for making impressions on hot wax 19

98.07 Stamps, self inking, number and/or letter 19

9 8 .0 8 Ink pads for self inking stamp machines 19

98.08 Inkers or inked rolls, of a kind used for re-inking ribbons on accounting machines, cash registers, terminals or proof systems

19

9 8 .0 8 Ink rolls, of a kind used on data printers

Ribbons:

19

9 8 .0 8 Carbon ribbons, having a metal strip attached to the entire length of one edge, of a kind used with electronic accounting machines

19

9 8 .0 8 Recording, of a kind used with roll chart type

temperature recorders

19

98.09 Fingerprint lifters, comprising a central laminar of a mixture of glycerol and gelatin supported on a film of nitro cellulose and protected by a film of cellulose acetate

19

9 8 .0 8 Sealing wax 19

NOTE: Goods admissable under by-law item 19 are dutiable at 2%.

47

APPENDIX C

WITNESSES, REQUESTS AND SUGGESTIONS, ABBREVIATIONS

Organisation, name of witness Summary of Relevant Abbreviation

and capacity in which appearing requests and suggestions tariff item used

Australian Paper Manufacturers Ltd 4 South Gate SOUTH MELBOURNE VIC 3205

Howard William Hutton manager tariff and trade

Biro Bic (Australia) Pty Ltd Popes Road KETSBOROUGH VIC 3178

Kenneth Hugh McGregor non executive chairman and advisor David Massey

company secretary

Box ton and Carr Pty Ltd 204 Edinburgh Road CASTLECRAG NSW 2068

John Arthur Ellis consultant and managing director John A Ellis & Associates 141 A Burns Road TURRAMURRA NSW 2074

The Commission recognise that a significant reduction in existing protective rates would have a chain reaction affecting both APM and Australian manufacturers of paper and paperboard packaging.

Ball pens should be dutiable at 250 per dozen

All developing country preferences should be removed.

Supports the requests of the Australian manufacturers of ball point and fibre tip pens for tariff increases.

Various

98.03.3

98.03.3 98.03.4 98.03.5 98.03.9

A PM

Biro Bic

Boxton and Carr

Organisation, name of witness and capacity in which appearing Summary of requests and suggestions

Relevant tariff item Abbreviation used

Brother Industries (Australia) Pty Limited 49 Herbert Street ARTARMON NSW 2064

Robert Inman Wilson director John Arthur Ellis consultant and managing director

John A Ellis & Associates 141 A Burns Road TURRAMURRA NSW 2074

GJ Coles & Coy Limited 236 Bourke Street MELBOURNE VIC 3000

There should be duty free admission for all cassette ribbons to a width of 14-3 mm falling under the following tariff items:

Fabric ribbons

Fabric and carbon ribbons )

Carbon ribbons. )

The following goods should not be dutiable but if duty is found to be necessary it should be no more than 15$:

Barry Weston customs and tariff manager

Ball point pens Markers Pencils

9 8 . 0 8 .1

98.08.9

98.03.3 98.03-9 98.05.1

The duty on crayons and pastels should be unchanged 98.05*9

Quotas should not be implemented on any products under reference.

Department of Business and No specific request.

Consumer Affairs Edmund Barton Building CANBERRA ACT 2600

Brother

Coles

Harold Edward Dunner senior inspector appraisements

Organisation, name of witness and capacity in which appearing Summary of requests and suggestions

Relevant tariff item Abbreviation used

Dow Chemical (Australia) Limited 100 Miller Street NORTH SYDNEY NSW 2060

John Arthur Ellis consultant and managing director John A Ellis & Associates 141A Burns Road TURRAMURRA NSW 2074

Supports the levels of protection requested by local manufacturers of ball point and fibre tip pens.

98.03.3 98.03.4 98.03.5

98.03.9

Faber-Castell (Australia) Pty Ltd 25/31 Pavesi Street GUILDFORD NSW 2161

David Allan Elias managing director Franz Widenbauer technical director John Arthur Ellis

consultant and managing director John A Ellis & Associates 141A Burns Road TURRAMURRA NSW 2074

The duty should be unchanged on goods falling within tariff items 98.03.1 and 98.03.2

Ball point pens and ball point pencils complete, should be dutiable at a common rate for General, Preferential and Developing Country rates, ie 20%, or, if higher, 150 per dozen

Assembled refills and ball point pens and ball point pencils, without the refill should be dutiable at a General and Preferential rate of 20%>, or if higher, 8 φ per dozen. The Developing Country and New Zealand rate should be Free

98.03.1 98.03.2

98.03.3

98.03.4

Parts and fittings of a kind used solely or 98.03-5

principally with ball point pens or ball point pencils, NSA should be dutiable at 11% General, 3% Preferential, with Developing Countries and New Zealand Free

Other fibre pens, fine line holders and clutch 98.03.9 pencils should be dutiable at 20% from all sources (except Papua New Guinea - Free)

Dow Chemical

Faber-Castell

Organisation, name of witness and capacity in which appearing Summary of requests and suggestions

Relevant tariff item Abbreviation used

Faber-Castell (Australia) Pty Ltd (Cont'd)

Gillette (Australia) Pty Limited 504-520 Princes Highway NOBLE PARK VIC 3174

Pencil leads should be dutiable at a General and Preferential rate of Free and 2%

At the draft report hearing, Faber-Castell requested that: Ball point pens from General and Developing Country sources be dutiable at 20% or, if

higher, 25 cents per dozen. The New Zealand rate should be 5%

Other fibre pens, fine line holders, clutch pencils and wood encased pencils should be dutiable at 20% General, 5% Developing Country and New Zealand

Pencils from Brazil should be dutiable at the Developing Country rate and imports of porous tip pens from Taiwan should be dutiable at the General rate.

Ball point pens and ball point pencils complete having a value for duty exceeding 20(4 should be duty free

Clive Anthony Hooke finance director Peter Buckley manager of government relations

Ball point pens and ball point pencils complete having a value for duty of less than 200 should be dutiable at 15% reducing to free over three years

Assembled refills should be 15%

Ball point pens and ball point pencils without refills having a vfd exceeding 200 should be free

98.05.2

98.03-3

98.03-9 98.05-1

98.03-3

98.03.4

Gillette

Organisation, name of witness and capacity in which appearing Summary of requests and suggestions

Relevant tariff item Abbreviation used

Gillette (Australia) Pty Ltd Ball point pens and ball point pencils without

(Cont'd) refills having a vfd less than 20(2 should be

dutiable at a rate of 15$ reducing to free over three years

Parts and fittings etc. should be dutiable at 15$ 98.03*5 reducing to free over three years

Goods falling to item 98.03.9 and having a vfd 98.03.9

exceeding 20 cents should be Free. Those goods having a vfd less than 20 cents should be dutiable at 10$ reducing to free over two years

At the draft report hearing the company requested that: Ball point pens, ball point pen refills and porous 98.03 point pens having a value for duty not exceeding

50 cents be dutiable at 20$

Ball point pens, ball point pen refills and porous point pens having a value for duty exceeding 50 cents be dutiable at minimum rates

Imports from developing countries be 5$·

Moore Business Systems Australia Limited The Boulevard RICHMOND VIC 3121

Computer ribbons should be dutiable at 40$ General rate, 20$ New Zealand and Developing Country rate and Papua New Guinea duty free.

98.08.1 Stat. Code 4X

Moore

Terry Wayne Lee regional manager - costs and planning

Organisation, name of witness and capacity in which appearing Summary of requests and suggestions

Relevant tariff item Abbreviation used

Mylex Corporation Limited Box 846J GPO MELBOURNE VIC 3001

John Arthur Ellis consultant and managing director John A Ellis & Associates 141A B u m s Road TURRAMURRA NSW 2068

Parker Pen (Australia) Pty Ltd 159 Cleveland Street, CHIPPENDALE NSW 2008

Michael John Woods general manager

Staedtler (Pacific) Pty Ltd 1 Inman Road DEE WHY NSW 2099

Alfred Thomas Bailey managing director

The Pencil Manufacturers' Group comprising:

Staedtler (Pacific) Pty Ltd 1 Inman Road DEE WHY NSW 2099

Duties should be set at a level sufficient to maintain viable operation.

At the draft report hearing, Parker requested a duty of 20% on all pens and pencils, the maintenance of existing by-laws for parts and fittings not produced in Australia and a duty of 20% for other parts and fittings not

covered under by-law.

Ball point pens and fibretip pens be dutiable at 25% General

At the draft report hearing, Staedtler opposed the cancellation of by-laws covering parts used in the local production of ball point and fibre tip pens and markers.

Pencils should be dutiable at 25% (ad valorem) General

The Developing Country rate should be removed from Brazil and imports from there be dutiable at 25% (ad valorem)

98.03 98.04 98.05

98.03.3 98.03.9

98.05.1

Nylex

Staedtler

Organisation, name of witness and capacity in which appearing Summary of requests and suggestions

Relevant tariff item Abbreviation used

The Pencil Manufacturers' Group (Cont1 d)

Columbia Products Limited 706 Mowbray Road West LANE COVE NSW 2066

Alfred John Bailey managing director Staedtler (Pacific) Pty Ltd

Andrew Gabriel Kaldor managing director Columbia Products Limited

The Ribbon Manufacturers' Group comprising:

The Commission should give consideration to the removal of current substantive rates of duty applicable to imports of Californian incense cedar slats and lead slips falling to tariff sub­ items 44.14.9 and 9 8 .0 5 .2 respectively, and their replacement with the substantive rates of "Free plus 2%" (ad valorem)

(The Commission notes that item 44.14.9 is not under reference).

Office machinery ribbon should be dutiable at a long term rate of 30% General

Columbia Products Limited 706 Mowbray Road West LANE COVE NSW 2066

Karbonkraft Division Bowater Paper Group 4-10 Hannon Street BOTANY NSW 2019

Carmassey Pty Ltd 503 Gardners Road MASCOT NSW 2020

If 30% is unacceptable as a long term rate, then ribbons falling to these sub-items should be dutiable at 30% for 2 years from the date of implementation then phasing to a General rate of 25% (ad valorem)

Woven piece goods, used in the manufacture of inked fabric ribbons and currently falling to 58.05.3 should be free of duty at the General rate

44.14.9 98.05.2

9 8 . 08.1 98.08.9

58.05.3

Organisation, name of witness and capacity in which appearing Summary of requests and suggestions

Relevant tariff item Abbreviation used

The Ribbon Manufacturers' Group (Cont'd)

Andrew Gabriel Kaldor managing director Columbia Products Limited

Wolfgang Koblitz manager Karbondraft Division

Keith William Harrison manager Carmassey Pty Ltd

Polyethelene/polyester film used in the manufacture of coated film ribbons and falling to 39.02.69 should be free of duty at the General rate

(The Commission notes that tariff items 58.05-3 and 39-02.69 are not under reference)

At the draft report hearing, the group requested that office machinery ribbon be dutiable at a long term rate of 25$ General.

9 8 .08.1 98.08.9

1979-80

Value

FOUNTAIN PENS, etc. cont'd - Goods, etc. cont'd 41 Parts

Sweden USA Other

TOTAL

OTHER

TOTAL

IMPORTS CLEARED FOR HOME CONSUMPTION

Tariff I tern Description

Country of

Customs Tariff History____

Tariff I tern and Operative Da te

TOTAL 51 057 31 153 44 538 194 985 145 034

347 853 87 010 82 966 82 143 537 815 472 136 627 325

10 794 141 795 843 550 416 428

5

3 646

3 653 466

566 278 333 76 241 350 626

1 14 196 257

572 192 490 512 041 872 571 144 470

110

98.03.3-14 From 1-7-76

348 972 636 8 906

TOTAL

130

9 232 40 124 1 571

2 59

3 734 23 879 3 281

889 52

3 481 36 940 3 176

245

186 708 6 655

pencils, complete 259 951

Germany FR 59 010

Hone Kong 115 273

155 820

Japan 105 946

NZ 352 303

Philippines 10 750 Taiwan 122 706

UK 156 679

USA 322 041

Other 152 454

1

By-law 182

2 679 133 2 420 359 4 580 152

Japan Sweden

USA Other By-1 aw

24 298

20 195 1 189 10 722 445 347 266 392

2 100

770 243

26 014

31 071 3 831 21 702 693 292

53 049 11 984

840 943

98.03.4-1X From 1-7-76

181

17 669 69

1 87 5 775 1 631

187 500

209 700

607 511

98.03.4-20 From 1-7-76

42 357 45 484 4 311

Quantity Value

SA fob

Quantity

SAfob

Quantity Value

$A fob

Quantity Value $A fob

98.03 98.03.2

Normal

98.03.3 Ball point pens and ball point 14

1 813 116

226 618 145 127 129 706

174 415 212 193 209 302 5 334

36 113 165 033 311 761 159 606

281

3 841

320 557 132 449 133 159 167 283 611 887 200 782

4 496 130 296 96 809 694 339

185 721

263 685 80 519 99 838

110 692 429 938 309 627 10 37 3

127 939 41 361 534 247 411 892

2

246

435 776 278 027 172 229 126 799 841 699

208 101 5 054 131 532 113 332 937 197 274 517

691

7 471

466 428 212 334 214 438 62 447 000 583

315 970 64

148 794 191 378 7 20 231 246 394

1 091

98.03.4 Goods, as follows: (a) assembled refills; (h) ball point pens and ball point pencils, ASSEMBLED REFILLS Germany

Ire land

Germany FR

36 968 701

22 337 420 5 29 3 211 210

23 229

300 158

30 164 6 981 44 255 1 086

8 801 204 082 7 895

303 264

57 561 1 150 21 094 1 122

3 692 387 258 29 391

501 268

593

4 842 42 118 3 131 12 227 488 708

22 978

618 597 589 606

50 417 36 200 34 405 19 951

320 776 56 364 88 995 177 642 318 505 307 939

9 572 265 867 39 444 436 766 245 571

283 229 58 492 89 371 63 778 470 991 443 602

27

26 185 79 416 381 383 390 960

Denmark Germany FR Japan Sweden UK USA Other By-law

without the 35 141 2 141 12 166

1 752 62 473 228 146 39 143

refill 25 004 8 164 18 899

4 771 25 235 175 206 14 388

380 962 271 667

26 629 852 4 662 392 203

122 635 204

32 598

50 888 2 747 11 781 541 097

24 584 5 464

20 848 4 513 1 716 1 16 745

10 260 6 115 6 226 1 10 883

2 519

196

600

20 849 56

2

8 132 26 834

287

1 925 10 218 613

169

15 366 24 665

20 833

566 396

4 529

21

3 105

1 835 11 513 8 641

769 519

9 430

133

61 188 38

8 390 719

6 473

Tariff Item and Operative Date

98.01, 1-59 From 1-1-80 NR: Prior to 1-1-80 recorded under code 26

98.08.I-6X From 1-1-80 NB: From 1-7-77 to 31-12-79 recorded under code 37. Prior to 1-7-77 NSR included

in code 15

98.08.1-70 From 1-1-80 NB: From 1-7-77 to 31-12-79 recorded under code 68.

Prior to 1-7-77 NSR included in code 15

98.08.1-15 1-7-76 to 30-6-77

NB: From 1-7-77 NSR see 98.08.1 codes 37 and 68