Tax on non-reusable plastic packaging: How to reduce it?

As of January 1, 2023, new regulations came into force for companies that manufacture, import or purchase non-reusable plastic packaging. This regulation includes the tax on non-reusable plastic packaging (IPNR).


What is the excise tax on non-reusable plastic packaging?

It is a tax that charges €0.45 for each kilo of non-recycled plastic, and depending on the way in which the company declares the VAT, it will pay the tax monthly or quarterly. It should be noted that an accredited entity registered with ENAC will be in charge of determining the % of non-recycled plastic in the packaging. It is important to know that all companies affected by the new tax are required to be registered in a territorial registry of the tax in question. 

This tax is in addition to existing measures, such as the tax on landfill disposal, incineration and co-incineration of waste, to encourage the circular economy in our country.

To what type of activities does this tax apply? Who pays the plastic tax?

The tax applies to activities such as manufacture, importation, intra-Community acquisition, introduction, possession and irregular circulation in the territory where the tax applies. However, there are some cases of non-taxation, such as the manufacture of products that have ceased to be suitable for use or have been destroyed, provided that the existence of such facts has been proven before the AEAT, by any of the means of proof admissible in law, prior to the birth of the obligation to pay the tax. 

Or, for example, they are intended to be shipped directly by the manufacturer or by a third party to a territory where the tax does not apply.

Other cases not subject to the tax are the manufacture, importation or intra-Community acquisition of paints, inks, lacquers and adhesives, designed to be incorporated into the products concerned. And the manufacture, importation or intra-Community acquisition of non-reusable containers containing plastic which, although they can perform the functions of containment, protection and handling of goods, are not designed to be delivered together with such goods. 

Also excluded from the non-reusable plastic tax law are sanitary products, containers for medicines, food for medical use, infant formula for hospital use or hazardous waste of sanitary origin; and products which, after being delivered or made available to the purchaser, have been returned for destruction or reincorporation into the manufacturing process, after reimbursement of the amount thereof to the purchaser.

If we start from the assumption that packaging is considered to be any product that performs the function of containing, handling, distributing, protecting and presenting any type of merchandise, it can be said that more specifically the products affected by the tax are non-reusable packaging containing plastic, semi-finished plastic products used to obtain the packaging, such as thermoplastic preforms or sheets, and products containing plastic used to allow the closing, marketing or presentation of non-reusable packaging.

Control and reduce IPNR payment with MESbook:

With the Traceability modules, Shrinkage Costs and WMS (Warehouse Management), you can keep track of what enters the production chain, identifying also the % of recycled material that will be in the final product. This percentage of product, being recycled, will not have the obligation to pay the tax, and therefore, only the percentage that is not recycled material will be paid.

But not only can you keep track of the material that is included in the final product, but you can also control the amount of material that is rejected or destroyed because it is not suitable for use. This material is also exempt from tax.

In addition, with the WMS module (Warehouse Management) module, there is a tracking of the movement of materials between warehouses, locations and machines. This provides complete traceability in order to identify the materials affected by the tax, and thus reduce their use, avoid purchasing them or replace them with others exempt from the tax.

In order for the purchaser of the recycled product to have confidence in the quality of the product, the supplier must keep records of the quality controls carried out, including input materials, processes and finished materials or products. Therefore, the UNE-EN 15343:2008 standard establishes the following procedures:

  • Control of incoming material
  • Control of the recycled production process
  • Characteristics of recycled plastics
  • Traceability

By certifying according to the UNE-EN 15343:2008 standard , producers can now certify their products in compliance with the conditions included in the draft law on waste and contaminated soils as soon as it comes into force.

Get UNE-EN 15343:2008 certification easily with MESbook. Ask us for more information.

Arturo Torres

Customer Success Management Director

Arturo Torres

Industrial Engineer with more than 27 years of experience in different sectors as Director of Operations, Supply Chain, Processes and Quality. Lecturer in institutions such as the Chamber of Commerce and the General Council of Industrial Technical Engineering of Spain.

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