Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
Non-reusable plastic packaging designed to contain, protect, handle, distribute, or present goods is subject to the tax. Articles that do not fulfill the function of packaging, such as garbage bags or protectors that are not delivered with the goods, nor elements that are an integral part of the product or perform additional technical functions such as print heads, are not taxed.
The DGT maintains a constant position based on the purpose of the object. Throughout the rulings, it has been delimited that liability depends on whether the element acts as a container for the goods or if it is a technical component or for a different use, as in the case of anti-rodent protectors or print heads.
Turning points
Distinguishes between adhesive paper, which is not subject to the tax, and the polypropylene or polyethylene reels that support it, which are indeed packaging subject to the tax.
Establishes that a cartridge is only packaging if it is a mere disposable container, excluding assemblies that include technical elements such as print heads or heating elements.
Specifies that protective articles are only taxed if they are intended to be delivered together with the protected goods.
Analysis based on 55 of 57 rulings with a stated position. Updated 23 September 2026.