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 the Excise Duty on Hydrocarbons must be covered by a circulation document, such as the delivery note provided for in the RIE, when exceeding 200 liters. In the case of transport in drums or additional tanks, it is not considered atypical transport if it complies with dangerous goods regulations and retail sale rules. Retail distributors supplying other retailers must be registered in the register of excise duties.
The DGT's position remains constant in requiring a circulation document for volumes exceeding 200 liters. Rulings confirm that transport in additional tanks is lawful under dangerous goods regulations and that the obligation to document circulation applies to both individuals and retail distributors.
Turning points
Establishes that transport in drums or additional tanks is not an atypical form of transport if it complies with dangerous goods and retail sale regulations.
Analysis based on 8 of 8 rulings with a stated position. Updated 30 September 2026.