Ezel / Tax Rulings / TX
TX 9007L1034E13 Sales and/or Use Tax (State,Local,MTA) 1990-07-27

Were fulfillment-house charges for gluing or constructing displays and posters taxable, and were sorting, stuffing, and metering mailing services taxable?

Short answer: Gluing or constructing displays and posters was taxable fabrication labor whether the printer or fulfillment house billed it. Actual mailing services such as sorting, stuffing, and metering were nontaxable.

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This page answers the general question as of 1990. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1990
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 an official Texas Comptroller of Public Accounts letter published on the State Tax Automated Research (STAR) system. Letters on STAR can be the basis of a detrimental reliance claim only for the taxpayer to whom the letter was directly issued (see 34 Tex. Admin. Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded. Taxpayer-identifying details are redacted. This summary is informational only and is not legal or tax advice. Consult a licensed Texas tax professional about your specific 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) is the authoritative source for any reliance.

Plain-English summary

Labor to glue or construct posters and displays was taxable fabrication labor. The result was the same whether the printer or the fulfillment house billed the customer.

Actual mailing services—including sorting, stuffing, and metering—were nontaxable.

Common questions

Was display or poster assembly taxable? Yes.

Did it matter whether the printer or fulfillment house billed it? No.

Were sorting, stuffing, and metering taxable? No.

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS
STATE OF TEXAS
AUSTIN, TEXAS 78774

BOB BULLOCK
Comptroller

July 27, 1990

Re: Mailing and Fulfillment Services

Dear *****:

This is in response to your letter of July 26, 1990, requesting a
written verification of applicability of sales tax to the above
referenced services.

Enclosed is a copy of my letter to the ** dated April
10, 1990, recommending changes that needed to be made to the indus-
try guidebook that you referenced.

Charges for labor to glue or construct displays or posters by ful-
fillment houses are taxable as fabrication labor, whether billed by
the printer or the by fulfillment house. Actual mailing services
(sorting, stuffing, metering, etc.,) performed by a fulfillment
house would not be taxable.

This opinion is based on the facts presented. If there are different
or additional facts, this opinion could change.

If you have further questions or need more information feel free to
call me at 1-800- 531- 5441. The regular number is (512) 463-4502.
You may write me at Taxability, Legal Services Division.
[FAX (512) 475-0900]

Sincerely,
Gilbert Zamora
Taxability, Legal Services Division

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