Accessory versus component part distinction denied customs exemption for imported camera cassettes.

Imported multi-image cassettes were held to be accessories, not component parts, of a multi-format camera, so exemption under the customs notification was denied. The Tribunal found that the camera was a complete product without the cassettes, which were separately obtained and used only for holding film. Applying the distinction between a component part and an accessory, it ruled that an item necessary for use is not part of the machine unless it enters into its composition. Prior concessional clearances did not create a binding entitlement for later imports, and estoppel or res judicata did not control the assessment.

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Issues: Whether the imported multi-image cassettes were component parts of the multi-format camera so as to qualify for exemption under the customs exemption notification.

Analysis: The relevant notification, as amended, extended exemption to component parts of the listed medical equipment. The Tribunal examined the nature of the imported cassettes and the surrounding literature and found that the camera was a complete product even without the cassettes, which were separately obtained and used with the camera for holding film. Applying the distinction between a component part and an accessory, the Tribunal held that an item required for use of a machine is not necessarily part of the machine if it does not enter into its composition. The fact that earlier consignments had been cleared at a concessional rate did not create a binding entitlement for later imports, and principles akin to estoppel or res judicata were held not to govern the assessment.

Conclusion: The imported cassettes were accessories and not component parts of the camera, and exemption under the notification was not available.

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