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HMRC internal manual

VAT Construction

- Building materials - Note 22 and Note 23: electrical and gas appliances: heating and ventilation appliances

Appliances are not excluded from the Note 22 definition of ‘building materials’ when they are designed to:

  • heat space or water (or both)
  • provide ventilation
  • provide air cooling
  • provide air purification


  • provide dust extraction.

These categories include:

  • cookers designed to have a dual purpose of providing space or water heating

Note: You must not accept arguments that all cookers are ‘space heaters’ because they incidentally radiate heat whilst operating. Our approach has been supported by the Tribunals in Richard Cusdin (VTD 19739) and Richard Sidgwick (TC00695).

  • built-in central vacuum cleaning systems
  • water heating and ventilation units incorporated in swimming pools.

The following electrical appliances are not heating and ventilation devices for the purposes of Note 22:

  • electrically operated window blinds that open and close automatically so as to admit or retain heat.