Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
The accreditation of recycled plastic content must be carried out through certification by an entity accredited under the UNE-EN 15343:2008 standard or equivalent. Following the end of the transitional period, the manufacturer's responsible declaration is no longer valid for this purpose. In the absence of specific certification schemes, the evidentiary rules of the General Tax Law (Ley General Tributaria) shall apply.
The DGT's position has moved from allowing a transition phase with responsible declarations to requiring formal certification. Ruling V1719-23 allowed the use of responsible declarations during the first 12 months, but ruling V1151-24 confirms that this period has expired, mandating accreditation through accredited entities or the evidentiary rules of the LGT.
Turning points
Introduced the possibility of using a responsible declaration signed by the manufacturer during the first 12 months of the tax's application.
Establishes that, upon the expiration of the responsible declaration's validity period, the accreditation of recycled plastic must be carried out according to article 77 of Law 7/2022.
Analysis based on 13 of 13 rulings with a stated position. Updated 27 September 2026.