How the DGT's position has evolved
Current position
The reusable status of packaging is determined by its objective configuration and not by the user's intention. Taxpayers may prove the nature of their products through any means of evidence admissible under the law. It is the responsibility of the Administration to assess the sufficiency of such evidence within the framework of tax procedures.
The DGT's position remains stable regarding the application of the tax, but it has evolved towards the definition of the means of evidence. Initially, it focused on information obligations and specific exemptions, whereas more recent rulings clarify the assessment of evidence to determine reusability.
Turning points
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Specifies that compostable plastic bags are included within the scope of the tax if they are non-reusable.
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Establishes that reusability depends on the objective configuration of the packaging and not on the user's will.
Analysis based on 48 of 49 rulings with a stated position. Updated 23 September 2026.