Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
Adhesives, understood as stickers and adhesive tapes, are not subject to the tax if they are incorporated into products that fall within its objective scope. However, self-adhesive processing films are considered subject semi-finished products if they are adhered to elements that are not packaging. Non-reusable plastic labels are considered subject packaging, unless they are classified as adhesives.
The DGT's position remains stable in defining adhesives as non-subject tapes and stickers. The evolution shows a technical delimitation to prevent the application of non-subjectivity to semi-finished products that are adhered to supports outside the scope of the tax. It has been clarified that the nature of the semi-finished product prevails over its final use.
Turning points
Establishes that self-adhesive films are subject semi-finished products if they are adhered to products that are not part of the objective scope. The fact that the final product is packaging does not change the nature of the semi-finished product.
Analysis based on 9 of 9 rulings with a stated position. Updated 29 September 2026.