The daily morning journal and courier., 1894-10-10
RE. FRS TO HAIR OF SHEEP.
IN GIAION GIVEN ON WOOL OF
 2 TIE NEW TARIFF ACT.

Tho l es Under 2 tchedule K Upon Arh-
 cles < Se oi the Hair of Other Animals
 Went ant, Effect From the Date the Act
 Took Ehect.
 Washington. Oct. 9.-Secretary Car lisle signed this telegram this evening":
 Washington, Oct. s.-To Collector of Customs. N. Y.
 "The attorney general has rendered an opinion that the word wool as used in paragraph 2e7 of the new tariff act. refers to hair of sheep only, and that the new duties under schedule K, upon articles made of the hair of other anil mals, went Immediately into effect from the date the act took effect. Customs officers will be governed accordingly. Instructions of August 27 remain. Col lectors will reliquidate all entries cov- ering goods classified contrary to above instructions. (Signed)
 "J. G. Carlisle, Secretary"
 The opinion upon which MT. Carlisle based his telegram which decides, at least for the present, the construction of the wool schedule of the tariff reads as follows
 "The Secretary of the Treasury, Sir
 "The new rules of import duties pre- scribed by section one of the tariff act of August 26, 1894, went into effect i'm mediately unless otherwise specially provided for" Paragraphs2s7 of that act provided that "the reduction of the rates of duty herein provided for manu- lecturers of wool shall take effect Jan uary 1, 1895. That paragraph closes schedule K., of the act, whose head is wool and manufactures of wool" The schedule does not, however, deal with wool and manufactures of wool alone. It distinguishes repeatedly between wool worsted, the hair of the camel, goat, alpaca or other animals" It in- cludes also certain manufactures of flax and cotton. You ask my opinion whether paragraph 297 refers solely to merchandise of which wool the pro- duct of the sheep, forms the material, or whether the product of the camel, goat, alpaca or other animals is equally included.
 The general intent of the act is to effect an immediate as we'll as an ex- tensive reduction of duties To post pone the reduction in the case of any specific articles, the article must be brought clearly within some exception to this general intent. All doubts aris- ing under the act are presumptively to be resolved in favor of the lower rate of duty, save when the act men hens or describes the same article In two different places under two differ4 ent rates when the higher rate governs.
 "WooI'' with it's dictionary detfnition. includes the hair of the alpaca and of clude all goats hair, not yet canels' hair, COW hair or horse hair Through out schedule K, except in the heading it is undoubtedly used so as to exclude even hair of the kind first mentioned. Moreover the phrase manufactures of wool should be given very re- strictive meaning in prior tariff acts Elliott versus Swartout, 10 Vt., 137; Seeberger versus Calm, 1S7 United States 9Oand there is a presumption in the absence of anything to the con- trary that congress intended it still to have the same signification (Maddock versus Magone 152 United States 36S, 31-N.
 If the heading of schedule were in tended as an accurate and comprehen- sive description of its contents the ques- tion would arise whether the hearing or the contents should control, and 1t might be argued that hair, flax and cotton were all wool. But the heading has little significance. It is intended only for a general suggestion as to the character of the articles within the schedule (Hollender versus Magone, 149 United States, 5s6, 591; seeberger versus schlesinger, 152 United States, 5S1, 5s3.) If the rule of construction was other wise then sponges would be either Chemicals, oils or paints" and cork would be either flax, hemp or jute.'
 Moreover it Is proper to consider as an aid to construction the original form of the billl and the changes made by amendment. The bill as it first passed the house of representatives in the same paragraph with the exception above quoted concerning manufactures of wool' had further provisions as to "all rates of duty in the woolen seed ule." The latter was stricken out in the senate, but serves to show that the distinction was brought to the atten- tion of congress. .
 I am, therefore, very clearly of the opinion that the word "wool" as used in paragraph 297 refers to hair of the sheep only; and that the new duties upon articles made of the hair of other animals went immediately into effect upon the passage of the act. You also ask my opinion whether the phrase manufactures of wool in that para graph Is applicable to articles of which wool, although a component part, Is not the material of chief value. I would answer this question in the nega- tive. (Arthur versus Butterfeld, 125 United States, 70, 75; Herman versus Robertson, 152 United States, 61 524.)
 (SigneO
 LAWRENCE MAXWELL, JR.,
 Acting Attorney General.
 Brook'yn Wh1towashed BOston.