Laerdal Medical Pty Ltd and Comptroller-General of Customs

In the matter of *Laerdal Medical Pty Ltd and Comptroller-General of Customs*, Deputy S A Forgie P considered a dispute concerning the customs classification of certain goods. Laerdal Medical Pty Ltd sought to classify the subject goods, which house automated external defibrillators (AEDs), under Heading 9018.90.00 as accessories to defibrillators. The Comptroller-General of Customs contended that the goods were not accessories.

The central legal issue before the court was to determine whether the subject goods, designed to house and present AEDs, qualified as accessories to those defibrillators for the purposes of customs classification. This required the court to apply established principles regarding the definition of an accessory, particularly in the context of customs law, and to assess the functional relationship between the subject goods and the AEDs they contained.

The court applied a series of principles derived from previous authorities, including that an accessory is not determined by analogy but by principle, and that specific design for use with another item does not automatically make it an accessory. The court noted that while an accessory need not be physically joined to the main item, it must be a subordinate part or object added for the convenience or effectiveness of that other item, or essential to its operation. In this instance, the court found that the subject goods, while making the AED visible and providing storage, did not enhance the AED's performance, convenience, or effectiveness. The goods did not rely on the AED for their operation, nor did the AED rely on the goods for its functionality. Consequently, the court was not satisfied that the subject goods were accessories to the AEDs.

As the court was not satisfied that the subject goods were accessories to defibrillators, they did not fall for classification under Heading 9018.90.00. The court indicated that it would proceed to consider other relevant headings, specifically Headings 9402 and 9403, before considering Heading 4202.