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HMRC internal manual

VAT Food

Items benefiting from the relief: What is food?: Food and medicine: Parenteral nutrition (PN)

Where a patient’s gastrointestinal tract is wholly non-functional, nutrition is administered intravenously by means of parenteral (i.e. outside the intestinal tract) preparations. Total parenteral nutrition solutions (TPN) are formulated to supply the patient’s complete nutritional requirements. They use a balance of

  • essential and non-essential amino acids (the active constituents of protein),
  • carbohydrate (generally one or more of a combination of glucose, sorbitol or alcohol),
  • vitamins, and / or
  • fat in the form of lipids.The liability of parenteral nutrition products is judged by the same criteria as “normal” food. Those which provide sufficient nutritional value to be considered the equivalent of a meal are zero-rated; those which simply provide a vitamin or mineral supplement are treated in the same way as vitamin and mineral supplements taken orally and standard-rated.

To be treated as “food” a PN solution would have to contain:

  • amino acids (either alone or with vitamins and minerals); or
  • amino acids together with carbohydrates; or
  • carbohydrate (e.g. glucose); or
  • lipids. Other combinations are possible. These solutions will normally be large volume preparations of 100 ml - 1000 ml with, typically, 500 ml - 1000 ml given to an adult over 24 hours.

Supplementary products consisting of single vitamins and / or vitamin-mineral mixes are standard-rated. These are generally small volume preparations (typically 10 ml - 20 ml) and do not contain significant amounts of nitrogen or carbohydrate.

Most intravenous glucose solutions are eligible for zero-rating as parenteral nutrition products. However, low level glucose solutions (e.g. 5% -10%) are generally not administered for their nutritional content, but are used as carriers for antibiotics etc, added in the hospital immediately before administration. These carrier solutions are not food, and are standard-rated.

Glucose is also used, in injection, to counter hypoglycaemia (e.g. in diabetic coma). Preparations designed for this application are medicinal not nutritional, and standard-rated. They will normally be supplied in small quantities of less than 100 ml, often in ready-to-use pre-filled syringes; if you are in any doubt, the accompanying promotional material will identify the intended use of the product.