How the DGT's position has evolved
Current position
To be taxable, a product must be a non-reusable packaging that contains plastic and is intended to contain, protect, handle, distribute, or present goods. Products intended to contain waste, such as garbage bags or pet waste bags, are not packaging because they do not contain goods. Packaging for internal use in laboratories or for containing reagents is subject to the tax, as it fulfills the functions of packaging for goods.
The DGT maintains a consistent position based on the distinction between goods and waste. The doctrine establishes that if the content is not a good (such as biological samples or waste), the container is not packaging. It confirms the taxability of products that, although used in specific environments such as laboratories, fulfill the function of containing goods.
Turning points
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Clarifies that packaging designed to contain waste intended for treatment is indeed within the scope of the tax, as it fulfills the functions of packaging for goods during its treatment phase.
Analysis based on 11 of 11 rulings with a stated position. Updated 28 September 2026.