Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
The circulation of products subject to excise duties requires an accompanying document, with the delivery note for circulation being the standard instrument for domestic sales or supplies between retailers. In the case of petroleum products, the transport of volumes exceeding 200 liters for own consumption requires this document. Documents may be issued in electronic format provided they comply with the data required by current regulations.
The DGT's position remains constant in requiring documentation for the circulation of sensitive products or those subject to excise duties. Throughout the rulings, the validity of electronic formats has been specified and the volume thresholds for the transport of fuels have been detailed. No changes in criterion are observed, but rather a technical application of excise duty and IVA (Value Added Tax) regulations.
Turning points
It is confirmed that circulation documents and delivery notes may be issued through computerised procedures and stored on any device for presentation.
It is established that electronic delivery notes comply with the approved models if they contain the minimum information required by Order HAC/1147/2018.
Analysis based on 10 of 12 rulings with a stated position. Updated 27 September 2026.