Ezel / Tax Rulings / CA

Could textile dyers buy wetting agents for resale when the agents helped fabric absorb more dye?

Short answer No on the stated facts. The agents aided dye absorption but did not enter the fabric or dye, so their sale was taxable; counsel invited contrary technical evidence.
State
CA
Ruling
Annotation 440.0460
Tax type
Sales and Use Tax
Issued
1953-05-29
Issued by
California State Board of Equalization
Requested by
A chemical seller asking about wetting agents sold to textile dyers
Topics
textiles manufacturing aid component parts additional evidence
Source
View Original PDF

Apply this to your situation

This page answers the general question as of 1953. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1953
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 a California State Board of Equalization junior-counsel letter dated May 29, 1953, published by CDTFA as support for a sales and use tax annotation. It relies on the stated understanding that the wetting agent aided dye uptake without becoming part of fabric or dye and expressly invites more complete technical information. Another taxpayer should not treat it as binding and should check current textile-dyeing, wetting-agent, absorption, component-part, manufacturing-aid, 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

A chemical seller supplied wetting agents to textile dyers. The agents enabled fabric to absorb more dye but, on the facts understood by counsel, did not themselves become incorporated into either the fabric or the dye.

Their sales were taxable retail sales because the agents functioned as manufacturing aids rather than resold components.

The letter expressly invited corrected or fuller technical information if that understanding of textile dyeing was incomplete, so the result is tied to the stated nonincorporation facts.

Citations and references

  • California Sales and Use Tax Ruling 14 (as cited)

Source

Original ruling text

440.0460

STATE OF CALIFORNIA

STATE BOARD OF EQUALIZATION

May 29, 1953

G--- A--- & F--- Corporation
XXX --- Avenue
--- --- XX, --- --Attention:

Mr. A. J. M--Tax Manager

Your letter of March 3
Account No. SZ --- XX-XXXXXX

Gentlemen:
You inquire concerning the application of sales tax to sales of wetting agents to a textile dyer. The application of the tax to property used in manufacturing is explained in Sales and Use Tax Ruling 14 (copy enclosed). We understand that the purpose of wetting agents is to enable the fabric to take up more of the day. The wetting agent itself does not become incorporated into the fabric or the dye. Under these facts, the sale of the wetting agent to the dyer is a taxable retail sale. Perhaps our understanding of the use of wetting agents in textile dyeing is incorrect or incomplete. If so, we welcome any information you wish to submit which you feel might affect the taxability of this type of transaction. Yours very truly,

Bill Holden
Junior Counsel

BH:ja
cc:

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