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Ezel / Tax Rulings / TX
TX 8509L0663B14 Sales and/or Use Tax (State,Local,MTA) 1985-09-06

Which carpet, upholstery, Scotchgard, and deodorizer services and purchases were taxable in Texas?

Short answer: Carpet and furniture-upholstery services were taxable, while automobile-upholstery cleaning and Scotchgard were not; cleaning chemicals were taxable inputs, but transferred deodorizer and Scotchgard were not.

Apply this to your situation

This page answers the general question as of 1985. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1985
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 1985 Texas Comptroller taxpayer-response letter addressing the specific carpet, furniture-upholstery, automobile-upholstery, Scotchgard, deodorizer, and chemical transactions reproduced below. Although STAR's caption mentions fire retardants, the ruling body discusses Scotchgard and deodorizer and does not mention fire retardants, so this page follows the body. The letter expressly says different facts could change the opinion. Current cleaning, protective-coating, deodorizing, automobile, input-purchase, resale, and sales-tax rules may differ, and STAR documents may no longer represent current policy even when not marked superseded. Letters on STAR can support detrimental reliance only for the taxpayer to whom the letter was directly issued under 34 Tex. Admin. Code Rules 3.1 and 3.10. Taxpayer-identifying details are redacted. This summary is informational only and is not legal or tax advice.
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

Carpet cleaning was taxable for wall-to-wall carpet, area rugs, and automobile carpeting. Furniture-upholstery cleaning was taxable, but automobile-upholstery cleaning was not.

Applying Scotchgard was taxable on carpet and furniture upholstery but not on automobile upholstery. Deodorizing carpet and upholstery was taxable, and Scotchgard and deodorizing remained taxable when performed in addition to carpet cleaning.

The provider owed tax when buying carpet- and upholstery-cleaning chemicals. Its purchases of deodorizer and Scotchgard were nontaxable because those materials were transferred to the customer by remaining in or on the carpet or upholstery.

Common questions

Was automobile carpet cleaning taxable? Yes.

Was automobile-upholstery cleaning taxable? No.

Was Scotchgard application taxable? Yes on carpet and furniture upholstery; no on automobile upholstery.

How were the provider's chemical purchases treated? Cleaning chemicals were taxable, while transferred deodorizer and Scotchgard were not.

Citations and references

  • 34 Tex. Admin. Code Rules 3.285 and 3.310 — rules enclosed for reference according to the letter.

Source

Original ruling text

September 6, 1985

Dear ***:

Thank you for your letter of August 22, 1985, concerning the taxability
of the following services:

  1. Carpet cleaning is performed on wall-to-wall carpet, area rugs and
    also automobile carpeting.

Response: Taxable.

  1. Upholstery cleaning is performed on all types of furniture and also
    automobiles.

Response: Cleaning furniture is taxable. Cleaning automobile upholstery is
not taxable.

  1. Scotchgarding is performed on both carpet and upholstery. Scotchgard is a
    liquid that is diluted with water and applied in a separate application as a
    protector against spotting, etc.

Response: Taxable when applied to carpet and furniture upholstery. Not taxable
when applied to automobile upholstery.

  1. Lysol deodorizer is a liquid diluted with water and is applied as a separate
    application to eliminate odors from carpet and upholstery.

Response: Taxable.

  1. Scotchgarding and deodorizing are applications done in addition to the carpet
    cleaning and as a rule are never performed without the carpet first being cleaned by us.

Response: Taxable.

The purchase of chemicals to clean carpet and upholstery is taxable. The purchase
of deodorizers and scotch guard is not taxable because they are transferred to the
customer (remain in or on the carpet and upholstery).

I have enclosed Rules 3.285 and 3.310 for reference.

This opinion is based upon the facts you presented. If there are additional
or different facts, this opinion may change.

Please feel free to contact us if you have additional questions. You may
write us, call toll free 1-800-252-5555 from anywhere in Texas.

Sincerely,

Tax Policy Section
Tax Administration Division

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