Revised Code of Washington
Wash. Rev. Code § 82.04.110 (2026)
"Manufacturer."
✓ current as of May 2026
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(1) Except as otherwise provided in this section, "manufacturer" means every person who, either directly or by contracting with others for the necessary labor or mechanical services, manufactures for sale or for commercial or industrial use from his or her own materials or ingredients any articles, substances, or commodities.
(2)(a) When the owner of equipment or facilities furnishes, or sells to the customer prior to manufacture, all or a portion of the materials that become a part or whole of the manufactured article, the department shall prescribe equitable rules for determining tax liability.
(b) A person who produces aluminum master alloys is a processor for hire rather than a manufacturer, regardless of the portion of the aluminum provided by that person's customer. For the purposes of this subsection (2)(b), "aluminum master alloy" means an alloy registered with the aluminum association as a grain refiner or a hardener alloy using the American national standards institute designating system H35.3.
(3) A nonresident of this state who is the owner of materials processed for it in this state by a processor for hire shall not be deemed to be engaged in business in this state as a manufacturer because of the performance of such processing work for it in this state.
(4) The owner of materials from which a nuclear fuel assembly is made for it by a processor for hire shall not be subject to tax under this chapter as a manufacturer of the fuel assembly.
(5) For purposes of this section, the terms "articles," "substances," "materials," "ingredients," and "commodities" do not include digital goods.
[ 2009 c 535 s 405; 1997 c 453 s 1; 1971 ex.s. c 186 s 1; 1961 c 15 s 82.04.110. Prior: 1955 c 389 s 12; prior: 1949 c 228 s 2, part; 1945 c 249 s 1, part; 1943 c 156 s 2, part; 1941 c 178 s 2, part; 1939 c 225 s 2, part; 1937 c 227 s 2, part; 1935 c 180 s 5, part; Rem. Supp. 1949 s 8370-5, part.]
Notes:
Intent—Construction—2009 c 535: See notes following RCW 82.04.192.
Effective date—1997 c 453: "This act is necessary for the immediate preservation of the public peace, health, or safety, or support of the state government and its existing public institutions, and takes effect July 1, 1997." [ 1997 c 453 s 2.]
Effective date—1971 ex.s. c 186: "The effective date of this 1971 amendatory act is July 1, 1971." [ 1971 ex.s. c 186 s 5.]
Notes of Decisions
Cited in 13
cases (2 in the last 5 years), 1952–2025 · leading case: Associated Grocers, Inc. v. State, 787 P.2d 22 (Wash. 1990).
Associated Grocers, Inc. v. State, 787 P.2d 22 (Wash. 1990). “This proviso shall not apply to purchases from manufacturers as defined in RCW 82.04.110. *187 The department of revenue shall prescribe uniform and equitable rules for the purpose of ascertaining such value, which value shall correspond as nearly as possible to the gross…”
Am. Sign & Indicator Corp. v. State, 610 P.2d 353 (Wash. 1980). “" RCW 82.04.110; WAC 458-20-136. Essential to classification as a manufacturer, then, is (1) ownership of materials and (2) fabrication of *432 goods from those materials, either through (a) the manufacturer's own labor or (b) the labor of one contracted for that purpose by the…”
Stokely-Van Camp, Inc. v. State, 312 P.2d 816 (Wash. 1957). “At the trial, the parties filed a stipulation containing the agreed facts. After argument the trial court made its findings of fact and conclusions of law, upon the basis of which it entered judgment for respondent in the sum of $20,809.”
Dep't of Revenue v. Schaake Packing Co., 666 P.2d 367 (Wash. 1983). “The Department reasoned that the feed mixing facility was engaged in manufacturing as defined in RCW 82.04.110 and 82.04.120. Therefore, it determined Schaake's feed mixing facility was subject to the business and occupation tax established in RCW 82.”
Valley Fruit v. Dep't of Revenue, 963 P.2d 886 (Wash. Ct. App. 1998). “60, manufacturing has the definition used in RCW 82.04.110 and WAC 458-20-136. WAC 458-20--24001(3)(j).”
Bornstein Sea Foods, Inc. v. State, 373 P.2d 483 (Wash. 1962). “RCW 82.04.110 defines a “manufacturer” as follows: “ ‘Manufacturer’ means every person who, either directly or by contracting with others for the necessary labor or mechanical services, manufactures for sale or for commercial or industrial use from his own materials or…”
J & J Dunbar & Co. v. State, 245 P.2d 1164 (Wash. 1952). “The tax commission made an audit and classified respondent as a manufacturer as defined by RCW 82.04.110. As a result of the classification of respondent *764 as a manufacturer, it was required to pay an additional tax for the period from January 1, 1947, to December 31, 1950,…”
Reynolds Metals Co. v. State, 400 P.2d 310 (Wash. 1965). “Reynolds contends that it is not a manufacturer of the aluminum metal it ships to its own plants outside of the state for further fabrication because such metal does not constitute an article for “sale” or “commercial or industrial use” essential to the definition of the terms,…”
Gen. Elec. Co. v. State, 256 P.2d 265 (Wash. 1953). “" (RCW 82.04.110.) "`To manufacture' embraces all activities of a commercial or industrial nature wherein labor or skill is applied, by hand or machinery, to materials so that as a result thereof a new, different or useful article of tangible personal property or substance of…”
Fujifilm Sonosite Inc., V. Washington State Dep't Of Revenue (Wash. Ct. App. 2025). “While SonoSite contends that these facts are not pertinent because they do not have any bearing on which entity performed the manufacturing activities, RCW 82.04.110(1) also defines a manufacturer by its ownership of the raw materials used in manufacturing.”
Fujifilm Sonosite Inc., V. Washington State Dep't Of Revenue (Wash. Ct. App. 2025). “While SonoSite contends that these facts are not pertinent because they do not have any bearing on which entity performed the manufacturing activities, RCW 82.04.110(1) also defines a manufacturer by its ownership of the raw materials used in manufacturing.”
Cont'l Coffee Co. v. State, 384 P.2d 862 (Wash. 1963). “RCW 82.04.110 defines a “manufacturer” as follows: “ ‘Manufacturer’ means every person who, either directly or by contracting with others for the necessary labor or mechanical services, manufactures for sale or for commercial or industrial use from his own materials or…”
— Wash. Rev. Code § 82.04.110(1) — 2 cases
Fujifilm Sonosite Inc., V. Washington State Dep't Of Revenue (Wash. Ct. App. 2025). “While SonoSite contends that these facts are not pertinent because they do not have any bearing on which entity performed the manufacturing activities, RCW 82.04.110(1) also defines a manufacturer by its ownership of the raw materials used in manufacturing.”
Fujifilm Sonosite Inc., V. Washington State Dep't Of Revenue (Wash. Ct. App. 2025). “While SonoSite contends that these facts are not pertinent because they do not have any bearing on which entity performed the manufacturing activities, RCW 82.04.110(1) also defines a manufacturer by its ownership of the raw materials used in manufacturing.”
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