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 containing plastic that are intended for the production of non-reusable packaging are included within the objective scope of the tax. This includes films, sheets, liquid polymers, and closure elements containing plastic. Products intended for packaging that undergo multiple cycles of use or that are not non-reusable packaging are excluded.
The DGT's position remains constant regarding the application of the tax to plastic semi-finished products intended for non-reusable packaging. Through various rulings, the scope of this concept has been clarified, differentiating between raw materials (such as dyes) and products that require subsequent transformation to fulfill their function as packaging. The evolution shows a clear delimitation of liability based on the final destination of the product.
Turning points
Establishes that color concentrate is not a semi-finished product as it is considered a prior raw material, thus falling outside the scope of the tax.
Defines liquid polymer as a semi-finished product because it requires a subsequent transformation phase to fulfill its function as packaging.
Clarifies that plastic films and sheets are taxable semi-finished products, but allows for an exemption in intra-Community acquisitions if it is proven that the destination is not the production of taxable packaging.
Analysis based on 33 of 34 rulings with a stated position. Updated 24 September 2026.