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HMRC internal manual

VAT Construction

HM Revenue & Customs
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Building materials - Note 22 and Note 23: electrical and gas appliances: examples of appliances and non-appliances

The following explains our view on items powered by electricity where doubts as to their classification often arise:

  • aerials and satellite dishes are not electrical appliances
  • gates and garage doors - the decision in Michael McCarthy and Georgina McCarthy t/a Croft Homes (VTD 16789) has confirmed that electrically operated gates are ‘electrical appliances’ and are therefore not ‘building materials’. The Tribunal stating:

    …we find that [electrically operated gates] are electrical appliances because they are operated by electricity (we do not think it relevant that they can be operated manually in the event of a power cut), although we should add that we did not have a proper description of the electric gates to see to what extent they were an appliance and what extent a gate. The fact that a door-entry system for a building designed as a number of dwellings is included in Note (22) suggests that an electric gate is an electric appliance. It may be possible in some cases to make an apportionment between the gates and the electrical appliance operating them with the result that standard-rating applies only to the electrical appliance, but we do not have any information on which to do so in this case.

    The fact that an electric gate is part of the security system is not relevant. It is clearly not itself a burglar alarm within paragraph (c)(iii) of Note (22).

Electrically operated gates are typically supplied in one of two ways, namely as:

* an integral unit with, say, the gate post encompassing the operating mechanism


* separate units with the operating unit being, say merely attached to the gate by some form of lever or control arm.

In the latter case, an appropriate apportionment can be made between the gates and the electrical appliance operating them. Standard-rating applies to the electrical appliance.

A similar approach to the above is taken for garage doors

  • lights - the following are not appliances and can be treated as ‘building materials:

    • ceiling, wall and spot lights
    • garage, porch and security lights
    • light fittings, including chandeliers
    • light bulbs and diffusers for strip lights when supplied as part of the light fitting, but not lampshades that are provided separately
    • lights (as part of an intelligent lighting system). Light fittings and cabling are treated as building materials ordinarily incorporated whereas remote control handsets are not treated as such. Touch pad controls would be accepted as building materials only to the extent that they serve the purpose of lighting. Other central controls may be treated as building materials in so much as they are dedicated to light, heating and/or ventilation. In both cases where the controls cover more than these functions they will be treated as building materials subject to apportionment. If no apportionment is possible the whole supply should be standard-rated.
  • lights - the following are not appliances but can’t be treated as ‘building materials’, when incorporated in the grounds of dwellings but can when incorporated in the grounds of buildings used for a relevant residential or charitable purpose:

    • lights that illuminate access paths
    • exterior ornamental lighting, such as flood lights; other landscaping feature lights
  • power showers and jacuzzi baths - although power showers are electrical appliances, because they heat water flowing through them, they are ‘building materials’ (VCONST13750)

In addition, jacuzzi baths are ‘building materials’ because they heat and pump water around the bath

  • water pumps - the Chairman in Garndene Communications Systems Ltd (VTD 2553) said that an electric water pump fixed in the garden of a house to operate a fountain or to circulate the swimming pool in the garden would, undoubtedly be a domestic electrical appliance 

However water pumps that form part of the building’s water or heating system are ‘building materials’

  • wiring and cabling - fixed wiring, sockets, telecommunications cabling, network termination points, and so on are not electrical appliances and are ‘building materials’.