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HMRC internal manual

VAT Food

HM Revenue & Customs
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Items benefiting from the relief: What is food?: Food of a kind used for human consumption: Food as nourishment

To most people, food is something eaten (or drunk) for nourishment or enjoyment. It would not include products which are consumed for any remedial or medicinal effect they might have. Medicinal products, such as indigestion remedies or senna teas, are therefore not within Group 1. However, a product would not necessarily be excluded from relief as food simply because it is marketed on the premise (real or imagined) that it is healthy or will do you good: see section VFOOD1600on medicinal products.

Since most people would see food as primarily a source of nourishment, we would normally expect a food product to have some measurable nutritional content - although, in the case of minor food ingredients, this may contribute only a small amount to the finished product. However, this is not always true - there are a number of food flavourings which, while we allow them to be zero-rated as food, have no nutritional content at all.

Conversely, it is also certainly not true that all products with nutritional content would be classed as food: to take an extreme case, even deadly nightshade has a nutritional content, but it would never be considered a food. While nutritional content may therefore be a pointer, it should not be the only test used.