News on Excise and environmental taxes

As a follow-up to the news of November 4, 2025, regarding the prohibition of marketing derivative beverages with old tax stamps attached from January 1, 2026, please remember that if on that date you have derivative beverages in containers and/or receptacles that incorporate tax stamps other than those required, in order to market them you will have to attach the new tax stamp models. You must contact the Management Office corresponding to your establishment, which will inform you of the necessary procedures for requesting and supplying them.

Information Note NI 22/2025, dated November 4, from the Department of Customs and Special Taxes, has been published on the control of residues with alcoholic content from yeast obtained in the beer manufacturing process, within the scope of the Special Tax on this product.  The measures set out in this note will be enforceable from April 1, 2026.

From January 1, 2026, it will only be permitted to market derivative beverages in containers and/or receptacles that incorporate the new models of tax marks approved by Order HAC/1271/2019, of December 9, which have a QR code with information of tax relevance.

Measures are introduced TARIC of this tax for those two tariff items (flavors or salts), which implies the need to record the corresponding code in the data sub-element 18 09 060 "nationalAdditionalCode" of the import document H1 ("S" when circulation under a suspension regime is applicable or "N" when it is an import of products not included in the objective scope of the Tax on Liquids for Electronic Cigarettes and other Tobacco-related Products.)

Both tariff items have also been included in the EMCS internal in order to be able to circulate the aforementioned products under a suspension regime when appropriate.

A query of the stock of products at the end of each month is available, in which the stock at the end of the months of January to June 2025 is provided, deducted from the entries provided in SILICON 2.0 until 01/09/2025.

Starting September 1, 2025, new validations are included that affect the presentation of accounting entries and the stock ledger for the Special Tax on Non-Reusable Plastic Packaging and the Tax on Fluorinated Greenhouse Gases. The accounting entry registration forms provide instructions for properly completing the aforementioned accounting entries and record books.

Under current regulations, the regularization of stocks stored for commercial purposes is not required as of April 1, 2025. When this obligation becomes enforceable, the appropriate dissemination and information will be given through the Electronic Headquarters of the AEAT and other communication channels available without the need to have a CAE in order to be able to present the corresponding self-assessment (form 573) within the period regulated.

A webinar will be held on July 21, 2025, from 9:30 a.m. to 1:00 p.m., to provide information on the main new features and modifications implemented in the stock accounting system for products subject to excise duties (SILICIE), specifically with reference to the obligations of small wineries. The questions posed below will be answered.

The official program of the informational seminar is included in the attached PDF document.

On June 30, 2025, the transitional period provided for in the sole transitional provision of Order HAC/1505/2024, of December 26, which modifies Order HAC/998/2019, of September 23, regulating compliance with the obligation to keep accounting records for products subject to Special Manufacturing Taxes, ended.

Consequently, as of July 1, 2025, all accounting entries for the 2025 financial year must be submitted via SILICIE 2.0. From July 1, 2025, it will no longer be possible to provide accounting entries for 2025 in the SILICIE 1.0 version.

The transitional period provided for in the sole transitional provision of Order HAC/1505/2024, of December 26, amending Order HAC/998/2019, of September 23, regulating compliance with the obligation to keep accounting records for products subject to Special Manufacturing Taxes, ends on June 30, 2025.

Consequently:

• Those who opted for the transitional period before June 30, 2025, must provide accounting entries for the first half of 2025 in the SILICIE 2.0 version.

• As of 01-07-2025, all accounting entries corresponding to the 2025 fiscal year must be provided through SILICIE 2.0.