As of January 2023, plastic packaging
non-recyclable and non-reusable
they are subject to a special environmental tax of 0.45 €/kg.
The law: Click here to see the PDF.
Check our interpretation of the law here and resolve your doubts. Click on 
each point to read more information.
The new tax aims to make the use of non-reusable plastic packaging more expensive than other more ecological alternatives which, until now, are also more expensive than traditional products.
Depending on the products used by each of our clients, how they use them, and their greater or lesser commitment to the environment, some possible alternatives are the following.
- As far as possible, ration or eliminate the use of plastic packaging: at Multisac we have items made with other materials such as paper, jute, or cotton, which are also much more respectful of the environment.
- Using reusable products: at Multisac we also have products designed and intended to be used more than once.
- Using products that contain recycled plastic, thus reducing the tax: at Multisac we have products that contain 30% recycled material or even up to 100%, so in the latter case the tax does not apply.
All these alternatives indeed have a cost similar to or even higher than paying the new tax, but this is the precise intention of the tax: to make the economic cost of ecological options much closer to options that are not.
Check the following tables with quantified examples based on €10 of some of the possible alternatives.
Big Bags Alternatives
the differences in orange characteristics compared to the reference product in the first column.
| PP Big Bag traditional (5:1) Not reusable (REFERENCE) | PP Big Bag Traditional (6:1) reusable * | PP Big Bag 30% recycled (5:1) not reusable | rPET Big Bag 100% recycled (5:1) not reusable | |
|---|---|---|---|---|
| Common characteristics | 90x90x90 cm U-Panel with 4 handles on edges open top and flat bottom SWL 1.000 Kg | 90x90x90 cm U-Panel with 4 handles on edges open top and flat bottom SWL 1.000 Kg | 90x90x90 cm U-Panel with 4 handles on edges open top and flat bottom SWL 1.000 Kg | 90x90x90 cm U-Panel with 4 handles on edges open top and flat bottom SWL 1.000 Kg |
| Fabric material | 100% Polypropylene | 100% Polypropylene | 70% Poypropylene 30% Recycled polypropylene | 100% recycled rPET |
| Could it be food grade? | Yes | Yes | No | Yes |
| Safety factor/Usability | (5:1) Single trip Not reusable | (6:1) Multiple trip Reusable | (5:1) Single trip Not reusable | (5:1) Single trip Not reusable |
| Ecological consideration | This Big Bag does not contain recycled plastic nor is it reusable, so it is the least ecological. | The Big Bag is reusable, although many customers do not take advantage of this capability as they lose the Big Bag during the first delivery. | Being partially constructed of recycled material, it promotes the circular economy of plastic. | Built entirely from recycled material, it implements a total plastic circular economy. |
| Ecological score | ♥♥♥♥ | ♥♥♥♥ | ♥♥♥♥ | ♥♥♥♥ |
| Current availability on the market | High | High | Medium | Very low |
| Reference price** | 3,00 € (2022)3,74 € (2023) | 3,72 € (2023) | 4,19 € (2023) | 5,91 € (2023) |
| Have you paid tax? | Yes because it contains 100% non-recycled plastic | Not because it is reusable | Yes because it contains 70% non-recycled plastic | Not because it contains 100% recycled plastic |
* It is pending confirmation that the Spanish Tax Agency considers “Reusable Big Bags” as “Reusable”.
**The prices are simulated as if the reference Big Bag cost €3.00 to better understand the proportional comparison. The comparison may vary depending on the type of Big Bag. Ask our sales representatives to know the prices adapted to your products and consumption.
Alternatives for bags
| PP Bag traditional (REFERENCE) | PP Bag 30% recycled | PP Bags 100% recycled | Paper Bag traditional | Jute Bag traditional | Cotton Bag traditional | |
|---|---|---|---|---|---|---|
| Characteristics | 50×80 cm BO No coating No inner liner | 50×80 cm BO No coating No inner liner | 50×80 cm BO No coating No inner liner | 45×85+10/2 cm 2H No coating No inner liner | 50×80 cm BO 10 onz No coating No inner liner | 40×60 cm BO No coating No inner liner |
| Fabric material | 100% Polypropylene | 70% Poypropylene 30% Recycled polypropylene | 100% Recycled polypropylene | 100% Paper | 100% Jute | 100% Cotton |
| Could it be food grade? | Yes | No | No | Yes | Yes | Yes |
| Bag weight | 43 g | 50 g | 80 g | 123 g | 278 g | 74 g |
| Ecological consideration | None | Being partially constructed of recycled material, it promotes the circular economy of plastic. | Being built entirely from recycled material, it implements a total plastic circular economy. | Paper is a product of plant origin but it destroys forest areas that must be replanted. | Jute is a product of plant origin and is highly biodegradable. | Cotton is a product of plant origin and is highly biodegradable. |
| Ecological score | ♥♥♥♥ | ♥♥♥♥ | ♥♥♥♥ | ♥♥♥♥ | ♥♥♥♥ | ♥♥♥♥ |
| Market availability | High | Medium | Very low | Low | Medium | Medium |
| Reference price*** | 0,15 € (2022) | 0,20 € (2023) | 0,24 € (2023) | 0,51 € (2023) | 1,14 € (2023) | 0,82 € (2023) |
| Have you paid the tax? | Yes because it is 100% non-recycled plastic | Yes, because it has 70% non-recycled plastic | Not because it has 100% recycled plastic | Not because it’s not plastic | No, because it’s not plastic | No, because it’s not plastic |
***The prices are simulated as if the reference Bag cost €0.15 to better understand the proportional comparison. The comparison may vary depending on the type of bag. Ask our sales representatives to know the prices adapted to your products and consumption.
plastic landfill
The purpose of the special tax on non-reusable plastic containers is waste prevention and is articulated as a tax of an indirect nature that falls on the use in the Spanish territory of containers that, contain plastic, and are not reusable. This is an environmental tax.
Despite all the efforts made, the majority of plastics still end up in landfills and a still very insufficient percentage is recycled. The new law 7/2022 aims to establish taxes and regulations to reverse the situation and promote a circular economy that favors respect for the environment.
Non-reusable plastic items
The new law establishes two new taxes: one on waste disposal and another on products that meet these three properties:
- That are “Containers”
- That are made of “Plasticnot recycled”
- That are “Not reusable”
Most of the products marketed by Multisac meet these three characteristics, so they are largely affected by this tax.
In any case, we have alternatives that also help preserve the environment and are totally or partially exempt from the new tax.
Primary, secondary and tertiary packaging
The Law generally considers a “Container” all articles designed to contain, protect, manipulate, distribute, and present merchandise.
The components that form part of them are also considered “Packaging”, but paints, inks, lacquers, and adhesives designed to be incorporated into the packaging are not subject to the tax.
Both those that are full and those that are empty, as well as primary, secondary, and tertiary containers, are considered “Containers”.
The Law does not consider “Packaging” to be the components of a product that are necessary to contain, support, or preserve it throughout its useful life, and all its elements are intended to be used, consumed, or disposed of together, for example, the casing of a pen.
Big Bag made from 100% recycled material from Multisac
The Law considers all containers that are totally or partially made of plastic to be plastic.
To encourage the recycling of plastic and its use, recycled plastic is not affected by the tax associated with this law. Therefore, for the calculation of the tax, only the amount of non-recycled plastic included in any non-reusable packaging should be considered.
Packaging that contains some recycled material is subject to tax only on the % of non-recycled plastic material it contains.
In this way, packaging that is 100% recycled is not subject to the tax.
What does The Law consider to be ''Non-reusable''? Those designed this way, not those used this way.
Reusable Bag
The Law considers and defines that packaging is “Reusable” when it has been conceived, designed, and marketed to perform multiple circuits or rotations throughout its life cycle or to be refilled or reused for the same purpose for which it was designed.
It is important to note that considering something “Reusable” is based on the intention and design the product was created for, instead of the use that the final customer makes of it.
This detail is important when considering whether Small Bags, Big Bags, and Fabrics are “Reusable” or “Non-Reusable”.
Multisac supplies more ecological alternatives that are not subject to the tax such as Diaper Bags, reusable Big Bags, rPet Big Bags, Reusable Bags, Jute Bags, Recycled Bags…
The concept “Reusable” is not linked to the concept “Returnable”.
The tax collected should also cover investments in infrastructure to truly promote the circular economy
The tax is very high: €0.45/Kg for non-recycled plastic.
The tax will have a great impact on the industry and on the end user, but ultimately it is logical that it is an amount high enough to make it “advisable” to use more ecological and sustainable alternative products, thus modifying the consumption habits of society in general.
The tax collected must cover the amounts, which in turn, Spain must pay to the EU for the use of plastic packaging and, additionally, should be invested in infrastructures that truly allow and promote a circular economy and environmentally friendly, such as collection points and centers for specific plastics (PP, PE, PET, PVC…) for effective recycling. There is no news about the latter.
The taxable event falls on any of these assumptions regarding containers that, containing non-recycled plastic, are non-reusable:
- Fabrication
- Importing
- Intra-community acquisition
In any of the cases, it is Multisac who must properly calculate and settle the tax to the Tax Agency according to each of the 3 assumptions.
One of the objectives of the Law is to discourage the USE of non-reusable plastic containers, therefore, the tax must reach the end USER. Multisac (as manufacturer, importer, and/or intra-Community purchaser) is obliged by the Law itself to charge the tax explicitly and in detail on its invoices or to do so through a certificate that its clients can request.
-The tax information detailed on the invoice or certificate must be at least the following:
-The total weight in kilos of non-recycled plastic of the containers supplied.
-The calculation of the stated weight multiplied by the tax, that is, Kg of non-recycled plastic x €0.45/Kg.
Any exemption provided by law that could be applied and justified.
Multisac always shows the broken-down amounts of the tax in its offers and invoices to provide its clients with a possible refund if it applies to them.
In any case, the mandatory impact of the tax does not exempt us from our commitment to environmental sustainability, so we encourage the reduction of the use of non-reusable plastic with alternative products made of other materials and with the increasing use of percentages of recycled products in our raw materials.
Multisac customers are not required to explicitly charge the tax to their sales invoices. In any case, the acquisition cost of these products will now be higher for our clients, and thus our clients (and in turn yours cyclically) must consider it to be passed on to the final price, without any breakdown like the rest of the costs. The cost passed along the entire value chain will reach the end user in the end.
In any case, what should be impacted and encouraged throughout the value chain (and not just the end user) is the commitment to sustainability and the environment, progressively eliminating the use of non-recycled and non-recycled plastic. reusable. In this way, an effective circular economy is created, respectful and friendly to natural resources.
For products that Multisac may have already acquired in Spain, it must also act as described in the previous paragraph, forming part of the aforementioned value chain.
Impact of the tax on the value chain
Big Bags for medicines
In particular, containers used for:
- Medicines are exempt from tax.
- Medical devices.
- Foods for special medical uses.
- Formulations for infants for hospital use.
- Hazardous waste of health origin.
- Plastic rolls for silage for agricultural and livestock use.
If the Multisac customer has been passed on with products intended for these special uses, they can request a refund of the passed-on tax.
The following products or in the following situations, the tax should not apply:
- Reusable plastic containers. (e.g. Reusable bags)
- The recycled plastic contained in the packaging. (e.g. Recycled Big Bag and Small Bags)
- Plastic rolls are used in bales or bales for silage of forage or cereals for agricultural or livestock use. (e.g. PP Tubes)
- The intra-community acquisition (not others) of containers intended to be sent directly by the intra-community purchaser, to a territory other than that in which the tax is applied.
- The intra-community acquisition (no other) of containers that are no longer suitable for use or have been destroyed.
- Small imports or intra-community acquisitions of packaging whose total amount of non-recycled plastic contained in the packaging does not exceed 5 kilograms per month.
- Non-reusable containers that are modified to be reused from then on.
- Semi-finished plastic containers will not be used to obtain non-reusable containers containing plastic.
The law aims to discourage the use of non-recycled plastic, that is, it forces manufacturers and importers to pass on the tax, and suggests that the same be done throughout the value chain up to the end user. Therefore, the easiest way for our clients to recover the tax is to pass it on (optionally) to their clients.
If there is a commercial return from the client to Multisac, the client must also receive a refund of the amount paid for the tax.
Additionally, there are cases where Multisac clients can request a refund of the tax paid by the public administration.
- If the customer delivers the products purchased from Multisac outside of Spain (Article 81.1.d)
- If the customer uses the purchased products to be used as containers for medicines, medical devices, food for special medical uses, infant formula for hospital use or hazardous waste of health origin (Article 81.1.e)
- If the client makes any modification to the product that is not reusable, it becomes reusable (Article 81.1.f)
- If the client purchases semi-finished products subject to tax that are NOT intended to obtain products subject to tax (Article 81.1.g.1)
- If the client acquires products intended for the closing, marketing or presentation of containers subject to the tax that were NOT ultimately intended to obtain products subject to the tax (Article 81.1.g.2)
The refund must be requested using Form A22 and must be properly accredited.