Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
Manufacturers must pass on the tax rate and include in the invoice the amount, the kilograms of non-recycled plastic, and the applicable exemptions. Non-manufacturer purchasers must include this information in an invoice or certificate if requested by the purchaser and provided they are not simplified invoices. The exemption for use in medicines is limited to packaging containing active ingredients intended exclusively for their manufacture.
The DGT's position remains stable regarding information obligations and the passing on of the tax. The exemption cases for medicines have been specified, limiting them to products with active ingredients (V2380-23). Likewise, the refund procedure for non-taxpayer purchasers has been clarified when the final destination is the healthcare sector (V0753-24).
Turning points
Establishes that the exemption only applies to packaging with active ingredients intended exclusively for medicines, excluding those with excipients or intermediate products.
Allows the non-taxpayer purchaser to request a refund of the tax if they prove that the destination is the healthcare sector or food for special medical uses.
Analysis based on 9 of 10 rulings with a stated position. Updated 28 September 2026.