Doctrine by topic · DGT Observatory
How the DGT's position on this topic has evolved, and the rulings it rests on.
Current position
Semi-finished products are not considered the manufacture of packaging, but their refund is conditional upon proving that they were not intended to obtain packaging and accrediting the payment of the tax. Reusable packaging, designed for multiple rotations or refills, falls outside the objective scope of the tax. The condition of being reusable must be proven through admissible means of evidence, such as UNE-EN 13429:2005 certificates.
The DGT's position remains constant regarding the definition of reusability and the exclusion of semi-finished products. There is a reiteration in the need to prove the reusable condition or the non-intended use of semi-finished products through admissible evidence. There are no changes in criterion, but rather a consolidation of the evidentiary requirements.
Analysis based on 47 of 49 rulings with a stated position. Updated 23 September 2026.