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HMRC internal manual

VAT Charities

Medicinal products and substances: Relevant goods

If an article does not qualify to be regarded as “relevant goods” under items 4 and 5 a charity may attempt to obtain zero-rating for it on the grounds that it is a medicinal product.

Note 11 to Group 15 is quite explicit in excluding from the relief an instrument, apparatus or appliance. Most of the goods that fall outside the terms of Items 4 and 5 will be excluded from Item 9 on the basis of this Note.

The clear implication from Note 11 is that medicinal products which qualify for relief are capable of being consumed or otherwise absorbed into the body. Clearly a syringe would fall outside this interpretation, whereas a contraceptive pill would fall within it.