Private ruling: GST and supply of grain protein powder
Date of advice: 16 September 2025
Published: 17 November 2025

Ruling: Q1: Is the supply of Grain Protein Powder (the Product) GST-free pursuant to section 38-2 of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act)? | A1: Yes. A supply of food is GST-free under section 38-2 of the GST Act if the product satisfies the definition of food in section 38-4 of the GST Act and the supply is not excluded from being GST-free by section 38-3 of the GST Act. The supply of the Product is GST-free under section 38-2 of the GST Act because:

Relevant facts and circumstances: • You are registered for GST. • You are importing the Product to be supplied to your customer who uses the Product for their flour mix. • The Product is sold in a bulk bag of a specific weight. • The Product is not for retail sale. It is a food ingredient for further processing. • The Product specification sheet describes it as 100% grain protein that is suitable for food application. The composition of the Product is 100% grain protein concentrate without any additives. The Product has a particular colour. The Product is bland and has its own flavour. The particle size is a specific mesh (approximately). • The Catalogue lists the various applications of the Product. • The Product is used to improve the nutritional value of a product. • You provided a picture of the Product and the processing flow chart.

Relevant legislative provisions: A New Tax System (Goods and Services Tax) Act 1999 section 38-2 | A New Tax System (Goods and Services Tax) Act 1999 section 38-3 | A New Tax System (Goods and Services Tax) Act 1999 section 38-4


the Product satisfies the definition of food in paragraph 38-4(1)(a) of the GST Act as food for human consumption and | the supply of the Product does not fall within any exclusions in section 38-3 of the GST Act.