How the DGT's position has evolved
Current position
The tax stamps from Order HAC/3482/2007 applied to packaging manufactured or imported in the EU before 2021 are valid until January 1, 2026. After that date, derivative beverages for consumption must bear the new tax stamps. In manufacturing processes, the regulatory shrinkage (such as 3% in hot processing or 1.5% in direct distillation) delimits normal losses without the need for justification if they are real.
The DGT position remains stable regarding the calculation of shrinkage, applying specific percentages to the pure alcohol of each individual process according to the technique employed. No doctrinal change is observed in the management of losses, but rather a technical application of the regulatory percentages to delimit what is considered a normal loss.
Analysis based on 8 of 8 rulings with a stated position. Updated 30 September 2026.