Importing blood, research substances and animals: HMRC releases new guidance in response to COVID-19

Liaison Financial

HMRC has released updates regarding imports of blood, other human derivatives, animals and other substances for research purposes, in response to the endeavours being made to tackle COVID-19.

Whereas relief from duty and import VAT for PPE items was a new measure released by HMRC, the guidance referred to below is a reminder of reliefs that are already available. The products do not have to be used in relation to COVID-19, although the measures are intended to help reduce the costs incurred in tackling the virus.

The measures work to secure relief from import duty and VAT and require the appropriate coding to be notified on import documentation. This is usually a function undertaken on behalf of an NHS importer by their freight forwarder or customs agent. There are instructions available for securing the relief if goods are imported by post or in baggage.

For importing animals for scientific research, the key conditions are:

For relief from import duty, the animals:

• must have been bred for the purpose of scientific research
• cannot be subsequently lent, sold or transferred

For relief from import VAT, in addition to the above conditions, the animals must be supplied to the NHS free of charge. For further guidance, please see the current HMRC publication on importing animals for scientific research.

For importing substances for biological and chemical research, relief is only available on import of the specific items listed in HMRC’s update, which can be found on the HMRC website.

For importing human blood products, HMRC has not changed its existing guidance, but again has reminded of the VAT relief available to avoid unnecessary costs throughout the coronavirus outbreak.

The specific items eligible for relief include human blood and derivatives, blood grouping reagents (of any origin) and tissue type reagents (of any origin). Please see this publication from HMRC.

If the NHS directly imports these items, they should not incur import duty or relief.

If the NHS is not the importer, but acquires these products from a UK supplier, VAT should not be charged on human blood and derivatives, as these products benefit from VAT exemption when supplied in the UK. However, VAT will still be charged on reagents as there is no VAT exemption for these products.

If your NHS organisation would like further advice on the import duty and VAT relief available, please speak to your Liaison Financial VAT Advisor, or contact us on 0845 603 9000 or via email at info@liaisongroup.com