Does acetone used to flush catalyzed resin out of fiberglass spray equipment (chopper guns) qualify for the sales tax manufacturing exemption?

Plain-English summary

A custom fiberglass product manufacturer uses "chopper guns" — spray equipment with a built-in acetone flush system — to purge catalyzed resins from the guns and lines during manufacturing. The manufacturer asked whether the acetone it purchases for this purpose qualifies for the sales tax manufacturing exemption.

The Comptroller ruled that the acetone does qualify for exemption, because it's used during the manufacturing process to prevent the decline, failure, lapse, or deterioration of exempt manufacturing equipment — the specific exemption ground under Tex. Tax Code § 151.318(a)(6). Practically, this means the manufacturer can purchase the acetone tax-free by giving its supplier a properly completed exemption certificate, rather than paying sales tax and seeking a refund later.

What this means for you

Manufacturers using flush/cleaning chemicals on production equipment

If a chemical (like acetone) is used specifically to keep your exempt manufacturing equipment running — flushing out residue, preventing buildup, or otherwise stopping the equipment from failing or deteriorating during production — it can qualify for the manufacturing exemption in its own right, separate from the equipment itself. Issue your supplier a proper exemption certificate to buy it tax-free.

Fiberglass and composite manufacturers specifically

This letter directly addresses chopper-gun acetone flush systems, so it's a close factual match if you run similar spray/resin equipment — but you still need your own facts confirmed, since letter rulings only bind the Comptroller for the taxpayer who requested them.

Accountants and tax professionals

This is a straightforward application of the § 151.318(a)(6) "equipment maintenance supplies" prong of the manufacturing exemption — supplies that keep exempt equipment from declining, failing, lapsing, or deteriorating are themselves exempt, distinct from the broader "causes a chemical or physical change in the product" test used for direct-use equipment and tools.

Common questions

Q: Is acetone used to flush manufacturing spray equipment exempt from Texas sales tax?
A: Yes, when it's used during the manufacturing process to prevent the decline, failure, lapse, or deterioration of exempt manufacturing equipment, per Tex. Tax Code § 151.318(a)(6).

Q: How do I buy the acetone tax-free?
A: Give your supplier a properly completed exemption certificate.

Q: Does this apply to any manufacturer using acetone, not just fiberglass makers?
A: The exemption ground (equipment-maintenance supplies under § 151.318(a)(6)) is general, but this specific letter's facts are about a fiberglass chopper-gun flush system — confirm your own facts match closely enough, or get your own ruling.

Q: Can I rely on this letter for my own manufacturing operation?
A: No. This opinion is rendered based on the facts presented; other facts, though similar, may yield different results.

Citations and references

Statutes:

• Tex. Tax Code § 151.318(a)(6) (manufacturing exemption — supplies preventing decline, failure, lapse, or deterioration of exempt equipment)

Source

• STAR search: https://star.comptroller.texas.gov/search?doc_type_code=L&tax_type_code=SST
• Opinion: https://star.comptroller.texas.gov/view/200004238L

Original ruling text

April 27, 2000

Dear **:

Thank you for your letter regarding sales tax on acetone.

You are a custom manufacturer of fiberglass products. You purchase acetone for
use in your spray equipment "chopper guns." The guns have a built-in acetone
flush system to purge the system of catalyzed resins in the lines and/or guns
during the actual manufacturing process.

You are asking if the acetone used in your spray equipment qualifies for sales
tax exemption.

The acetone qualifies for exemption because it is used during the manufacturing
process to prevent the decline, failure, lapse or deterioration of exempt
manufacturing equipment. See Texas Tax Code 151.318(a)(6). The acetone may be
purchased tax-free with a properly completed exemption certificate.

This opinion is rendered based on the facts presented. Other facts though
similar, may yield different results.

If you have any questions or require additional information, you may call
1-800-531-5441, extension 6-5809. You may also submit inquiries to our tax help
Internet address at .

Sincerely

Emilio S. Lerma
Tax Policy Division