Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
Acquirers of taxed products who do not hold the status of manufacturers must state in an invoice or certificate, upon request, the amount of tax paid and the quantity of non-recycled plastic in kilograms. In the case of plastic coils for processing, the acquirer is not a taxpayer if purchasing from a domestic manufacturer, but maintains the information obligation. Imports are settled as customs debt, although the taxpayer must prove the exemption based on the minimum amount.
The DGT's position remains constant regarding the formal information obligations for acquirers who are not manufacturers. Throughout the rulings, the cases for exemption due to medical products or for amounts below 5 kg per month have been specified, and the treatment of semi-finished products such as plastic coils has been clarified.
Turning points
Establishes that recycled plastic must be certified under the UNE-EN 15343:2008 standard or through a responsible declaration during the first 12 months.
Specifies the exemption for medical product packaging (primary, secondary, and tertiary) and the exemption for not exceeding 5 kilograms per month.
Analysis based on 34 of 34 rulings with a stated position. Updated 23 September 2026.