Did the Comptroller change the manufacturing exemption policy for equipment (dies, photoengravings, presses) used by printers and publishers?

Subject

Printer/Publisher Manufacturing Exemption — Comptroller Declines Proposed Policy Change

Source

• STAR search: https://star.comptroller.texas.gov/search?doc_type_code=L&tax_type_code=SST
• Opinion: https://star.comptroller.texas.gov/view/9311L1299C10

Plain-English Summary

This is a short letter from Comptroller John Sharp responding to a taxpayer (likely an industry representative, given the letter's reference to "the industry") who had written in expressing concern about a proposed policy change affecting how the manufacturing exemption applies to equipment used by printers and publishers — the letter's subject line points to items like dies, photoengravings, and printing presses used in the printing process.

The Comptroller's office reviewed the issue and concluded that it would not change the existing policy — the same policy that "has been applied to printers and publishers over the last several years." Because the policy was staying the same, the letter states that "the rule does not require amendment."

The letter acknowledges that "the proposed change in our application of the manufacturing exemption to printers and publishers has worried the industry," and frames the decision not to change the policy as something intended to "alleviate those concerns."

A handwritten-style note at the end of the letter references a previous accession number (9311325L), indicating this letter is a re-issued or re-indexed version of an earlier document in the STAR system.

What This Means For You

If you're a printer or publisher relying on the manufacturing exemption for equipment like dies, photoengravings, or presses: This letter reflects a decision by the Comptroller, as of November 1993, to leave the existing manufacturing exemption policy for printers and publishers unchanged, despite a proposal that would have altered it. The letter does not describe what the proposed change would have been or what the underlying exemption policy actually says — it only confirms that the status quo was preserved and the rule was not amended.

Limits of this letter: The letter does not cite any specific statute, administrative rule number, or STAR policy document, and it does not explain the substance of the manufacturing exemption itself (e.g., which specific equipment qualifies or under what conditions). It is a decision memo confirming "no change," not a standalone explanation of the exemption's requirements. Because it dates from 1993 and is only preserved as a re-issued STAR document, readers should confirm current Comptroller guidance before relying on it.

Q&A

Q: Did the Comptroller change how the manufacturing exemption applies to printers and publishers?
A: No. The letter states the Comptroller "will not change the policy that has been applied to printers and publishers over the last several years."

Q: Was any rule amended as a result of this decision?
A: No. The letter says explicitly, "Because the policy is not being changed, the rule does not require amendment."

Q: What equipment does this letter concern?
A: The letter's subject concerns equipment such as dies, photoengravings, and printing presses used in the printing process, though the body of the letter itself discusses the policy decision in general terms rather than itemizing specific equipment.

Q: Does this letter explain what the manufacturing exemption actually covers for printers and publishers?
A: No. The letter only confirms that a previously proposed change to the exemption's application was rejected; it does not describe the substantive rules for what equipment qualifies.

Original ruling text

November 30, 1993

Dear ***

Thank you for your letter expressing your concerns about the
policy change regarding items used in manufacturing by printers and publishers.
First, I want to apologize for taking so long in answering your letter. As
you know, your letter raised very important and difficult issues which required
a thorough review by me and my staff.

I am sure you will be pleased to know that, after this review, I have concluded
that we will not change the policy that has been applied to printers and
publishers over the last several years. Because the policy is not being
changed, the rule does not require amendment.

I know the proposed change in our application of the manufacturing exemption to
printers and publishers has worried the industry. However, I believe this
decision will alleviate those concerns. Should you have any further questions,
please call Mike Doyle, Director of Tax Administration, at 463-4783.

Sincerely,

JOHN SHARP
Comptroller of Public Accounts

NOTE: Previous Accession Number 9311325L