UK Tribunal Rules Collagen Beauty Drinks Do Not Qualify for VAT Zero-Rating

• The UK First-tier Tribunal held in Minerva Research Labs Ltd v HMRC [2026] UKFTT 1320 (TC) that collagen-based liquid products were not zero-rated food for human consumption. [marcusward.co], [claritaxnews.com]
• Although the products provided protein, energy, vitamins and minerals, the Tribunal placed greater weight on how they were marketed, presented and purchased as liquid beauty and anti-ageing products.  [taxscape.d…loitte.com], [claritaxnews.com]
• The Tribunal dismissed a claim for approximately GBP 3.64 million of output VAT covering periods from 2018 to 2022.  [marcusward.co], [kohenavocats.com]

Extended article

The UK First-tier Tribunal has ruled that a range of collagen-based liquid products did not qualify for VAT zero-rating as food of a kind used for human consumption.

Minerva Research Labs Limited had originally accounted for VAT at the standard rate but subsequently submitted a claim for overdeclared output VAT. By the time of the appeal, the claim was approximately GBP 3.64 million.  [marcusward.co]

The products supplied collagen, protein, energy, vitamins and minerals and were targeted at skin, hair, joints and muscles. The Tribunal accepted that they delivered nutritional value, but held that this factor was not sufficient to classify them as food. [claritaxnews.com]

The classification required a multifactorial assessment. Factors supporting standard rating included:

• presentation as “liquid beauty products”;
• purchase primarily for cosmetic and anti-ageing benefits;
• no marketing as a meal replacement or snack;
• use of terms such as “dose” and “treatment”;
• medicine-like packaging; and
• precautionary or warning labels not normally associated with food.  [taxscape.d…loitte.com], [claritaxnews.com]

The Tribunal concluded that the products were not food within Item 1, Group 1, Schedule 8 to the Value Added Tax Act 1994 and dismissed the appeal.

The ruling demonstrates that product ingredients and nutritional content cannot be considered in isolation. Marketing, packaging, customer purpose, sales channels and the manner in which the product is held out for sale may all influence the VAT classification.

External links

• Read the detailed case summary [claritaxnews.com]
• Review the professional VAT commentary [marcusward.co]
• Read Deloitte’s weekly VAT analysis [taxscape.d…loitte.com]
• Review the reported Tribunal decision [vatupdate.com]