[Global IDT Insights] IRA Clarifies Reduced VAT on Medical Dressings and Food Supplements

Editorial Team – [2026] 185 taxmann.com 428 (Article)

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1. Italian Revenue Agency Clarifies Reduced VAT Applicability to Medical Dressings and Food Supplements

Italy has clarified that the sale of products used as primary dressings for the treatment of acute and chronic wounds, including those infected or at risk of infection, is subject to a reduced VAT rate of 10 percent. The same reduced rate is also applicable to food supplements that meet specified requirements under the VAT framework.

The clarification has been issued by the Italian Revenue Agency (IRA) based on the technical opinion of the Customs and Monopolies Agency (Agenzia delle Dogane e dei Monopoli), which examined the products under two separate inquiries. The applicability of the reduced VAT rate has been determined on the basis of the customs classification assigned by the Customs authority.

Reduced VAT applicability to medical dressings classified under heading 3004

(a) Request by company engaged in medical devices sector for classification and rate applicability – The clarification arises from a request made by a company operating in the medical devices sector, engaged in the development, preparation, packaging, distribution, and wholesale and retail sale of products intended for the treatment of skin lesions.

(b) Product characterised as therapeutic medical device without pharmacological action – The product in question is described as a spreadable preparation used as a primary dressing for the treatment of acute and chronic wounds, including those infected or at risk of infection. The company sought clarity in the context of classification of such products.

The product is identified as a medical device intended for human use with a clearly therapeutic purpose, as it helps treat or alleviate skin lesions. However, it does not qualify as a medicinal product in the strict sense, as it does not contain active pharmacological ingredients or vital biological substances. Further, it does not act through pharmacological, immunological, or metabolic mechanisms.

(c) Conclusion based on Customs classification under CN code 3004 90 00 enabling reduced VAT rate – The clarification confirms that an assessment conducted by the Customs authority, including laboratory analysis, is essential for determining eligibility. The product has been classified under CN code 3004 90 00, which refers to medicinal products consisting of mixed preparations intended for therapeutic or prophylactic use and marketed in doses or for retail sale.

The substances contained in the preparation are considered to exert beneficial effects, justifying classification as ‘other medicinal preparations’ under heading 3004, and meeting the requirements of Supplementary Note 1 to Chapter 30 of the Combined Nomenclature. Accordingly, based on this classification, the IRA concludes that the product qualifies for the reduced VAT rate of 10 percent.

Reduced VAT applicability to food supplements classified under headings 2106 and 1806

(a) Request by company engaged in research, production and distribution of food supplements – The clarification arises from a request made by an Italian company engaged in the research, production, and distribution of innovative medical devices.

(b) Products comprising food supplements and nutritional preparations in various forms – The products in question comprise a series of food supplements and preparations intended for sports or functional nutrition, presented in various forms such as powders, capsules, tablets, and bars.

(c) Classification under heading 2106 enabling reduced VAT under item 80 – In respect of products classified under heading 2106, the Explanatory Notes to the Harmonized System provide that supplements based on vitamins, amino acids, minerals, or extracts, packaged as supplements to normal nutrition and lacking sufficient active ingredients to confer therapeutic purposes, are to be classified under code 2106.

Additional Note 5 to Chapter 21 further includes preparations presented in measured doses intended for use as food supplements, provided they cannot be classified under more specific headings. It is also noted that none of the products fall under syrup subheadings, which are excluded unless governed by specific legislation. Accordingly, such products fall within item 80 of Table A, Part III, of the VAT decree and qualify for the reduced VAT rate of 10 percent.

(d) Classification under heading 1806 enabling reduced VAT under item 64 – For products classified under heading 1806, relating to chocolate and food preparations containing cocoa, the classification arises due to the presence of cocoa, which precludes classification under heading 2106. The identified subheadings include preparations such as beverage mixes containing cocoa and bars with added cereals or fruit. Under item 64 of Table A, Part III, such products are eligible for the reduced VAT rate of 10 percent, provided they are not packaged in premium forms.

(e) Conclusion based on customs classification enabling reduced VAT rate – Based on the technical classifications provided by the Customs and Monopolies Agency, the IRA concludes that products classified under heading 2106 as well as those under heading 1806 meet the conditions specified under Table A, Part III, of the VAT decree. Accordingly, both categories of products are eligible for the reduced VAT rate of 10 percent.

Source – Clarification by IRA

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