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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 and medicine: Invalid foods

There are many products designed to meet special dietary requirements, such as the promotion of weight gain in convalescent or elderly patients, or to provide an adequate liquid diet where, because of damage to or disease of the gastrointestinal tract, solid food cannot be taken. These products are often provided under medical supervision, or even on prescription, and are usually in liquid form. Since they are supplied solely to meet an individual’s nutritional requirements, such products are food for VAT purposes and eligible for zero-rating unless they fall within one of the excepted items.

Meal replacement drinks falling within the above category, that are designed to provide for an individual’s complete nutritional requirements, are not considered to be beverages.

Other products are not complete meal replacements, but simply a specialised form of a normal food product, designed to cater for people with particular allergies or intolerance of one or more of the ingredients found in the normal equivalent. Gluten-free and diabetic products fall within this category. These products are not medicated foods and are treated for VAT purposes in exactly the same way as the equivalent normal food product: they are zero-rated unless they fall within one or other of the excepted items.