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V2326-25 2 December 2025 · SG de Impuestos Especiales y de Tributos sobre el Comercio Exterior y sobre el Medio Ambiente Criterion in force
OTRO · impuesto especial sobre envases de plástico no reutilizables

Recycled plastic certificates accepted if kilogram amounts can be calculated

The consultant asks whether plastic recycling certificates expressing content as a percentage are valid in the absence of direct kilogram measurement. The DGT confirms they are acceptable if the percentage allows calculation of kilogram quantities.

The question raised

For the purposes of determining the tax base of the Special Tax on non-reusable plastic packaging, the applicant states that, as there is currently no reliable analytical technology for the direct determination of recycled content in a product that allows for the certification of the quantity of recycled plastic in kilograms, whether certificates that determine the quantity of recycled plastic based on a percentage should be considered valid.

The DGT's ruling

In order for recycled plastic not to be included in the tax base, its quantity must be certified in kilograms by an entity accredited under the UNE-EN 15343:2008 standard. Notwithstanding, certificates expressing the content as a mass percentage shall be accepted provided that, based on said percentage, the quantity of recycled plastic expressed in kilograms can be determined.

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