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HMRC internal manual

VAT Food

Items benefiting from the relief: what is food?: food ingredients and additives: gelatine, collagen and derived products

Collagen is a protein found in the connective tissue, skin and bones of mammals. It is extracted for use both

  • in foodstuffs as a thickener and texturiser, and for making sausage skins, and
  • for a number of industrial and pharmaceutical uses.

By further processing it is converted into gelatine which also has varied food and non-food uses. Both products are zero-rated, unless processed to make them unsuitable for use in food or held out for specifically non-food use (for example photographic gelatine), when they are standard-rated.

The case of Devro Ltd (EDN/91/0259) concerned a producer of sausage skins made from reconstituted naturally occurring collagen, extracted from cattle skins. Being a component of the connective tissues of meat, collagen is digestible to give nourishment, so Customs accepted that it was edible, but did not see it as a food.

The tribunal held that many things which do not look like food on their own, but are edible and incorporated into other products which are undoubtedly food, should also be regarded as food in their own right. That was the case here, so the sausage skins were zero-rated as food.