Do wheelchair ramps, stair lifts, and grab bars qualify for Illinois's reduced 1% sales tax rate for medical appliances?

Plain-English summary

A company that sells and rents wheelchair accessibility ramps, stair lifts, and grab bars asked the Illinois Department of Revenue whether those products qualify for the state's reduced 1% sales and use tax rate for "medical appliances," the same rate that applies to wheelchairs. The Department said no: ramps, stair lifts, and grab bars are taxed at the regular 6.25% state rate (plus any applicable local taxes), not the 1% rate.

Illinois taxes most tangible personal property at 6.25% under the Retailers' Occupation Tax Act and the Use Tax Act, but drugs, medicines, and "medical appliances" get a reduced 1% state rate under 86 Ill. Adm. Code 130.311. The regulation defines a medical appliance as an item that directly substitutes for a malfunctioning part of the human body — examples given include artificial limbs, dental prostheses, orthodontic braces, crutches, orthopedic braces, wheelchairs, heart pacemakers, and dialysis machines, as well as corrective items like hearing aids, eyeglasses, and contact lenses.

The Department drew a line between wheelchairs (which qualify for the 1% rate) and the accessibility products at issue here (which do not). Its reasoning: wheelchair ramps, stair lifts, and grab bars help a person with physical disabilities get around, but they do not themselves substitute for any malfunctioning body part the way a wheelchair, artificial limb, or pacemaker does. Because they fall outside the regulatory definition of "medical appliance," they're taxed at the full 6.25% rate.

The letter also flagged a related but separate point: since January 1, 2025, leases of tangible personal property (which would include ramp or stair-lift rentals) are themselves treated as taxable "sales" under Illinois's retailers' occupation tax, following changes made by Public Act 103-592.

What this means for you

Sellers and lessors of mobility and accessibility equipment

If you sell or rent wheelchair ramps, stair lifts, grab bars, or similar accessibility products in Illinois, charge the regular 6.25% state sales tax rate (plus local taxes) — do not apply the 1% medical appliance rate to these items. Note that rentals of this equipment are now taxable "sales" for retailers' occupation tax purposes as of January 1, 2025, so rental receipts are taxed the same way as outright purchases.

Businesses selling actual medical appliances (wheelchairs, braces, prosthetics)

If your products directly substitute for a malfunctioning body part — wheelchairs, artificial limbs, orthopedic braces, hearing aids, and the like — the 1% reduced state rate under 86 Ill. Adm. Code 130.311 still applies. This letter reinforces that the exemption is narrow and tied to that specific "directly substitutes" test, not to whether a product generally helps someone with a disability.

Accountants and tax professionals advising disability-related retailers

When classifying accessibility products for Illinois sales/use tax purposes, apply the Department's direct-substitution test rather than a broader "assists people with disabilities" standard. Items that merely provide access (ramps, lifts, grab bars) fail that test even though items that replace bodily function (wheelchairs, braces, pacemakers) pass it. Also track the new leasing rule under Article 75 of Public Act 103-592, since it changes how rental transactions of this kind of equipment are taxed going forward.

Common questions

Q: Do wheelchair ramps qualify for Illinois's 1% medical appliance sales tax rate?
A: No. The Department concluded that ramps, along with stair lifts and grab bars, are taxed at the regular 6.25% state rate plus applicable local taxes, because they do not directly substitute for a malfunctioning part of the body.

Q: Do wheelchairs themselves get the reduced rate?
A: Yes. Wheelchairs are specifically listed as qualifying for the 1% rate under 86 Ill. Adm. Code 130.311(e)(1), unlike the ramps, stair lifts, and grab bars addressed in this letter.

Q: What is the legal test the Department used to draw this line?
A: To qualify as a "medical appliance" taxed at 1%, an item must directly substitute for a malfunctioning part of the human body (as with artificial limbs, braces, or pacemakers). Devices that merely assist a person with a disability, without replacing a bodily function, do not meet that test.

Q: Does renting out these ramps or lifts change the tax treatment?
A: Not the applicable rate, but it does affect how the tax is collected. Since January 1, 2025, leases of tangible personal property are treated as taxable "sales" for Illinois retailers' occupation tax purposes, so rental receipts on ramps and lifts are now taxed the same way as sales receipts.

Q: Can this company (or any other taxpayer) rely on this letter as binding?
A: No. This is a General Information Letter, not a Private Letter Ruling. It only directs the requester to relevant regulations and is not a statement of Department policy and is not binding on the Department.

Citations and references

Statutes and rules:

• 35 ILCS 120/2 (Retailers' Occupation Tax Act imposition)
• 35 ILCS 105/3 (Use Tax Act imposition)
• 35 ILCS 120/1 (definition of "sale" includes a lease, effective Jan. 1, 2025)
• 86 Ill. Adm. Code 130.101 (Retailers' Occupation Tax regulations)
• 86 Ill. Adm. Code 150.101 (Use Tax regulations)
• 86 Ill. Adm. Code 130.311 (Drugs, Medicines, Medical Appliances and Grooming and Hygiene Products)
• 86 Ill. Adm. Code 130.311(a) (items taxed at the reduced 1% rate)
• 86 Ill. Adm. Code 130.311(c)(1) (medicinal-claim examples)
• 86 Ill. Adm. Code 130.311(e)(1) (wheelchairs qualify for the low rate)
• 86 Ill. Adm. Code 130.311(g) (medical appliance examples)
• 2 Ill. Adm. Code 1200.110 (private letter ruling procedure)
• 2 Ill. Adm. Code 1200.120 (general information letter procedure)

Source

• Landing page: https://taxarchive.illinois.gov/research/legal/letter-rulings/sales-tax/2025.html
• Original PDF: https://tax.illinois.gov/content/dam/soi/en/web/taxarchive/research/legal/letter-rulings/sales-tax/2025/st25-0008-gil.pdf

Original ruling text

ST 25-0008-GIL 03/04/2025 DRUGS & MEDICAL APPLIANCES
A medical appliance is an item that directly substitutes for a malfunctioning part of
the human body. Products that qualify as medical appliances are taxed at a lower
State tax rate of 1% plus any applicable local taxes. 86 Ill. Adm. Code 130.311. (This
is a GIL).
March 4, 2025
NAME
COMPANY d/b/a COMPANY1
ADDRESS
Dear NAME:
This letter is in response to your letter dated February 4, 2025, in which you requested
information. The Department issues two types of letter rulings. Private Letter Rulings
(“PLRs”) are issued by the Department in response to specific taxpayer inquiries concerning
the application of a tax statute or rule to a particular fact situation. A PLR is binding on the
Department, but only as to the taxpayer who is the subject of the request for ruling and only
to the extent the facts recited in the PLR are correct and complete. Persons seeking PLRs
must comply with the procedures for PLRs found in the Department’s regulations at 2 Ill.
Adm. Code 1200.110. The purpose of a General Information Letter (“GIL”) is to direct
taxpayers to Department regulations or other sources of information regarding the topic
about which they have inquired. A GIL is not a statement of Department policy and is not
binding on the Department. See 2 Ill. Adm. Code 1200.120. You may access our website at
https://tax.illinois.gov/ to review regulations, letter rulings and other types of information
relevant to your inquiry.
The nature of your inquiry and the information you have provided require that we
respond with a GIL. In your letter you have stated and made inquiry as follows:
I am requesting a letter ruling to consider exempting my customers from being
required to pay sales tax on wheelchair ramps. As my clients are primarily
disabled with very high medical expenses, and senior citizens, most of which
living on fixed incomes, I was hoping you would consider this request. When
speaking with a representative at the Illinois Taxpayer Assistance Division,
they mentioned that wheelchairs appeared to be exempt under section
130.311. Perhaps the ramps that are required for the use of these wheelchairs
could be exempted as well? We provide ramps for residents in both STATE and
Illinois, and I've enclosed a copy of the letter ruling we were provided for STATE
simply for your reference in case I've made a mistake in the procedure for
making a request such as this.

COMPANY d/b/a COMPANY1/NAME
Page 2
March 4, 2025
Issue: Are Applicant’s sales and rentals of wheelchair accessibility ramps,
stair lifts, and grab bars that allow users access to stairways and over door
thresholds exempt from sales and use tax? This issue is not presently under
investigation or audit by the Department of Revenue, and Applicant is not
presently pursing any protest, litigation or negotiation on the issue with the
Department of Revenue.
Facts: COMPANY1 (Applicant) sells, rents and assembles wheelchair
accessibility ramps that allow users access on stairways and over door
thresholds. The ramps are prefabricated in an out-of-state factory and
shipped to Applicant for distribution. Ramps may be rented for short durations
or can be purchased for longer-term needs.
Desired Result: To receive a current letter ruling that confirms the exemption
of the sale or rental of ambulatory aids from sales and use tax.
Please let me know if you have any questions or concerns and thank you for
your consideration.
DEPARTMENT’S RESPONSE:
The Illinois Retailers’ Occupation Tax Act imposes a tax upon persons engaged in this
State in the business of selling tangible personal property to purchasers for use or
consumption. See 35 ILCS 120/2; 86 Ill. Adm. Code 130.101. In Illinois, Use Tax is imposed
on the privilege of using, in this State, any kind of tangible personal property that is
purchased anywhere at retail from a retailer. See 35 ILCS 105/3; 86 Ill. Adm. Code 150.101.
These taxes comprise what is commonly known as “sales” tax in Illinois. If the purchases
occur in Illinois, the purchasers must pay the Use Tax to the retailer at the time of purchase.
The retailers are then allowed to retain the amount of Use Tax paid to reimburse themselves
for their Retailers’ Occupation Tax liability incurred on those sales. If the purchases occur
outside Illinois, purchasers must self-assess their Use Tax liability and remit it directly to the
Department.
Effective January 1, 2025, in accordance with the provisions of Article 75 of Public Act
103-592, persons engaged in the business of leasing tangible personal property at retail
(“lessors”) in Illinois are subject to State and local retailers’ occupation tax on the gross
receipts from leases of tangible personal property made in the course of business. See 35
ILCS 120/2. A “lease” is defined as a transfer of the possession or control of, the right to
possess or control, or a license to use, but not title to, tangible personal property for a fixed
or indeterminate term for consideration, regardless of the name by which the transaction is
called, but does not include a lease entered into merely as a security agreement that does
not involve a transfer of possession or control from the lessor to the lessee. On and after

COMPANY d/b/a COMPANY1/NAME
Page 3
March 4, 2025
January 1, 2025, for purposes of State and local retailers’ occupation taxes, the term “sale”
includes a lease. See 35 ILCS 120/1. The tax applies to lease receipts received on or after
January 1, 2025, for leases in effect, entered into, or renewed on or after that date. The lessor
must remit for each tax return period the tax applicable to lease receipts received during
that tax return period. See 35 ILCS 120/2.
All gross receipts from sales of tangible personal property in Illinois are subject to
Retailers’ Occupation Tax unless an exemption is specifically provided. Medicines and
medical appliances are not taxed at the basic State rate of 6.25% plus applicable local
taxes. These items are taxed at a reduced State rate of 1% plus applicable local taxes. See
86 Ill. Adm. Code 130.311, Drugs, Medicines, Medical Appliances and Grooming and
Hygiene Products. Items subject to this lower tax rate include prescription and
nonprescription medicines, drugs, medical appliances, and insulin, urine testing materials,
syringes, and needles used by human diabetics. See 86 Ill. Adm. Code 130.311(a).
A medicine or drug is defined as any pill, powder, potion, salve, or other preparation
for human use that purports on the label to have medicinal qualities. A written claim on the
label that a product is intended to cure or treat disease, illness, injury, or pain, or to mitigate
the symptoms of such disease, illness, injury, or pain constitutes a medicinal claim. See 86
Ill. Adm. Code 130.311(c)(1) for examples of medicinal claims.
A medical appliance is an item that is used to directly substitute for a malfunctioning
part of the human body. Included in the exemption as medical appliances are such items
as artificial limbs, dental prostheses and orthodontic braces, crutches and orthopedic
braces, wheelchairs, heart pacemakers, and dialysis machines (including the dialyzer).
Corrective medical appliances such as hearing aids, eyeglasses, and contact lenses qualify
for 1% rate. Moreover, generally, home glucose monitors, test strips, and related supplies
used to treat human diabetes also qualify for the 1% State rate of tax. See 86 Ill. Adm. Code
130.311(g).
Wheelchairs qualify for the low rate of tax. See 86 Ill. Adm. Code 130.311(e)(1).
However, wheelchair ramps, stair lifts, and grab bars do not generally qualify for the low rate.
In order to qualify for the low rate of tax as a medical appliance, the item must directly
substitute for a malfunctioning part of the body. These items do not meet this requirement.
Wheelchair ramps, stair lifts, and grab bars are devices which, while used to assist a
person with physical disabilities, do not directly substitute for a malfunctioning part of the
body. Such items do not fall within the definition of medical appliance and are, therefore,
taxed at the State sales tax rate of 6.25% plus any applicable local taxes.

COMPANY d/b/a COMPANY1/NAME
Page 4
March 4, 2025
I hope this information is helpful. If you require additional information, please visit
our website at https://tax.illinois.gov/ or contact the Department’s Taxpayer Information
Division at 800-732-8866.
Very truly yours,
Kimberly Rossini
Associate Counsel
KAR:slc