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HMRC internal manual

VAT Food

Excepted items: pet food and wild bird food: products used for feeding fish

Since they are kept primarily for ornament, most fish kept by private individuals are classed as pets for VAT purposes. This classification would include both fish kept in aquaria in the home (such as tropical fish and goldfish) and garden pond fish (such as Koi carp). Other fish are farmed on a commercial basis, salmon and trout being the species most commonly used for this purpose - the UK trout and salmon farming industry currently accounts for about 95% of the total production of farmed fish.

There is a wide range of fish food products on the market, but they can basically be divided into two main categories.

  • Dry diets are compounded diets produced as a powder, granules or pellets of various sizes. They basically contain fish meal or refined fish protein together with various additives such as carbohydrates (soya, cereal), specific amino acids, minerals, etc. These are all carefully blended to meet the specific nutritional requirements of the target species of fish.
  • Live foods include a wide variety of both aquatic and terrestrial insect larvae (such as mosquito larvae, bluebottle or maggots), oligochaete worms (such as earthworms, tubiflex or blood worms) and both freshwater and marine crustaceans such as daphnia and artemia (brine shrimps). Daphnia and artemia are also widely sold frozen or freeze-dried.

Food for farmed fish

The industry uses dry compounded diets based on fish meal (60-70%) as the protein source. The small amount of carp farming for the table also uses trout and salmon diets or dry diets compounded specially for the carp species. Commercial farming of fish for the table rarely involves the use of live food, as it is relatively expensive and the quantity involved makes it economically impractical. One exception is turbot farming, which uses live artemia for the early fry rearing stages. However, the UK industry is currently very small, and this constitutes a very minor application.

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Food for pet fish

The pet fish trade utilises dry compounded diets in the form of granules and flakes and live foods, particularly artemia, which is widely supplied for marine ornamentals. The amount of dry foods produced for the pet trade is relatively small compared with that produced for the trout and salmon industry, but the specification is usually much higher (depending on the species) and it is therefore more expensive.

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The VAT liability of food for fish follows the normal rules, according to whether the fish species involved is a pet, non-pet or mixed species. Dry compounded diets blended specifically for pet fish (usually in granular or flake form) are therefore standard-rated, while those blended for farmed fish are zero-rated. You should usually have little difficulty in distinguishing between them. Fish food, like other animal feed, is covered by the Animal Feeding Stuffs Regulations, and details of the composition of the feed and the species of fish for whom it is intended will be carried on the packaging or on supporting documentation.

Live food other than artemia is supplied virtually exclusively for ornamentals, and is therefore pet food. However, it would only be standard-rated if it is canned, packaged or prepared which, given the nature of the product, is unlikely.

Live artemia are fed to farmed fish in the early stages of rearing, as well as to pet fish, and are therefore not considered to be pet food.

Frozen or freeze-dried artemia, daphnia etc are prepared pet food and standard-rated.