Ezel / Tax Rulings / CA

Was Hylage forage saver exempt when added to qualifying animal feed?

Short answer Yes. California treated Hylage as an exempt feed additive when used to preserve and enhance otherwise exempt animal feed.
State
CA
Ruling
Annotation 110.0820
Tax type
Sales and Use Tax
Issued
1968-04-17
Issued by
California State Board of Equalization
Requested by
A Board district audit office asking about the tax treatment of Hylage forage saver
Topics
silage feed additives preservatives cattle feed exemptions
Source
View Original PDF

Apply this to your situation

This page answers the general question as of 1968. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1968
Subsequent statutory amendments, regulation changes, court decisions, or later rulings may have changed the analysis. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, rate, or position mentioned here.
Disclaimer: This is an internal California State Board of Equalization legal memorandum dated April 17, 1968, published by CDTFA as support for a sales and use tax annotation. Its conclusion depends on the described formulation and use of Hylage as an additive to otherwise exempt feed. Another taxpayer should not treat it as binding and should check current Hylage, silage, forage-saver, feed-additive, preservative, exemption, and sales-and-use-tax rules. This summary is informational only and is not legal or tax advice.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official state tax ruling. The original ruling (linked on this page as a PDF) is the authoritative source for any reliance.
View original ruling (PDF)

Plain-English summary

Hylage forage saver was exempt when sold for use as an additive to otherwise exempt animal feed. The product contained plant protein, hydroxypropionic acid, and cobalt carbonate and was added to silage and high-moisture grains to keep feed moist and fresh.

Counsel treated Hylage like other additives used to preserve feed and improve its flavor and nutritional value. The conclusion was expressly tied to use with exempt feed.

Citations and references

  • California Revenue and Taxation Code section 6358 (as cited)
  • California State Board of Equalization Ruling 47 (as cited)

Source

Original ruling text

State of California

Board of Equalization

Memorandum

To:

San Jose – Dist. Prin. Aud. (JFS)

From:

Tax Counsel (GAT)

110.0820

Date:

April 17, 1968

This is in regard to your memo of April 8 concerning “Hylage” forage saver.
It is our understanding that this product, containing plant protein, Hydroxyproprionic Acid, and
Cobalt Carbonate, is added to silage, such as alfalfa, oats, barley and high moisture grains to be
used as animal feeds. It is used as an admix and keeps the feed moist and fresh.
It appears to us that Hylage forage saver is similar to other additives which are used to preserve
feed and enhance its flavor and nutritive value. Accordingly, it is our opinion that the sale of
Hylage for use as an additive to exempt feed for animals is exempt under Section 6358 and
Ruling 47.

GAT:smk

[lb]

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