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HMRC internal manual

VAT Health

Blood and associated products: Scope of the relief

  1. Human blood

Supplies of human blood are exempt where there is a consideration. Donations of blood or plasma are outside the scope.

  1. Human organs and tissue

It is illegal to sell organs for transplantation. Although organs may be supplied for medical research or for diagnostic or therapeutic purposes, they are rarely supplied by way of business. If they are, they will be covered by the exemption. Due to advances in medicine and technology, it is more common now for human organs and tissue to be supplied for the therapeutic substances which can be extracted from them. In these cases, both the supply of the organ and the supply of the extracted therapeutic substance will be exempt. Teaching exhibits, skeletons and curiosities such as shrunken heads are not covered by the exemption and are standard rated.

  1. Products for therapeutic purposes derived from human blood

For a product to be exempt, it must be:

* derived from human blood; and
* intended “for therapeutic purposes” - i.e. to be administered to a patient.

All drugs and therapeutic substances contain one or more “active” ingredients and are administered to a patient because of the benefits that those ingredients will bring. They also contain non-active ingredients which do not bring direct medical benefit but serve only as a carrier or excipient - for example to make the product easier to inject. You will have to ascertain the nature of the active ingredients to determine the liability of the supply.

Products can be exempt only if they contain a single active ingredient which is wholly derived from human blood. The addition of simple dilutants or preservatives or any other product - blood or otherwise - as a non-active ingredient will not affect exemption but the product will be standard rated if it contains:

two or more active ingredients, but only one of which is derived from human blood; or

one active ingredient but that active ingredient is not derived from human blood. This is so even if the product contains a blood product as a non-active ingredient - for example, in recombinant products, the active ingredient is genetically engineered and the carrier is the blood product, human albumin.

Examples of blood products which are covered by the exemption when supplied as the active ingredient are:

  • Blood plasma (fresh or dried);
  • Plasma protein fraction;
  • Haemoglobin;
  • Globulin;
  • Albumin (fresh or dried);
  • Human Factor VIII fraction;
  • Human Factor IX fraction (partial and total prothrombin complexes);
  • Fibrinogen;
  • Thrombin;
  • Normal and specific immunoglobulins;
  • Plasmin; and
  • Plasminogen
  • Products which are wholly or partly of animal origin are not covered by the exemption.
  1. Products for diagnostic purposes

Blood products such as blood-grouping and tissue typing reagents are often used in diagnostic tests carried out in laboratories, for example to test for diseases such as diabetes and jaundice. Products packed or held out for sale for these purposes (which are often in kit form) are not covered by the exemption but are taxable at the standard rate. Supplies in bulk which could eventually be used either for therapeutic or diagnostic purposes may be assumed to be mainly for therapeutic use and are thus exempt.