The provisions of Regulation 20 allowing the printer to purchase these items on resale relates solely to the purchase of the finished end product of another vendor. Regulation 20 does not apply to the production of these items by a printer preliminary to the production of printed matter. The exception pertains exclusively to items purchased by printers. As the regulation provides, the printer is regarded as the retailer of printed material. As such, the printer is not deemed to be retailing preliminary production items, although the same may be furnished to the customer.
Any items furnished to the customer are incidental to the printer's sale of printed material.
Therefore, it is hereby ruled that in producing color separations, typesetting, mechanicals and assembled lithographic films and flats a printer cannot purchase the materials to produce those items on resale. The Department expects all printers to be in compliance with the above policy by July 1, 1990.