How the DGT's position has evolved
Current position
Taxpayers who import fluorinated greenhouse gases must register in the Territorial Registry at the management office of their tax residence. Registration allows for the issuance of an identification card with the Fluorinated Gases Activity Code. For manufacturing or intra-Community acquisition activities, registration is also mandatory, except for specific exceptions based on the weight or nature of the product.
The DGT's position remains constant regarding the requirement to register in the territorial registry to carry out the activity as a taxpayer. Throughout the rulings, the mandatory scenarios for installers, importers, and manufacturers have been specified, as well as the administrative management through the identification card and the Activity Code.
Turning points
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Establishes that registration must be carried out at the management office of the demarcation where the establishment is located and allows for the accreditation of the right to the facilities through a mediation and deposit contract.
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Clarifies that installers with limited certificates for loads of less than 3 kg are final consumers and cannot obtain the Activity Code as resellers.
Analysis based on 48 of 51 rulings with a stated position. Updated 23 September 2026.