IA DO 912498 Sales / Use / Excise Tax 2025-07-31

Is commercial-kitchen exhaust-hood cleaning taxable in Iowa?

Short answer: No. Summit's specialized cleaning of grease and debris from commercial-kitchen exhaust hoods and fire-suppression systems did not fit any taxable service the Department analyzed. Performing it on real property did not by itself make it taxable.

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This page answers the general question as of 2025. Ezel answers yours, under current Iowa tax law, with citations.

Disclaimer: This Iowa declaratory order applies agency law to Summit Fire Protection's disclosed hood-cleaning process and has the same status and binding effect as a final contested-case order under Iowa Code § 17A.9(7). Different work—especially repair, installation, or ordinary janitorial cleaning—or later law may produce a different result. This summary is informational only and is not legal or tax advice. Consult a licensed Iowa tax professional about your situation.

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

Summit's specialized commercial-kitchen hood cleaning was not a taxable Iowa service under the facts presented.

The service removed grease and debris from exhaust hoods and fire-suppression systems to reduce fire hazards and meet fire-code standards. Summit covered kitchen equipment, pressure-washed exhaust components, replaced filters, cleaned its work area, and verified that lights and fans operated.

The Department compared that work with five taxable service categories Summit identified:

janitorial or building maintenance and cleaning;
carpentry repair and installation;
roof, shingle, and glass repair;
electrical and electronic repair and installation; and
pipe fitting and plumbing.

The described service did not fit any category. It was specialized fire-prevention cleaning rather than regular janitorial work, and it did not involve construction, repair, installation, wiring, glass, roofing, pipe fitting, or plumbing. Iowa also had no rule making a service taxable solely because it was performed on real property.

What this means for you

Hood-cleaning and fire-protection companies

Keep the scope of work clear. This result depended on cleaning grease and debris—not repairing, replacing, installing, or modifying equipment.

Restaurants and commercial kitchens

The order treated the described periodic fire-safety hood cleaning as nontaxable, but separate repair or installation charges may require a different analysis.

Tax professionals

Classify the actual tasks against Iowa's enumerated taxable services. The location of the work on real property is not enough by itself.

Common questions

Q: Was hood cleaning taxable as janitorial service?
A: No. The Department considered it specialized periodic fire-prevention work, not cleaning performed by a janitor in the regular course of duty.

Q: Did rooftop access make it roof repair?
A: No. The described work did not repair, restore, or renovate a roof or shingles.

Q: Did working around powered fans make it electrical repair?
A: No. The service did not repair or install wiring, fixtures, switches, or powered property.

Q: Does performing a service on real property automatically make it taxable?
A: No. The order found no Iowa statute or rule imposing tax solely for that reason.

Citations and references

Iowa Code § 423.2(5) — tax applies to services enumerated in § 423.2(6)
Iowa Code § 423.2(6)(k), (l), (p), (z), (an) — service categories analyzed
Iowa Administrative Code rule 701—211.23(2) — janitorial and building maintenance or cleaning
Iowa Administrative Code rule 701—219.13(6) — repair, installation, and pipe-fitting/plumbing rules cited in the order
Iowa Department of Revenue Declaratory Ruling No. 98-30-6-0026 — similar hood-cleaning ruling discussed by the Department

Source

Landing page: https://revenue.iowa.gov/resources/law-policy-information/administrative-orders
Archive document link: https://revenue.iowa.gov/media/4281/download?inline
Original PDF: https://documents.iowa.gov/home/PreviewDocument/10351994

Original ruling text

SUMMIT FIRE PROTECTION CO (DO) (2025)

Reference No. 25300009

BEFORE THE IOWA DEPARTMENT OF REVENUE
HOOVER STATE OFFICE BUILDING
DES MOINES, IOWA
IN THE MATTER OF
SUMMIT FIRE PROTECTION CO
1250 NORTHLAND DR
MENDOTA HEIGHTS MN 55120-1174

DECLARATORY ORDER
DOCKET NO. 912498

SALES/USE/EXCISE
PursuanttoaPetitionforDeclaratoryOrder(“Petition”)filedwiththeIowaDepartmentof
Revenue(“Department”)bySummitFireProtectionCo.(hereinafterreferredtoas“SummitFire
Protection” or“Petitioner”)onApril24,2025,andinaccordancewithIowaCodesection17A.9
(2025) and Iowa Administrative Code rule 701—4.7(17A), “Declaratory order-in general,” the
Director issues the following order.
I.

FACTS
The facts below are based on the Petition, accompanying letter from Petitioner, and

supplemental information submitted to the Department on May 29, 2025 in response to a
request for additional information.
Petitionerisafireprotectioncompany.Itprovidesvariousservicesandproductsrelated
tofireprotectionandsafety,includingahoodcleaningservice.Petitionerstatesthatcommercial
kitchens often have fire suppression systems in their exhaust fans. These fire suppression
systems must b
e inspected and cleaned regularly. The frequency of these inspections and
cleanings depends on the specific equipment used. Petitioner states that its hood cleaning
service is utilized to clean grease build-up from the exhaust system and fire suppression
system, which presents a fire hazard. The accumulated build-up is flammable and can be
ignited if not regularly removed.

According to thePetition,thefollowingisalistofstepsthatPetitionertypicallytakesin
this process:
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Arrive onsite and contact client personnel.
Document condition of kitchen, identify water source and grease trap drain.
Visually inspect exhaust system to verify presence of grease accumulation.
Unloadequipmentusingeitheratruckmountedoramobilepressurewasher,
ladders(foraccessingtheroof/fanifinternal/externalaccessisnotavailable),
and all necessary equipment for providing the service.
Don appropriate personal protective equipment (PPE).
Verify and document if hood lights and exhaust fans operate. Document
condition of exhaust fan, to include wiring deficiencies.
Turn off the exhaust fan at power source.
Prepare pressure washers (mix degreaser, connect to water source, etc.)
Coverappliancesandcook-prepareaswithplastic.Wraphoodwithplasticto
make funnel for water collection.
Remove filters from the hood.
Clean exhaust components until the NFPA [National Fire Protection
Association] and IFC [International Fire Code] standard is met.
Replace filters; dry hood interior; remove and dispose of plastic.
Performclean-upoftheentireworkarea,includingrooftopandparkinglot(as
needed).
Turn on power to fan unit; verify and document lights and fans work.
Document condition of kitchen upon completion.

Petitioner notes itsbeliefthatexhaustsystemsarerealpropertyandstatesinthePetitionthat
this is a service to real property.
II.

ISSUE PRESENTED
Petitionerpresentsonequestionforconsideration—whetheritshoodcleaningserviceis

ataxableserviceinIowa.InitsresponsetotheDepartment’srequestforadditionalinformation,
Petitioner provided the following five enumerated services that it believesmayencompassits
hood cleaning service:
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Carpentry Repair and Installation Iowa Code § 423.2(6)(k)
Roof, Shingle, and Glass Repair Iowa Code § 423.2(6)(l)
Electrical and Electronic Repair and Installation Iowa Code § 423.2(6)(p)
Janitorial and Building Maintenance or Cleaning Iowa Code § 423.2(6)(z)
Pipe Fitting and Plumbing Iowa Code § 423.2(6)(an).

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III.

STANDARD OF REVIEW
Iowa Code chapter 17A, the Iowa Administrative Procedure Act(“IAPA”),wasenacted

“to provide a minimum procedural code for theoperationofallstateagencieswhentheytake
action affecting the rights and duties of the public.” Iowa Code § 17A.1(2). Under the IAPA,
“[a]ny personmaypetitionanagencyforadeclaratoryorderastotheapplicabilitytospecified
circumstances of a statute, rule, or order within the primary jurisdiction of the agency.” Id. §
17A.9(1)(a). The IAPA also describes agency rights and responsibilities with respect to
declaratory order proceedings. Id. § 17A.9(8). Pursuant to Iowa Code section 17A.9(2), the
Department

adopted

Iowa

Administrative

Code

rule

701—4.7,

which

outlines

department-specific rules governing declaratory orders.
The purpose of a declaratory order is to provide a “generally available means for
persons to obtain reliable information about agency administered law as it applies to their
particular circumstances.”SierraClubIowaChapterv.IowaDep’tofTransp.,832N.W.2d636,
647 (2013) (citing Arthur Earl Bonfield, Amendments to Iowa Administrative Procedure Act,
ReportonSelectedProvisionstoIowaStateBarAssociationandIowaStateGovernment,1–8
(1998)).Declaratoryordersarenotcontestedcasesthat“entitlepartiesaffectedbytheagency
action to an adversarial hearing” in order to “adjudicate disputed facts pertaining toparticular
individuals in specific circumstances.” Greenwood Manor v. Iowa Dep’t of Pub. Health, State
Health Facilities Council, 641 N.W.2d 823, 834 (Iowa 2002); see also Iowa Code § 17A.12.
Instead, the IAPA “contemplates declaratory rulings by administrative agencies on purely
hypotheticalsetsoffacts.”CityofDesMoinesv.Pub.Emp’tRelationsBd.,275N.W.2d753,758
(Iowa 1979).
As such, “[t]he procedure established by section 17A.9 allows persons to seek formal
opinions on the effect of future transactions and arrange their affairs accordingly.” Bennett v.
Iowa Dep’t of Nat. Res., 573 N.W.2d 25, 26 (Iowa 1997). Declaratory orders issued by an
administrativeagencydo,however,have“thesamestatusandbindingeffectasanyfinalorder
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issued in a contested case proceeding.” Iowa Code § 17A.9(7). The Department’s rules
governing declaratory orders are consistent with this understanding of the role of declaratory
orders in administrative procedure. See Iowa Admin. Code r. 701—4.7.
IV.

DISCUSSION
Iowa imposes “a tax ofsixpercentuponthesalespricefromthefurnishingofservices

as defined in section 423.1.” Iowa Code § 423.2(5). This code section further states that the
“salespricesofanyofthe...enumeratedservices[listedinsubsection423.2(6)]issubjectto
the tax imposed by subsection 5.” These enumerated services includetheservicesPetitioner
requested the Department analyze.
A.

Janitorial and Building Maintenance or Cleaning

First, Petitioner requested the Department analyze whether its hood cleaning service
may be taxable as janitorial and building maintenance or cleaning. “Janitorial and building
maintenance or cleaning” islistedasataxableserviceinIowaCodesection423.2(6)(z).Iowa
Code section 423.2(6)(z) is implemented by Iowa Administrative Code rule 701—211.23.
i. Building Maintenance or Cleaning
Iowa Administrative Code rule 701—211.23(2) provides a definition for “building
maintenanceorcleaning.”Thissectionstates,“‘[b]uildingmaintenanceorcleaning’includesbut
is not limited to the cleaning of exterior walls or windows of any building and any other act
performedupontheexteriorofabuildingwiththeintenttokeepitingoodconditionorupkeep.”
Iowa Admin. Code r. 701—211.23(2).
Here,thedescriptionofthehoodcleaningservicesprovidedbyPetitionerincludeslittle
workdoneontheoutsideofthecustomer’sbuilding.Inthestepstakentoperformtheserviceat
issue, Petitioner lists the clean-up of the workarea,whichmayincludethecustomer’sroofor
parking lot. However, Petitioner indicates that this step consists of clearing debris left by
Petitioner in thecourseofprovidingtheservice,notmaintainingorcleaningtheexteriorofthe
building.Theonlycleaningserviceprovidedisclearingtheirowndebrisfromtheexteriorofthe
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building that were left in the course of the work provided. Becausenoworkontheoutsideof
customers’buildingsorcleaningoftheoutsideofthebuildingsisbeingperformedbyPetitioner
inthecourseofthedescribedservice,Petitioner’shoodcleaningservicedoesnotfallwithinthe
definition of “building maintenance or cleaning.”
ii. Janitorial Services
Iowa Administrative Code rule 701—211.23(2) also provides a definition of “janitorial
services”. The rule defines “[j]anitorial services” as follows:
“Janitorialservices”meansthetypeofcleaningservicesperformedbyajanitorin
theregularcourseofduty.Theseservicesmaybeperformedindividuallyundera
separatecontractorincludedwithinageneralcontracttoperformacombination
of such services. These services may include but are not limited to interior
window washing, floor cleaning, vacuuming, waxing, cleaning of interior walls
and woodwork, cleaning of restrooms and furnaces, and the movement of
furniture or other personal property within a building.
The rule indicates that the services that would fall under this definition are services
“performed by a janitor” and “in the regular course of duty.”Id.
Here, Petitioner provides fire prevention and safety services, including a particular
cleaning service that is performed to remove a fire hazard. Thishoodcleaningservicediffers
fromjanitorialservices,asitisnotacleaningservicedoneintheregularcourseofdutyandis
more specialized than the examples ofjanitorialworkprovidedintherule.Thepurposeofthe
cleaning that Petitioner performs in the course of this service is for fire prevention and the
operation of fire suppression systems. Thefrequencyofserviceisdescribedinthepetitionas
“periodic,”withtheservicerequiredtobeperformedbyfirecodes.Therefore,thisisnotthetype
of service that is done “by a janitor in the regular course of duty.”
Additionally, the Department has previously analyzed a similar service that involved a
business providing tangible personal property and services related to fire prevention and fire
safety.InInreRickSertle,abusinessrequestedadeterminationonthetaxabilityoftheservice
and inspection of hand held fire extinguishers, fire suppression systems, alarms, and the

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servicing and cleaning of exhaust hoods, duct and fans. Iowa Dep’t of Revenue,Dec.Ruling
No. 98-30-6-0026 (1998). The business provided “[t]he service of cleaning exhaust hoods,
ducts, and fans involves the removal of grease build-up on exhaust systems for commercial
restaurants to reduce the risk of fire and increase the effectiveness of the fire extinguishing
systemtoputoutafireonceignited.”Id.TheDirectordeterminedthattheserviceofcleaningof
exhausthoodsis“aservice[that]isnotthetypeofcleaningservicesperformedbyajanitor....
Asaresult,thegrossreceiptsfromcleaningofexhausthoods,ductsandfansarenotsubjectto
Iowa sales or use tax.”Id.
Inthepresentmatter,likeSertle,Petitioner’sserviceofclearinggreaseanddebrisfrom
exhaust hoods forfirepreventionandfiresafetyisalsonotaserviceperformedbyajanitorin
the regular course of duty. Petitioner’s hood cleaning service involves clearing grease and
debris fromtheexhausthoodandfiresuppressionsystemincommercialkitchensandisdone
periodicallybyafiresafetyandpreventioncompany.LiketheserviceatissueinSertle,itdoes
not resemble anycleaningservicesidentifiedinIowaAdministrativeCoderule701—211.23(2)
thatwouldconstituteajanitorialservice. Therefore,Petitioner’shoodcleaningservicedoesnot
fall within the definition of “[j]anitorial services.” Because this service does not fall within the
definition of “[j]anitorial services” or “[b]uilding maintenance or cleaning,” provided in Iowa
Administrative Code rule 701—211.23(2), it is not a taxable service under IowaCodesection
423.2(6)(z).
B.

Carpentry Repair and Installation

Second, Petitioner requests analysis of whether its hood cleaning service may be a
taxable service as carpentry repair and installation. Iowa Code section 423.2(6)(k) lists
“[c]arpentry repair and installation” as a taxable service, but does not provide a definition of
“carpentry.”TheDepartment’sadministrativerulesalsodonotprovideadefinitionof“carpentry.”
However, Iowa Administrative Code rule 701—219.13(6) provides, “[p]ersons engaged in the
business of carpentry, as the trade is known in the usual course of business, are selling a
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service subject to sales tax, regardless of whether they perform repair or installation. The
carpentry services can be conducted on or within real or personal property.”
Whenascertainingthemeaningofawordnotdefinedincode,theDepartmentmaylook
to the ordinaryusageoftheword,dictionarydefinitions,useinsimilarstatutes,andtheuseof
the word in court rulings. Kay-Decker v. Iowa State Bd. of Tax Review,857N.W.2d216,223
(Iowa 2014). There is no more precise definition in statute or rule, so we may look to the
dictionary definitions and ordinary usage of the word “carpentry” and “carpenter.”
Merriam-Websterdefinesa“carpenter”as“aworkerwhobuildsorrepairswoodenstructuresor
their

structural

parts.”

“Carpenter,”

merriam-webster.com,

https://www.merriam-webster.com/dictionary/carpenter. (Accessed June 19, 2025). The United
States Bureau of Labor Statistics (BLS) also provides a definition of “carpenter” in its
Occupational Outlook Handbook. Per this definition, “[c]arpenters construct, repair, andinstall
building frameworks and structures made from wood and other materials.” Bureau of Labor
Statistics, U.S. Department of Labor, Occupational Outlook Handbook, Carpenters, at
https://www.bls.gov/ooh/construction-and-extraction/carpenters.htm. (last visited June 23,
2025).
Here,thePetitionerdescribestheirhoodcleaningservicesascleaningservices.Itdoes
not describe any work related to building or repairing. The statement in the BLS definition of
“carpenter” that carpenters may perform work on structures made from “other materials” in
addition to wood allows forsomeambiguityinwhatconstitutes“carpentry.”Thehoodcleaning
servicedescribedneverthelessdoesnotincludeconstruction,repair,installation,orconstruction
toanystructure,whetherconstructedofwoodoranyothermaterials.Thisservicedoesnotfall
withinanydefinitionofcarpentry.Therefore,Petitioner’shoodcleaningserviceisnottaxableas
“carpentry.”

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Roof, Shingle, and Glass Repair and Electrical and Electronic Repair and

Installation
Petitioner also requested the Department analyze whether itshoodcleaningserviceis
taxable as roof, shingle, and glassrepairoraselectricalandelectronicrepairandinstallation.
Iowa Code sections 423.2(6)(l) and 423.2(6)(p) identify “roof, shingle, and glass repair” and
“electrical and electronicrepair”asenumeratedservicessubjecttotax.Similarto“[c]arpentry,”
the Iowa Code and Iowa Administrative Code do not provide precise definitions for what
constitutes “roof, shingle, and glass repair” or“electricalandelectronicrepair.”However,Iowa
AdministrativeCoderule701—219.13(6)“b”statesofroof,shingle,andglassrepair,“[P]ersons
engaged in the business of repairing, restoring, orrenovatingroofsorshinglesorrestoringor
replacing glass, whethertheglassispersonalpropertyoraffixedtorealproperty,aresellinga
servicesubjecttosalestax.”Similarly,IowaAdministrativeCoderule701—219.13(6)“c”states,
“[p]ersons engaged in the business of repairing or installing electrical wiring, fixtures, or
switchesinoronrealproperty,orrepairingorinstallinganyarticleoftangiblepersonalproperty
powered by electric current, are selling a service subject to sales tax.”
In the present case, there is nothing in Petitioner’s description or in the rest of the
Petitionshowingthatitshoodcleaningservicefallswithinthescopeofeitherroof,shingle,and
glass repair or electrical and electronic repair and installation. Therefore, the hood cleaning
service at issue is not taxable as either of these enumerated services.
D.

Pipe Fitting and Plumbing

ThelastenumeratedservicethatPetitionerlistedispipefittingandplumbing.IowaCode
section 423.2(6)(an) lists “pipe fitting and plumbing” as an enumerated service. There is no
definition forthesetermsinstatute.However,theassociatedadministrativerulestates,“‘[p]ipe
fittingandplumbing’meansthetradeoffitting,threading,installing,andrepairingpipes,fixtures,
or apparatus used for heating, refrigeration, or air conditioning, or concerned with the

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introduction, distribution, and disposal of a natural or artificial substance.” Iowa Admin. Code
701—219.13(6) “f”(2).
Here,thePetitioner’sdescriptionofitshoodcleaningservicedoesnotincludeanywork
on customers’ “pipes, fixtures, or an apparatus used for heating, refrigeration, or air
conditioning, or concerned with the introduction, distribution, and disposal of a natural or
artificialsubstance.”Id.Italsodoesnotincludeanyworkonanyoftheothertypesofequipment
describedinthedefinitionidentifiedabove.TheserviceprovidedbythePetitionerinvolveswork
on the customers’ exhaust hoods, but even if exhaust hoods were an “apparatus used for
heating, refrigeration, or air conditioning, or concerned with the introduction, distribution, and
disposal of a...substance,”theserviceistoremovegreaseanddebrisfromthehoodrather
than “fitting, threading,installing,andrepairing”ofthehood.Petitioner’shoodcleaningservice
does not include any of the items from the rule’s description of “pipe fitting and plumbing.”
Therefore, the hood cleaning service is not taxable as pipe fitting and plumbing.
E.

Services to Real Property

Finally, the Petitioner states its belief that hood cleaning may be a taxable service
becausehoodcleaningcouldbeaservicetorealproperty.Petitionerstatesthatotherservices
to real property are enumeratedastaxableservicesinIowaCodesection423.2(6)andstates
that its hood cleaning service may be a taxable service for this reason.
ThesalespriceofaserviceisonlysubjecttosalesorusetaxinIowawhenenumerated
insection423.2(6).IowaCode§423.2(5).Thecleaningofexhausthoodsisnotanenumerated
service in this subsection andisnotoneoftheenumeratedservicesanalyzedabove.Further,
there is no Iowa Code section or Iowa Administrative Code rule indicating that a service is
taxable solely because it is a service to real property. Petitioner has also not identified any
sourceorprecedentthatwouldsuggestaserviceistaxablesolelybecauseitisaservicetoreal
property. Therefore, even if it is assumed that commercial kitchen exhaust hoods are real

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property, the hood cleaning service provided by Petitioner is not a taxable service solely
because it is performed on real property.
V.

CONCLUSION
ThehoodcleaningservicedescribedinthePetitiondoesnotfitwithinanyofthetaxable

services that Petitioner requested theDepartmentanalyze.Hoodcleaningservicesarenotan
enumerated service in Iowa Code section 423.2(6). Therefore, Petitioner’s hood cleaning
service is not a taxable service in Iowa.

ORDER
THEREFORE, based on the facts presented, foregoing reasoning, and applicable
provisions of the law, the questions presented in Petitioner’s Petition for Declaratory Order,
Docket No. 912498, are as answered above.

31st day of __,
July
Issued at Des Moines, Iowa this ______
2025.

IOWA DEPARTMENT OF REVENUE

By ______
Mary Mosiman, Director

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