Copy of Minute of Works Committee Meeting - Held on Tuesday the 30 June 1930 - "Advertisement  Boards and Hoardings". Shanghai, June 30, 1930. Source: SMA (SMC), U1-14-3267 (1108). 

Advertisement boards and hoardings. With regard to the classification of main roads for purposes of assessment of charges in respect of advertiseemnts boards and hoardings, the Commissioner of Revenue, with the concurrence of the Public Works Department, recommends that for the present it will be sufficient if the term "main roads" in the Northern and Western Districts be allowed to cover North Szechuen Road, Broadway and East Seward Road. In realising that this classification may require revision from time to time the above recommendation is endorsed.  

Extract from Municipal Gazette. Shanghai, July 4, 1930. Source: SMA (SMC), U1-14-3267 (1109-1110) 

Municipal Notification No. 3994. Advertisement Hoardings. Notice is hereby given that te Council has authorised the issue of permits for the erection of advertisement hoardings, boards and signs, subject to certain General Conditions and Special Regulations. Information as to these General Conditions and Special Regulations may be obtained from the Public Works Department. No advertisement hoardings may be erected until such permit has first be obtained. The following fees have been approved and will be enforced from August 1, 1930 :

• Per Permit : Issue of Permit : Tls 4.00.
• Advertisement in Central and Western Districts per square foot, and all main roads : Tls; 0.30 ;
• Northern and Eastern Districts other than on main roads : Tls. 0.15.
• Electric roofs & Sky Signs all Districts: Tls. 0.30.

The above scale of fees is also applicable to hoardings round buildings in course of construction, except in cases where the hoardings projects on to a Municipal road, when an additional fee of 50 per cent will be charged.

By order, S.M. Edwards, Secretary. Council Chamber, Shanghai July 3, 1930.  

Excerpts from Minutes. Advertising Hoardings and Boards. In submitting a copy of the general and special conditions of a proposed permit for advertisements on hoardings and boards, the Deputy Secretary outlines the measures which have been taken in this connection in the past and the difficulties which have been encountered. He states that the proposed rules have been framed tentatively and modified as a result of experience gained in the past two years and have evolved in close cooperation with advertisement agencies so far as hoardings that are not on Municipal properties are concerned. With regard to the fees to be imposed he has discussed this question with the Commissioners of Public Works and Revenue and the scale now submitted by the latter he recommends for approval. It is accordinly recommended that a Municipal notification be published giving effect thereto as from August next. It is noted that the main roads and districts, as to which a higher fee is proposed, will be defined by schedule for member's approval.
 
Deputy Secretary to Commissioner of Public Works. Shanghai, July 4, 1930. Source: SMA (SMC), U1-14-3267 (1111).

The new rules and regulations governing the issue of permits for advertisements hoardings and signs, together with the schedule of fees recommended, have been approved by the Council and are to come into force as from August 1. The definition of the main roads and districts as to which a higher fee is proposed was left over until the next meeting of the Council. 

"Advertising Hoardings" - Report by Commissioner of Revenue. Shanghai, July 8, 1930. Source: SMA (SMC), U1-14-3267 (1113-1114).

Advertisement Hoardings. In 1906 the question of advertising hoardings was considered and the then Engineer and Surveyor reported: "The Council cannot prevent advertising on private property, provided public rights are not infringed, but I would suggests that is should at any rate be controlled where practicable." The Council decided "that permits shall be given for the erection of those boards on temporary hoardings only, and that they shall be confined to non-residential districts". No special fees were to be charged (S/O 7 11/1/1906).

On several subsequent occasions the Council reiterated its inability to control advertisements on private property and even went so far as to contemplate blocking undesirable advertisements with fences. (Letter to Mr. John Liddell dated 22/4/1910). In 1913 the Legal Adviser gave his opinion that the Council would not be justified in adopting such a course.

In 1914 the Council decided to levy rates on advertisements and at the Ratepayers' Meeting held that year the follwoing resolution was passed: "Resolution VI. That in addition to the General Municipal Rate authorized in Revolution V, the Council be hereby authorized to impose upon the occupier of Land upon which any building carrying advertisements, advertising hoardings or station is erected a Special Rate to be assessed by the Council according to the locality at the rate of from Tls. 0.05 to Tls. 5.00 per annum per square foot of advertisement and to collect and recover the same.

Mr Ambrose challenged the Council's right to impose this tax and the Chairman replied: "I beg to inform you that we are assured by our Legal Adviser that the resolution is within the Law as laid down in Article 9 of the Land Regulations". 

It will be noted that the Resolution specifically states that the levy is to made as an additional rate upon the occupier of land carrying advertisements, etc. and it was upon the advice of the Council's Legal Adviser that this form was adopted, as be considered that the levying of a direct advertisement tax was beyond the Council's powers. As a matter of fact, it was at once found that it was impracticable to (p.2/5) collect the fees from anyone but the actual advertisers or their agents and this course has been followed up to the present time. 

In 1921, the Council's Legal Adviser stated that he did not consider the Council had any power to levy a tax on advertisements. The full text of his opinion is attached. Up to the present, although some of the advertising companies have demurred at paying the Special Advertisement Rate, the Council's right to make the levy has not been directly challenged. 

From July 1, 1927, the minimum rate was raised from Tls. 0.05 to Tls. 0.10 per square foot per annum (Municipal Gazette August 12, 1927).

From the outset the Council has maintained the principale that the Special Advertisement Rate was not to be regarded as a source of revenue, but was instituted to eliminated undesirable advertisements and to preserve the amenities of purely residential district. On the whole, these aims have been achieved, as the imposition of the maximum fee of Tls. 5 per square foot per annum has invariably proved a sufficient deterrent. The rapid development of Shanghai and the encroachment of business premises into residential districts has led to much confusion and to a certain amount of dissension and prevented the Council's ideal from being fully attained. There is little doubt, however, that without the Advertisement rate, the Streets of the Settlement would have been disfigured to a very much larger extent than they are at present. 

Intending advertisers apply to the Public Works Department for permits to carry out the structural work involved in the display of advertisements, and the following scale of permit fees are in course:

• (a) Hoardings surrounding property nad on roofs for which sketch plans are required:  Tls. 4.00
• (b) Advertisement boards fixed to walls : Tls. 1.00 (p.3/5)
• (c) Poster boards and hand boards for erection : Tls. 0.50
• (d) Placing ladders on M.C.R. For repainting and/or reposting. : Tls. 0.50. 

It was originally intended that decision as to the rate to be levied should rest with the Commissioner of Public Works, but, as a matter of fact, this duty has fallen to the Commissioner of Revenue, who receives information regarding all proposed advertisements from the P.W.D.

The actual rate levied in the vast majority of cases is the minimum one of Tls. 0.10 per square foot, but Tls. 0.50 is charged on the principal roads in the Central District and in some of the main roads in the other Districts, especially in the Western District. 

The amounts collected yearly in fees from the inception of the Rate in 1914 are as follows (cf. U1-14-3267 (1076)).

The scale of fees laid down in Notification No. 3994 dated July 3, 1930 is as follows:

• Issue of permit : Tls. 4.00 per permit.
• Advertisements in Central and Western Districts and on all main roads : Tls. 0.30 per square feet
• Northern and eastern Districts other than on main roads : Tls. 0.15
• Electric Roof and Sky Signs, all Districts: Tls. 0.30. 

The first item is the permit fee collectable by the P.W.D for structural work requiring the submission of sketch plans, the fees of Tls. 1.00 and Tls. 0.50 for minor works will still remain in force.

(p.4/5) The rate of Tls. 0.30 per square foot is that at present levied on advertisements in main roads, so that the only vital alteration is the increase of 50% on ordinary advertisements (Tls. 0.10 to Tls. 015 per square foot). It should also be noted that Tls. 0.30 per square foot is now the maximum fee and it would appear that no effort is to be made in future to restrict advertisements to business districts.

A further change is that advertisements are to be permitted on hoardings around building sites where such hoardings encroach on the Municipal Road. Prior to 1925, advertisements were permitted in such cases, but no fees were levied. In that year the Acting Commissioner of Public Works recommended that the Rate should be applied to these advertisements (Report 8/12/1925) and in 1927 the Commissioner of Revenue raised the same point (Report 23/8/1927). As the Council was averse to such a levy, the practice of allowing the display of advertisements on hoardings projecting on Municipal Roads was discontinued and this led to a certain amount of confusion, as where buildings were being set back to sceduled road lines, the advertisements could not be disallowed, for the reason that the widening did not become the Council's property until the site was cleared and the land paid for. In 1928 the whole question was reopened by the Council (S/0 1641 dated 23/5/1928) and has been under discussion ever since. 

In February 1930, Messrs. Millington, Ltd.were allowed to place advertisements on the hoardings erected around old buildings at the corner of Nanking and Kiangse Roads during demolition and as these hoardings projected on to the Municipal roadway, this was a return to the policy in force prior to 1925 (Works Minutes 21/1/30). This permission brought charges of preferential treatment from other advertising concerns and it was realized that the issue of definite rules regarding advertising was a question of some urgency. Unofficial consultations took place between the Deputy Secretary and the Acting Building (p.5/5) Surveyor, resulting in the drawing up of the general and special conditions and scale of fees which were approved at the Works Meeting held on June 6, 1930. Municipal Notificaiton No.3994 was issued on July 3, 1930.

It should be noted that no tax is levied on posters pasted to walls, although these are taxed in the French Concession. There is no doubt that there would be strong opposition to such a levy unless the Council was prepared to guarnatee immunity to advertisers from the operations of "pirates". (July 8, 1930)

Deputy Secretary to Commissioner of Public Works. Shanghai, July 17, 1930. Source: SMA (SMC), U1-14-3267 (1118-1119).

By a decision of the Council on July 9, the regulation governing advertisement hoardings and signs and the schedule of fees in respect thereof have been postponed to January 1, 1931, in ordre to allow discussion to take place in the meantime between the Council and the representatives of advertisement concerns.  

Excerpts from Minutes - Municipal Gazette. Shanghai, July 17, 1930. Source: SMA (SMC), U1-14-3267 (1121).

Excerpts from Minutes. Advertising Hoardings and Boards. The Deputy Secretary reports that so far as concerns the revised regulations governing the display of advertisements no objections have been forthcoming. Exception has however been taken to the proposed scale of fees from certain quarters on the ground that is it somewhat excessive. Although the proposed scale comes within the ambit of thoses provided for in the previous Budget, the point has been made by parties who hithterto have escaped taxation that contracts have been entered into which did not take the proposed charges into consideration. 

The Chairman's suggestion is adopted that in order not to inflict hardship in cases where contracts have been entered into the proposed scale of fees be not given effect until January 1 next. 

Letter from Millington, Limited, to Secretary. Shanghai, July 23, 1930. Source: SMA (SMC), U1-14-3267 (1122-1124).

Last night a meeting was held in our office at the request of your department, to discuss the question of the new tax and the new Regulations with regard to hoardings in the Settlement. The following suggestions were made and we have been asked to submit them to the Council for your kind consideration:

Regulations as they stand to be accepted with the following additions:

(1) Addition to No.7 - by means of ladders supplied by the Advertising Agency on any date selected by the Council for inspection (the Meeting considered that to ask a man to build a special door in a roof to allow the Council Inspector access to hoardings, when a ladder could be brought down quite easily to the site, seems to be putting the owner of the building to unncessary expense. This Regulation, of course, only applies to a Chinese house as most foreign buildings have exits on their roofs already).

(2) Addition to No. 1 Regulation. At least six months notice will be given of any change in any fee.

(3) Regarding the taxes themselves, it was the unnanimous opinion of the Meeting that the tax of Tls 0.30 per square foot should only be charged on boards placed - On the Bund, Nanking Road, Bubbling Well Road  - all other positions should have a flat rate of Tls. 0.10 per square foot per annum. This would bring the tax in line with that charged in the French Municipal Council, although the tax now charged by them will be lower that that charged by the Shanghai Municipal Council.

(4) The Meeting was definitely opposed to the addition of a 50% increase on boards in front of buildings in the course of erection where Municipal Roads are being used. It was hoped that the Council would consider the permitting of boards to be erected in front of buildings without paying any extra tax at all. The Meeting desired that the Council would grant permission to erect boards three feet in front of any existing property that was to be reconstructed, from August 1st, 1930 onwards. All Agents were most anxious that this Regulation be allowed to go into force immediately.

Agents will be prepared not to paint any hoarding that is on a Municipal Road in a main thoroughfare durin the day-time between the hours of 8.00 and 7.00. Further they were prepared to erect these hoardings during the night.

Signed : Covers Limited, Carl Crow Incorporated, Oriental Advertising Agency, ???, Millington Limited, C.F. Lin & Company. 

Commissioner Public Works to the Secretary. "Letter from Covers, Limited, and others dated 23/7/30". Shanghai, August 7, 1930. Source: SMA (SMC), U1-14-3267 (1122-1125).

Letter from Covers, Limited, and others dated 23/7/30. Ref. 1641.

I. Regulation 8. I am not in favour of the proposed addition to Regulation 8. It is very advisable that permanent access to hoardings is available. The expense to which owners will be put must naturally be met out of advertising fees. Owing to the form of construction of most Chinese houses it is important that they be not exempted.

II. I think the request that fees shall not be changed without 6 months notice is reasonable provided, however, that agreement in this does not affect new regulations and fees which may come into force as from January 1 next.

III. The question of what are main roads should be left for decision by the Council. The fee of Tls. 0.30 should not necessarily be confined to the Bund, Nanking Road and Bubbling Well Road, but consideration should be given to high rates on roads such as Avenue Edward VII, Szechuen and North Szechuen Roads, Broadway and Yangtzepoo Road and other important thoroughfares.

IV. Boards in front of building have always been a source of trouble, through faulty construction and erection. A very large number of them are erected on land vested in the Council and in such cases the fees can be considered as rental for the use of the land. As user is granted free to a building owner for his conveninence in building, he should not in such cases let it for profit. 

Deputy Secretary to Commissioner of Public Works. Shanghai, December 25, 1930. Source: SMA (SMC), U1-14-3267 (1128).

I enclose a copy of the draft provision relating to advertisements together with a draft of the proposed Muniipcla Notification in relation thereto. I shall be gload to have your final views in the matter in order to publich the Regulations in this week's gazette.  

Municipal Notification No. - Advertisement Hoardings. Shanghai, December 30, 1930. Source: SMA (SMC), U1-14-3267 (1130).

Municipal Notification No. (4044) - Advertisement Hoardings. Notice is hereby given that the Council has authorised the issue of permits for the erection of advertisement structures and Boards and the painting of advertisements subject to certain conditions. The general conditions and special regulations relating to such permits may be obtained from the Public Works Department.

No advertisement structure or board may be erected or advertisement paintings exhibited until a permit has been obtained.

The following fees have been approved and will be enforced from January 1, 1931:  

• (1) For Issue of Permit : Per Permit Taels 4.00  
• (2) Advertisement Rates :
  • Advertisements on the Bund, Nanking Road, Bubbling Well Road, Szechuen and North Szechuen Roads : Tls. 0.30 per annum ;
  • Advertisements elsewhere : Tls. 0.10 ; Electric Roof and Sky Signs : Tls 0.20
• Six calendar months' notice by publication in the Municipal Gazette will be given of any change in the above fees.

By order, J.M. McKee, Deputy Secretary. Council Chamber, Shanghai, December 30, 1930. 

(Blank) Permit Application and General Conditions - Public Works Department. Shanghai, 1930. Source: SMA (SMC), U1-14-3267 (1131-1132).

SHANGHAI MUNICIPAL COUNCIL - PUBLIC WORKS DEPARTMENT - PERMIT  

Permission is hereby given to  to …..…………………. to erect an advertising hoarding (or paint an advertisement) on roof/on ground House No………………… Road……………………Cadastral Lot…………………………………………in the …………………..District, subject to the following General Conditions and to the Special Regulations in respect of Advertisement Structures and Boards. 

GENERAL CONDITIONS

1. That during construction the road be not be occupied beyond a width of three feet. 

2. That sufficient protection be made so that the materials do not fall into the road.

3. That at least three days notice be given in writing to the Shanghai Power Company before any scaffolding or scaffold poles be erected if such scaffoldings or scaffold poles when erected will be within three feet of any electric cables, wires or fixtures.

4. No work shall be done within the hours of 10 p.m. and 6 a.m. in such a manner as to cause a nuisance or annoyance to residents in the vicinity. The Commissioner of Public Works may at his discretion require any work of erection maintenance or demolition to be done between the hour of 6 p.m. and 8 a.m. 

5. That efficient barriers and lights be placed to protect and show all openings and obstacles. 

6. That in the event of there being any accidents through defective and insufficient lighting, fencing or barriers, or warnings, or any way arising from or in respect of the issue of this permit, the applicant hereby undertake to indemnify and save the Council harmless against all claims for injuries, damage or loss sustained.

7. That all repairs to a public footpath or carriageway rendered necessary in connection with any advertisement hoarding or board carried out by the Council be at the expense of the applicant. 

8. That this permit confers no title to or right to build upon or otherwise use land not now vested in the applicant except as provided in Clause 1 and is subject to all existing rights of adjoining proprietors. 

9. That this permit does not cover any work on any structure or sign which contravenes any Municipal Regulation.

10. That all work be carried out in accordance with the deposited plans, Land Regulations Bye-laws and Rules with respect to new buildings and with the Special Regulations relating to advertisement structures and boards and that in the event of any infringement thereof or of the conditions herein the permit be liable to withdrawal and the work to be stopped by the Council forthwith. 

11. That the advertisement structure be removed at the expiry of…………..months from the date of this permit unless it is renewed, subject, however, to the Council’s right to require its removal at any time in pursuance of Clause 11 of the Special Regulations..

The fee payable for this permit is Tls………………... issued ………………………………………..19………………. Valid for 30 days. 

NOTE : Attention is directed to Bye-law No. 33 "Any person offending against of infringing any provision of this Bye-law or any condition appearing in any such permit as aforesaid shall be liable for every offense to a fine not exceeding $100 or in default of payment to imprisonment for a period not exceeding one month or to any such other penalty as shall be prescribed by the Law to which such person is amenable."

Special Regulations - With Respect to Advertisement Structures & Boards. Shanghai, 1930. Source: SMA (SMC), U1-14-3267 (1133-1135).

(1) No person shall erect any advertisement structure or board of any kind to be used for advertising purposes without a permit first obtained from the Municipal Council. All applications shall be made upon forms specially provided for the purpose, which may be obtained at the office of Public Works Department free of charge. The Council reserves to itself the right at its discretion of refusing to issue a permit in any particular case. 

(2) Every person shall at the time of making application for a permit, submit such plans and specifications, showing the locations, dimensions, materials, details of construction, and method of securing the proposed advertisement structures or boards as the Commissioner of Public Works may require.

(3) Every advertisement structure or sign shall have painted thereon or affixed thereto the name of the applicant for the permit, together with the date of such permit, which shall be in such positions and of such size as can be easily seen and read at all times. 

(4) No portion of any advertisement structure or board other than a skeleton sky sign shall be at any point more than 24 feet above the ground or 20 feet above the level of the roof immediately below such structure, and the lowest part of all such structures shall be at least 18 inches above the level of the ground or 2 feet above the parapet or level of the room immediately below such structure.  The intervening space below such structure shall be kept open or filled in only with approved lattice work. Skeleton sky signs may be of such height dependent upon the circumstances of each as may be approved by the Commissioner of Public Works.

(p.2/2) Advertisement signs erected on walls or buildings shall be exempt from the height limitations of this Regulation provided

• (a) that the signs are fixed close against the walls and
• (b) that no portion of the signs project above or beyond the walls to which they are affixed. 

(5) Should any advertisement structure or board be or become in the opinion of the Commissioner of Public Works insecure or in danger of falling, or otherwise unsafe,  the holder of the permit for such structure shall upon notice of the Commissioner of Public Works forthwith secure the same in an approved manner, and should such structure not be secured to his satisfaction the Commissioner of Public Works within the time specified in such notice he may cause such portion or portions as he may consider to be insecure or in danger of falling or otherwise unsafe, to be fortwith removed, and all fees whatsoever which may have been paid in respect with such portion or portions of such structures shall be liable to be forfeited. The omission to send or the non-receipt of such notice shall not affect the Council with any liability and the person to whom the permit is issued shall at all times be respectable for any damage resulting from such structure and shall indemnify the Council in the event of any liability it may incur by reason thereof.

(6) The Council shall have the right to order the removal of any advertisement structure or board at any time should any money payable to the Council in respect thereof not be paid on due date. 

(7) In the case of advertisement structures above the ground level such permanent access shall be provided in each case as the Council may approve except in specific cases where in the Council’s opinion satisfactory means of access and inspection already exists. 

(8) Advertisements painted on walls or roofs shall be subject to all the conditions of the permit herein in so far as the said conditions are applicable. 

(9) An advertisement structure in connection with a building site shall not at any point project over the public way to a greater distance than the projection allowed by No. 3 of the Building Rules applicable to fencing, hoardings, scaffoldings, provided that cornices to hoardings, if at a height of not less than 10 feet above the ground, may project not more than 6 inches beyond these distances. Advertisements may be allowed upon the face of gantries subject to such conditions as may be approved in each case by the Commissioner of Public Works. Save as aforesaid no portion of any advertisement structure shall project beyond the Municipal road line provided that cornices if at a height of not less than 10 feet above the ground may project not more than 6 inches beyond these distances. 

(10) The Council shall have the right to order the removal of any advertisement structure erected in connection with a building site at any time whether the same does or does not project over a public way 

• (a) should such structure not be removed with due despatch upon completion of the building, or 
• (b) should completion of the building, in the opinion of the Commissioner of Public Works, be unduly delayed.

A permit for the erection of hoardings or boards projecting over the public way shall only be issued when the building permit in connection with the site affected is granted.  

(11) Regulations 1, 2, 3, 4, 5, 7 and 8 do not apply in the case of boards or similar structures of a reasonable size advertising the names of the architect, contractor and sub-contractors. 

Extract from Municipal Gazette.  Shanghai, January 9, 1931. Source: SMA (SMC), U1-14-3267 (1136).

Municipal Notification No. 4044 - Advertisement Hoardings. Notice is hereby given that the Council has authorised the issue of permits for the erection of advertisement structures and Boards and the painting of adverisements subject to certain conditions. The general conditions and special regulations relating to such permits may be obtained from the Public Works Department. 
No advertisement structure or board may be erected or advertisement paintings exhibited until a permit has been obtained. 
The following fees have been approved and will be enforced from January 1, 1931 
(1) For Issue of Permit : Per Permit Taels 4.00 
(2) Advertisement Rates :

• Advertisements on the Bund, Nanking Road, Bubbling Well Road, Szechuen and North Szechuen Roads : Tls. 0.30 per annum ;
• Advertisements elsewhere : Tls. 0.10 ; Electric Roof and Sky Signs : Tls 0.20

Six calendar months' notice by publication in the Municipal Gazette will be given of any chage in the above fees. By order, J.M. McKee, Deputy Secretary. Council Chamber, Shanghai, December 30, 1930

Letter from the Association for Chinese Advertising Agencies to Acting Secretary. Shanghai, July 27, 1931. Source: SMA (SMC), U1-14-3267 (1137-1142).

According to your notification No. 4404 on Advertising Hoardings just received a few days ago, we are surprised to find that you have increased 100% your tax on roof signs from Tl. 0.10 per foot  per annum to Tls. 0.20 per foot annum. 

While ignorant of the real purpose for this sudden increase we wish to submit our views for your deliberation and consideration as follows: 

1. Disparity of rates between wall and roof signs: Formerly with the exception of Nanking Road, Bubbling Well Road, Szechuen Road and the Bund, the taxes on the the wall and the roof signs were the same - Tls. 0.10 per foot per annum. Now your tax on wall signs remain the same, where that on roof signs has advanced to Tls. 0.20 per foot per annum. On the whole, the advertising value of wall signs and roof sign is too way up to be seen clearly and the rate should be cheaper - decidedly not twice as high.

(p.2/4) However, if your belief is that all roof signs are better than wall signs and their value is twice as much as the wall signs, then your tax on the boards on the roofs along Nanking Road should be Tls. 0.60 per foot per annum instead of only Tl. 0.20 per foot, as your tax on Nanking Road hoardings is only Tl. 0.30 per foot.

2. Roof signs get less and cost more to construct: On the whole, the signs on the roof are larger and more difficult to construct, therefore besides the high cost of construction, the roof signs have to pay more tax per sign on account of the larger size. So we believe, the Shanghai Municipal Council is already receiving increased revenue from their larger size without necessarily resorting to increase of tax on roof signs. 

3. Chinese advertising agents hard hit by this increase: As most of the roof signs are owned by the Chinese advertising agents, and the Chinese signs are renting out at a much lower price than the foreign (p.3/4) agents, we feel that the increase of 100% on roof signs will work great hardship on us alone and your office will bear the inexplainable blame of deliberate discrimination against the Chinese.

We do believe this can possibly be your motive behind the increase, but it certainly has the undesirable effect and we, at our 46th meeting, have passed a resolution to bring up this matter to your attention and request your immediate rectification. 

4. Issuance of painting and construction permit: Our members also wish to inform you that the charges for painting and construction permit are too high and too numerous. Oftentimes, the erection and painting of several boards at one location cannot be carried out at the same time and the paying of Tls. 4. each time for such board is absolutely excessive.  

We believe the method used in French Concession is more flexible and reasonable, and we hope you will refer to it for reference. 

Again about the issuance of small licence plate we wish to inform you that you are now issuing one small plate to cover the entire hoarding site, which may have 10 to 40 boards. Some of them may be for 6 months and others may be for a year, and still others may start in January and others may be for a year, and still others may start in January and others may not start until December. Such general plate will not enable to tell the true story for taxing purposes. 

However, on the other hand, if you should change your present methods by issuing separate permit for each board your fees must be substantially reduced as more permits will be required and also the time for issuing such permits must be speeded up, as we have often found that foreign agents can get quicker attention than Chinese agents. 

We trust that the above will receive your careful consideration and that satisfactory revision will be made accordingly.  

Translation of letter to Council from the Advertising Merchants Association of the Municipality of Greater Shanghai. Shanghai, August 7, 1931. Source: SMA (SMC), U1-14-3267 (1144).

Advertisement Signs. With reference to the Council's notice No. 4404 regarding the increase in the tax for painting advertisement signs, this Association wrote to the Council on the subject on 20th July, 1931, but no reply has been received though a fortnight has elapsed. The Council is asked for a reply so that the members of this Association may carry out the Council's instruction. (Chopped) Advertising Merchants' Association

Report from Commissioner of Public Works to Acting Secretary - "Advertising Rates - Letter dated July 20th from the Association of Chinese Advertising Agencies - Ref 1641". Shanghai, August 10, 1931. Source: SMA (SMC), U1-14-3267 (1147-1148).

The revised scale of charge for advertisement rates was published under Municipal Notification No. 4044 on the 30th December 1930 and came into force on the 1st January 1931, since when no changes have been made. Referring to the various items enumerated, - 

(1&2) The reasons for charging a higher rate for roof signs was intended to act as somewhat of a deterrent to avoid wholesale erection of roof structure of this nature which obviously take considerable time and trouble in inspection, especially as many roof signs are provided with little or no means of access for this purpose. However, I have no objection to the Annual advertisement rates for roof signs being reduced to that for ground and wall signs, i.e. Tl. 0.10 per square foot in all localities except the Bund, Nanking Road, Bubbling Well Road, Szechuen & North Szechuen Roads, the roof signs on these roads to remain Tl. 0.20 per square foot as at present. 

(3) I am unable to comment on this paragraph as I have no data as to the proportion of roof signs owned by foreign and Chinese advertising agents, nor as to the rent charged to advertizers. Possibly the Commissioner of Revenue has information on these points. 

(4) It is unncessary for agents to pay Tl. 4 for the erection of each board on any one site. Should an application and plans for a complete hoarding be received a permit fee of Tl. 4 only is charged, and the permit can be renewed without charge to cover any reasonable period, say 3 months, so that the hoardings can be erected as a whole or in sections with the same permit during this period.

As regards repainting of advertisement hoardings, which is necessarily carried out periodically, I suggest that the various firms be invited to agree to a six-month permit fee of Tl. 0.50 for each hoarding or board oned by them respectively, a complete list of hoardings and boards to be submitted by them on the 1st of January and 1st July each year. A general permit could be issued to each firm for all hoardings to be maintained by them, as it now done for the various Neon Lights firms. The cost would be then Tl 0.50 per half year for each hoarding, and no separate permit would be required. Delay in dealing with application and issuance of permits would be avoided, and the only thing necessary would be that each firm should equip its employees with armlets approved by the Police Department. 

The question of licence plates is one that is dealt with entirely by the Revenue Office.

The suggestion that foreign firms obtain better attention than Chinese firms is, of course, incorrect, and quite without foundation. 

Report from Commissioner of Revenue to Acting Secretary - "Letter dated July 20th from the Association of Chinese Advertising Agencies". Shanghai, August 11, 1931. Source: SMA (SMC), U1-14-3267 (1150-1151). 

I consider that the main points raised by this Association merit favourable consideration. My comments and recommendation follow: Present Scale of Fees. Issue of Permit : Per Permit Tls. 4.00 ; Advertisement Rates (Per square foot) Advertisements on the Bund, Nanking Road, Bubbling Well Road, Szechuen and North Szechuen Roads : Tls. 0.30 per annum ; Advertisements elsewhere : Tls. 0.10 ; Electric, Roof and Sky Signs : Tls. 0.20. . 

1. Disparity in Fees - The present tax on Roof Signs is admittedly inconsistent and contradictory. On the Bund, Nanking, Bubbling Well, Szechuen and North Szechuen Roads, Roofs Signs pay 33% less than wall signs. Inversely, on all other roads Roof Signs are taxed double the rate of wall signs. This was not the intention when the fees were drawn up. The anomaly was created by the reduction of the Electric, Roof, and Sky Sign fee from Tl. 0.30 per square foot as originally recommended to Tls. 0.20 per square feet (p.2/2) on the Bund, Nanking Road, Bubbling Well Road, Szechuen and North Szechuen Roads, but be reduced to Tls. 0.10 per square foot elsewhere with effect from January 1, 1931. 

2. Construction Costs - This office has no knowledge of the comparaive cost of construction of Roof and Wall Signs. The argument that Roof Signs have, owing to their distance from ground, to be of larger proportion than a Wall Sign, appears to be sound.

3. Chinese Agents Mainly Affected - It is correct that the Chinese Advertising Agencies are mainly affected by the adverse Roof Sign rate. The Foreign companies, on the whole, take advantage of the favourable rate on the Bund, Nanking, Bubbling Well, Szechuen and North Szechuen Roads, but do not exploit the areas where the adverse rate applies. 

4. Permits - These questions will be dealt with by the Public Works Department, and do not call for comment by this Office.

5. Registration Plates. Before the receipt of the Association's letter, it had been decided to issue a registration plate in respect of each panel of a multiple-panel hoarding, and this is now being done.  

Reply to the Association for Chinese Advertising Agencies from Acting Secretary. Shanghai, August 17, 1931. Source: SMA (SMC), U1-14-3267 (1153-1154).

With reference to your letter of July 21 on the subject of advertisement hoardings, I am directed to inform you that the Council has no authority to make, during the current year, any changes in the Advertisement Rates which were sanctioned by the Ratepayers at the last Annual Meeting, but that sympathetic consideration will be given to the question of revising these Rates in connexion with the framing of the Tax Schedule for 1932. 

With regard to the fourth item dealt with in your letter, I am directed to state that it is uncessary for advertising agents to pay Tls. 4 for the erection of each board on any one site. When an application and plans for a complete hoardings are received a permit fee of Tls. 4 only is charged, and the permit can be extended without charge to cover any reasonsable period, say three months, so that the hoardings can be erected as a whole or in sections with the same permit during this period. 

Small fees are also levied in connection with the periodical repainting of advertisement hoardings. The Commissioner of Public Works is at present taking steps to simplify procedure and avoid delay in this respect. 

With reference to registration plates, before the receipt of your letter it had been decided to issue one for each panel of a multiple-panel hoarding, and this is now being done. 

I have finally to observe that you appear to be under a misapprehension in stating that in the issue of permits, foreign advertising agents get more prompt attention that Chinese agents. The treatment of both classes of applicants is the same. 

Extract from Municipal Gazette  - Municipal Notification No. 4255. Shanghai, June 30, 1932. Source: SMA (SMC), U1-14-3267 (1155).

With reference to Municipal Notification No. 4044 dated December 31, 1930, notice is hereby given that the following revised scale of fees has been approved and will be enforced from January 1, 1933 (See Excel Sheet). Six calendar's months notice by publication in the Municipal Gazette will be given of any change in the above fees.

By order, J.R. Jones, Secretary. Council Chamber, Shanghai, June 30, 1932. 

Extract from Municipal Gazette  - Municipal Notification No.4255 - Advertisements. Shanghai, June 30, 1932. Source: SMA (SMC), U1-14-3267 (1156).