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V2931-23 31 October 2023 · 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

Self-adhesive processing films are subject to the plastic packaging tax

A company has requested a ruling on whether its self-adhesive processing films are exempt from tax due to their adhesive nature. The DGT has ruled that they are not exempt, as they adhere to materials that are not yet packaging, but rather materials that will subsequently be converted into packaging.

The question raised

Whether the self-adhesive processing film is considered an adhesive for the purposes of applying the non-liability exemption established in Article 73.c) of Law 7/2022, of April 8, on waste and contaminated soils for a circular economy.

The DGT's ruling

Self-adhesive processing films are considered semi-finished products included within the objective scope of the tax. The non-liability exemption for adhesives does not apply because these films adhere to products (such as sheets or panels) that do not form part of the objective scope of the tax. The fact that the final product is packaging does not change the nature of the semi-finished product under inquiry.

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