My client is a dog food manufacturer selling his food as working dog food. His working dog food is produced by buying in fresh human grade meats, mincing or cutting it into chunks and packaging it for sale as working dog food, the packaging also stating that the product is not for human consumption. Can the sale of this product qualify for zero-rating as working dog food?
The sale of working dog food is zero-rated but HMRC’s guidance at section 6.4 of VAT Notice 701/15 and VFOOD8560 clearly shows that there is a two-test approach for a product to be considered to be ‘working dog food’. The first test is that the product is specially formulated to provide working dogs with the additional energy and nutrients they require to perform. The second is that it is held out for sale as working dog food with the packaging clearly demonstrating this and that the product is not suitable for non-working dogs.
In this client’s case the packaging may well meet the second test. However, the product itself is simply human grade meat that has been repackaged and rebranded as working dog food. It has had no additional processes applied to it or additives added to it; it is simply meat in its original state. Therefore it cannot be said to have been “specially formulated” and does not pass the first test.
It will therefore not qualify for zero-rating as working dog food (or as human food, for that matter, as the packaging clearly states “not for human consumption) and is therefore standard-rated as pet food.
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