Medical VAT Win for Chamber International’s Affiliate Partner

2 November 2023


HMRC has made it easier to export certain medical and veterinary-related goods at zero-rate VAT, if they are to be used in charitably-funded activities. This change follows lobbying from Chamber International affiliate partner GAMBICA, Britain’s trade association for the instrumentation, control, automation and lab-tech industries.

More than two years ago, GAMBICA started receiving complaints from its members about HMRC guidance on the eligibility for VAT relief of equipment or services purchased for medical or veterinary research. As a result of lobbying, the majority of GAMBICA’s recommendations have been incorporated in the new version of the guidance.

Ben Sunderland, from CAMLAB, and a member of GAMBICA’s VAT group, said, “The new VAT Notice 701/6 clarifies many ambiguities introduced by the previous update versions, in particular to amendments made in the list of examples of qualifying goods.”

“In particular, any medical or veterinarian equipment used in research, diagnosis and treatment funded by charitable donations, or by individual registered charities, can be considered for zero rate VAT by the supplier of these goods. This is a significant 20% cost saving for those eligible bodies on tight research funds.”

Thermo Fisher’s Louise Scattergood, also a member of GAMBICA’s VAT group, said, “The work done by GAMBICA members to facilitate these changes has been done on behalf of universities and hospitals across the UK. It will make research funds go considerably further, as well as making the process simpler and clearer for research institutions and their suppliers.”

Changes in the new VAT Notice

Some of the difficulties with the previous VAT Notices focused on Personal Protective Equipment (PPE). Such equipment can be essential to protect researchers as well as patients, but the last edition of the VAT Notice disallowed dual-use products labelled both as a medical device and as PPE, two different sets of regulations often used in a clinical and medical setting.

HMRC specifically declared that nitrile gloves, including those classed as medical equipment, were ineligible for zero-rate VAT. Using examples of alternative materials used for medical and surgical gloves, GAMBICA’s VAT Group persuaded HMRC that the intended us of the product should be considered, rather than the specific material of manufacture. The same argument regarding material of manufacture was used to include lab plasticware under the Laboratory Glassware definition.

The new VAT Notice, issued on 6 October, makes it clear that gloves can be eligible for VAT relief if they are used in a ‘medical’ or ‘surgical’ capacity, and that PPE can be eligible for zero-rating where it is an accessory to the equipment, or required for its safe use (e.g. cryogenic gloves or surgical masks). It is the supplier’s responsibility to provide the evidence, usually obtained from the manufacturer, to support the declaration claim within the prescribed definitions of Notice 701/6.

In addition, the following items have now been added to the list of examples, given in the VAT Notice, of items which are eligible for zero-rate VAT:

Aprons, Cryogenic

Laboratory glassware or plasticware

Batteries for eligible equipment (if bespoke)

Laboratory ovens

Biosafety cabinets

Masks, medical or surgical




Needles, suture

Furnace, laboratory

Scanner, MRI, CAT

Gloves cryogenic


Gloves, medical or surgical


Gloves, nitrile medical or surgical

Sinks, specialised laboratory

Gowns, medical or surgical 

Test tube racks

The new notice also clarifies about the eligibility of laboratory ‘consumables.’ It makes explicit that reagents and substances, including liquids, powders, sheets or pellets, may be eligible for relief under VAT Notice 701/1.

Extra help from GAMBICA

GAMBICA has developed additional guidance, including a consensus position on items not specifically mentioned in the examples given in HMRC’s new VAT Notice 701/6 (the ‘Grey Items’ list), and a decision-making flow chart to help both suppliers and customers decide what can be zero-rated. These will be made available on the GAMBICA website.

GAMBICA is asking members to provide information on decisions made by HMRC inspectors during VAT audits, to ensure there is consistency of application.

It may not be easy to determine if goods qualifying for zero-rating. Exporters can apply directly to HMRC for a non-statutory clearance.


Chamber International is a preferred supplier to GAMBICA.

Chamber International’s customs compliance experts are on hand to assist with import and export issues, and can help you avoid costly non-compliance. Contact us with your query.


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