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HMRC internal manual

VAT Food

Items benefiting from the relief: animal feeding stuffs: introduction and background

Group 1 of Schedule 8 to the VAT Act 1994 allows zero-rating for animal feeding stuffs generally, but specifically excludes pet food that is canned, packaged or prepared and packaged wild bird food from that general relief (see VFOOD0200). VFOOD3000 looks at the legal references to animal feeding stuffs, the reasons for the relief for animal feeding stuffs, and the reason for the exclusion of pet food from this relief.

The decision to allow relief for animal feeding stuffs was taken in order to zero-rate a major component of the production of food for human consumption, so removing tax from the entire human food chain.

Given this intention, consideration was given to restricting relief specifically to feed for animals yielding or producing food for human consumption. However, the practical difficulties of this approach would have been immense, given that, for example, a horse (or even a zebra or giraffe in a zoo) eats similar food to cattle or sheep. It would have been necessary to introduce some form of end-use control. Given the nature of the agricultural produce industry, which operates largely through a network of brokers, end-use control would have been unworkable, because most suppliers would have no idea what species of animal their produce would eventually be eaten by. It was therefore decided to remove zero-rating from the most significant class of non-food animals by introducing an exclusion for pet food.

Pet food had been chargeable with purchase tax since 1969, so the general public were used to it being taxed; it also produced a significant and useful amount of revenue.

The wording of the exclusion is a straightforward copy of the purchase tax legislation. There have been no changes to the law in this area since the inception of VAT.