Ezel / Tax Rulings / CT
CT Ruling 89-18 Sales and Use Taxes 1989-06-30

Did a laundry and dry-cleaning business qualify for Connecticut's manufacturing fuel exemption under Ruling 89-18?

Short answer: No. Cleaning garments did not substantially transform property into a different product with a distinctive name, nature, and use, so it was not manufacturing and the fuel exemption was unavailable. The ruling is superseded.

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This page answers the general question as of 1989. Ezel answers yours, under current Connecticut tax law, with citations.

Currency note: this ruling is from 1989
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 1989 Connecticut Department of Revenue Services Ruling is not current. The official page says it was superseded by Policy Statement 94(3), so it is provided only as historical reference and should not be used as current authority. It addressed one laundry and dry-cleaning business and the manufacturing fuel exemption under the law then in effect. Connecticut imposes sales and use tax solely at the state level: there are no local or municipal sales taxes. This summary is informational only and is not legal or tax advice. Consult a licensed Connecticut tax professional about current manufacturing and utility exemptions.
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

The laundry and dry-cleaning business did not qualify for the manufacturing fuel exemption because cleaning garments was not manufacturing.

Manufacturing required a substantial transformation into a different product with a distinctive name, nature, and use. Garment cleaning did not meet that test.

The official archive says this ruling was superseded by Policy Statement 94(3).

What this means for you

The historical ruling required substantial transformation, not merely processing or improving existing property. Its superseded status means current manufacturing and utility exemptions must be checked separately.

Common questions

Was garment cleaning manufacturing? No.

Did the business receive the fuel exemption? No.

Citations and references

  • Conn. Gen. Stat. § 12-412(3) and Public Act No. 89-251, as cited in the ruling.

Source

Original ruling text

Ruling 89-18, Utility Exemption - Manufacturing

This information is not current and is being provided for reference purposes only

Ruling 89-18

Utility Exemption - Manufacturing

This Ruling was superseded by   PS 94(3)

Effective July 1, 1989, section 12-412(3) of the Connecticut General Statutes, as amended by Public Act No. 89-251, exempts, under certain circumstances, the sales of fuel, electricity, etc. One of the establishments which falls under this exemption is an industrial manufacturing plant.

"Manufacturing" means the performance as a business of an integrated series of operations which places personal property in a form, composition or character different from that in which it was acquired for sale in the regular course of business by the manufacturer. The change in form, composition, or character must be a substantial change, and it must result in the transformation of property into a different product having a distinctive name, nature and use .

The cleaning of garments would not fall under this definition of "manufacturing." Therefore, the exemption described above is not available with respect to the fuel sales to such laundry and dry cleaning business.

LEGAL DIVISION

June 30, 1989

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