Private ruling: GST and waterproof bedding products
Date of advice: 5 March 2026
Published: 20 April 2026
Ruling period: 1 January 2026 to 31 March 2030

Ruling: Q1: Are Entity A's supplies of the following products (collectively, the Health Waterproof Protectors) GST-free under subsection 38-45(1) of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act): (a) Mattress Protector 1 and Mattress Protector 2; and (b) Mattress Protector 3; and (c) Mattress Protector 4; and (d) Mattress Protector 5; and (e) Mattress Protector 6; and (f) Mattress Protector 7; and (g) Mattress Protector 8; and (h) Pillow Protector 1 and Pillow Protector 2; and (i) Pillow Protector 3; and (j) Pillow Protector 4 and Pillow Protector 5; and (k) Pillow Protector 6; and (l) Pillow Protector 7; and (m) Pillow Protector 8; and (n) Quilt Protector 1; and (o) Quilt Protector 2? | A1: Yes, Entity A's supplies of the Health Waterproof Protectors are GST-free under subsection 38-45(1) of the GST Act.

Relevant facts and circumstances: Entity A is registered for GST. Entity A is in the business of manufacturing and selling bedding products and accessories, including mattress protectors, pillow protectors, quilt protectors, linen protectors, bed pads and chair pads. Entity A's Health Waterproof Protectors are specifically designed for people with, and not widely used by people without, an illness or disability. The products are specifically designed to protect a mattress from incontinence. These products have distinct manufacturing characteristics. The Health Waterproof Protectors are solely sold through healthcare channels and are not sold to general bedding stores, department stores or via commercial channels. Entity A does not have any agreements with the recipient of their supplies to treat their products as taxable.

Relevant legislative provisions: A New Tax System (Goods and Service Tax) Act 1999 section 38-45 | A New Tax System (Goods and Service Tax) Act 1999 section 182-10 | A New Tax System (Goods and Service Tax) Act 1999 section 182-15 | A New Tax System (Goods and Service Tax) Act 1999 Schedule 3

Reasons for decision: Summary: Supplies of certain medical aids and appliances are GST-free. Subsection 38-45(1) of the GST Act states: (1) A supply is GST-free if: (a) it is covered by Schedule 3 (medical aids and appliances), or specified in the regulations; and (b) the thing supplied is specifically designed for people with an illness or disability, and is not widely used by people without an illness or disability. Entity A's supplies of the Health Waterproof Protectors are GST-free under subsection 38-45(1) of the GST Act if all three of the following requirements are satisfied: (a) It is covered by Schedule 3 to the GST Act or the GST Regulations; and (b) It is specifically designed for people with an illness or disability; and (c) It is not widely used by people without an illness or disability. Where a medical aid or appliance satisfies all of the requirements above, the supply is GST-free throughout the supply chain and not only when supplied to a person who has an illness or disability, [1] unless the supplier and the recipient agree to treat the supply as if it were taxable pursuant to subsection 38-45(3) of the GST Act. Entity A does not have any agreements with the recipients of your supplies to treat the Health Waterproof Protectors as taxable. Accordingly, subsection 38-45(3) of the GST Act is not relevant. We have considered all of the Health Waterproof Protectors together to determine if they are covered by Schedule 3 to the GST Act or the GST Regulations for the purposes of paragraph 38-45(1)(a) of the GST Act before considering the other requirements under subsection 38-45(1) of the GST Act. | Detailed Reasoning - Are the Health Waterproof Protectors covered by Schedule 3 or the GST Regulations?: Paragraph 38-45(1)(a) of the GST Act requires for the thing to be covered by the list of medical aids and appliances in Schedule 3 to the GST Act or the A New Tax System (Goods and Services Tax) Regulations 2019 (GST Regulations). Item 16 of Schedule 3 to the GST Act (Item 16) lists 'waterproof covers or mattress protectors'. Item 16 is a cover or mattress protector that is designed to prevent liquid from passing through the material. The essential character of each of the Health Waterproof Protectors is that of a mattress, pillow or quilt cover designed to prevent liquid from passing through the material to the mattress, pillow or quilt underneath. Each of these protectors are waterproof. Therefore, all of the Health Waterproof Protectors are 'waterproof mattress protectors' for the purposes of Item 16, satisfying paragraph 38-45(1)(a) of the GST Act. We have considered each Health Waterproof Protectors individually to determine if they: (a) are identical to another one of your products; and (b) satisfy the design and use tests under paragraph 38-45(1)(b) of the GST Act. | Detailed Reasoning - Are Mattress Protector 1 and Mattress Protector 2 identical to another one of Entity A's products?: The supply of the same, or an identical product, is GST-free irrespective of who it is supplied to and at all points in the supply chain. Entity A supply several products with similar physical characteristics across different brands and retail channels. When assessing each product to determine whether it satisfies subsection 38-45(1) of the GST Act, it is necessary to determine whether any of the products are the supply of the same 'thing'. If two or more products are the same 'thing', then, irrespective of any differences in marketing, branding or labelling, those products must be considered together for the purposes of applying subsection 38-45(1) of the GST Act. Whether the 'thing' supplied for the purposes of subsection 38-45(1) of the GST Act is different from, or identical to, another item will depend on the facts and circumstances in each case. If two products are identical, they must be considered together when determining whether the requirements in subsection 38-45(1) of the GST Act are satisfied. While not definitive, we take an objective view of the physical functions, characteristics and attributes of the goods to determine whether the physical functions, characteristics and attributes of two or more goods are identical, irrespective of their labelling, description or marketing. Although the name, packaging or marketing of a good may be used to emphasise differences between products, these factors tend to be of lesser importance in determining whether the product is identical. Therefore, it is relevant to ascertain whether there are differences in their physical materials, technical specifications or composition of two or more goods that appear to be similar. Where two or more goods have the same or identical physical functions, characteristics and attributes, we regard them as the supply of the same 'thing' for the purposes of subsection 38-45(1) of the GST Act. Where two or more goods are the same 'thing', the manner in which they are marketed and the types of outlets through which they are supplied must then be considered in their totality when determining whether the product satisfies the requirements in subsection 38-45(1) of the GST Act. As they constitute the supply of the same 'thing', the goods will have the same GST classification. Accordingly, if you merely change the name or packaging of one of your products, without altering any physical functions, characteristics or attributes of the product, the product will retain the same GST classification. For example, merely changing the care instructions or packaging for a product to distinguish the product across different retail channels without any changes to the physical functions, characteristics or attributes of the product will not result in a different GST classification. Each rebranded iteration of the product must be considered together when determining whether the requirements under subsection 38-45(1) of the GST Act are satisfied. Additionally, where a product shares the same physical functions, characteristics or attributes but is available in different sizes according to the size of the mattress (e.g., king, queen, single, etc.), the same GST classification applies to each size as they are essentially the same product. Based on the information provided, we consider that Mattress Protector 1 and 2 are identical to each other. | Detailed Reasoning - Specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability: In determining whether a product is specifically designed for people with an illness or disability and not widely used by people without an illness or disability requires the consideration of the product itself, its design objectives, and both its intended and actual use. These two tests are questions of fact and degree. The Commissioner's view on how the key elements under subsection 38-45(1) of the GST Act are interpreted can be found in GSTD 2021/2. [2] | Detailed Reasoning - 'Specifically designed for' test: Whether an item is 'specifically designed for' people with an 'illness or disability' is determined by application of the 'essential character' test. That is, by objectively considering the design features and characteristics of the product. [3] In the context of section 38-45 of the GST Act, '... the task ... is to determine the essential character of the goods, what essentially the goods are, not some characteristic that the goods might have'. [4] Reference should be made to the designer's or manufacturer's intention of how the good is to be used and it's features. The intended use of the product is to be determined by objective consideration of all the evidence, including how it is marketed and by reference to the type of outlets through which the product is sold. Where there is no direct evidence of the designer's or manufacturer's design purpose, marketing material and other commercial information can be drawn on as a proxy indicator. The word 'specifically' in paragraph 38-45(1)(b) of the GST Act does not mean 'exclusively' or 'solely'. The Oxford Dictionary of English (3 ed.) defines 'specifically' as follows: adverb 1. in a way that is exact and clear; precisely: a workman called at the time I specifically stated I would not be in | the problem was specifically mentioned in the report | [sentence adverb]: censorship, or more specifically the banning of books, is a threat to the freedom of speech. for a particular purpose: books created specifically for children | some collectors maintain spaces specifically to house their larger works of art. The Macquarie Dictionary defines 'specific' as follows: adjective 1. having a special application, bearing, or reference; specifying, explicit, or definite: specific mention . A thing that has (or is designed for) some special application does not necessarily deny that it may also have (or be designed for) some other incidental application. The question is whether the primary design focus or feature is for people with an illness or disability, as opposed to design features which are equally for and beneficial to people with and without an illness or disability. Paragraph 7 of GSTD 2021/2 provides: [5] Specifically designed 7. The following factors are a non-exhaustive list of matters you should take into account when considering whether a particular product is specifically designed for people with an illness or disability: • An objective view of the design features and characteristics of the product indicate whether its essential character is that it is specifically designed for people with an illness or disability. • The designer's or manufacturer's intention of how the particular product is to be used. Indicators of the designer's or manufacturer's intention include an objective consideration of how the product is marketed and the type of outlets at which the product can be purchased. Based on the information provided, we consider that Mattress Protector 1 and 2 are specifically designed for people with an illness or disability. The first test under paragraph 38-45(1)(b) of the GST Act is satisfied. | Detailed Reasoning - 'Not widely used by' test: Whether an item is 'not widely used' by people without an illness or disability is a question of degree and judgment. Paragraphs 8 to 10 of GSTD 2021/2 provides: [6] Not widely used 8. The phrase 'not widely used' is not defined in the GST Act. It therefore takes its ordinary meaning, having regard to the context in which it appears. It is a question of degree whether a product is not widely used by people without an illness or disability. The Commissioner considers that it is reasonable to conclude that the test is not satisfied if the product is widely purchased by or on behalf of people without an illness or disability, without the need to examine how this class of people in fact use the product. 9. In the context of paragraph 38-45(1)(b), the Commissioner considers 'not widely used' to mean not used by many people who do not have an illness or disability. 10. The following factors will be relevant, but are not an exhaustive list, when considering whether a product is widely used by people without an illness or disability: • The product is widely sold in retail or other outlets that predominantly sell standard beds (that is, beds that do not have features specifically designed for people with an illness or disability) to the general public. • The marketing material for the product emphasises how it enhances the lifestyle of people without an illness or disability. Based on the information provided, we are satisfied that Mattress Protector 1 and 2 are not widely used by people without an illness or disability. The second test under paragraph 38-45(1)(b) of the GST Act is satisfied. | Detailed Reasoning - Conclusion: Entity A's supplies of Mattress Protector 1 and 2 are GST-free under subsection 38-45(1) of the GST Act. | Detailed Reasoning - Is Mattress Protector 3 identical to another one of Entity A's products?: We consider the reasons discussed above about determining whether the 'thing' supplied for the purposes of subsection 38-45(1) of the GST Act is the same or identical applies equally to Mattress Protector 3. Based on the information provided, we consider that Mattress Protector 3 is not identical to other products sold by Entity A and is not the supply of the same 'thing' for the purposes of subsection 38-45(1) of the GST Act. | Detailed Reasoning - Specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability: We consider the reasons above about when something is specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability applies equally to Mattress Protector 3. Based on the information provided, we consider that Mattress Protector 3 is specifically designed for people with an illness or disability and is not widely used by people without an illness or disability. The two tests under paragraph 38-45(1)(b) of the GST Act are satisfied. | Detailed Reasoning - Conclusion: Entity A's supply of Mattress Protector 3 is GST-free under subsection 38-45(1) of the GST Act. | Detailed Reasoning - Is Mattress Protector 4 identical to another one of Entity A's products?: We consider the reasons discussed above about determining whether the 'thing' supplied for the purposes of subsection 38-45(1) of the GST Act is the same or identical applies equally to Mattress Protector 4. Based on the information provided, we consider that Mattress Protector 4 is not identical to other products sold by Entity A and is not the supply of the same 'thing' for the purposes of subsection 38-45(1) of the GST Act. | Detailed Reasoning - Specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability: We consider the reasons above about when something is specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability applies equally to Mattress Protector 4. Based on the information provided, we consider that Mattress Protector 4 is specifically designed for people with an illness or disability and is not widely used by people without an illness or disability. The two tests under paragraph 38-45(1)(b) of the GST Act are satisfied. | Detailed Reasoning - Conclusion: Entity A's supply of Mattress Protector 4 is GST-free under subsection 38-45(1) of the GST Act. | Detailed Reasoning - Is Mattress Protector 5 identical to another one of Entity A's products?: We consider the reasons discussed above about determining whether the 'thing' supplied for the purposes of subsection 38-45(1) of the GST Act is the same or identical applies equally to Mattress Protector 5. Based on the information provided, we consider that Mattress Protector 5 is not identical to other products sold by Entity A and is not the supply of the same 'thing' for the purposes of subsection 38-45(1) of the GST Act. | Detailed Reasoning - Specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability: We consider the reasons above about when something is specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability applies equally to Mattress Protector 5. Based on the information provided, we consider that Mattress Protector 5 is specifically designed for people with an illness or disability and is not widely used by people without an illness or disability. The two tests under paragraph 38-45(1)(b) of the GST Act are satisfied. | Detailed Reasoning - Conclusion: Entity A's supply of Mattress Protector 5 is GST-free under subsection 38-45(1) of the GST Act. | Detailed Reasoning - Is Mattress Protector 6 identical to another one of Entity A's products?: We consider the reasons discussed above about determining whether the 'thing' supplied for the purposes of subsection 38-45(1) of the GST Act is the same or identical applies equally to Mattress Protector 6. Based on the information provided, we consider that Mattress Protector 6 is not identical to other products sold by Entity A and is not the supply of the same 'thing' for the purposes of subsection 38-45(1) of the GST Act. | Detailed Reasoning - Specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability: We consider the reasons above about when something is specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability applies equally to Mattress Protector 6. Based on the information provided, we consider that Mattress Protector 6 is specifically designed for people with an illness or disability and is not widely used by people without an illness or disability. The two tests under paragraph 38-45(1)(b) of the GST Act are satisfied. | Detailed Reasoning - Conclusion: Entity A's supply of Mattress Protector 6 is GST-free under subsection 38-45(1) of the GST Act. | Detailed Reasoning - Is Mattress Protector 7 identical to another one of Entity A's products?: We consider the reasons discussed above about determining whether the 'thing' supplied for the purposes of subsection 38-45(1) of the GST Act is the same or identical applies equally to Mattress Protector 7. Based on the information provided, we consider that Mattress Protector 7 is not identical to other products sold by Entity A and is not the supply of the same 'thing' for the purposes of subsection 38-45(1) of the GST Act. | Detailed Reasoning - Specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability: We consider the reasons above about when something is specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability applies equally to Mattress Protector 7. Based on the information provided, we consider that Mattress Protector 7 is specifically designed for people with an illness or disability and is not widely used by people without an illness or disability. The two tests under paragraph 38-45(1)(b) of the GST Act are satisfied. | Detailed Reasoning - Conclusion: Entity A's supply of Mattress Protector 7 is GST-free under subsection 38-45(1) of the GST Act. | Detailed Reasoning - Is Mattress Protector 8 identical to another one of Entity A's products?: We consider the reasons discussed above about determining whether the 'thing' supplied for the purposes of subsection 38-45(1) of the GST Act is the same or identical applies equally to Mattress Protector 8. Based on the information provided, we consider that Mattress Protector 8 is not identical to other products sold by Entity A and is not the supply of the same 'thing' for the purposes of subsection 38-45(1) of the GST Act. | Detailed Reasoning - Specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability: We consider the reasons above about when something is specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability applies equally to Mattress Protector 8. Based on the information provided, we consider that Mattress Protector 8 is specifically designed for people with an illness or disability and is not widely used by people without an illness or disability. The two tests under paragraph 38-45(1)(b) of the GST Act are satisfied. | Detailed Reasoning - Conclusion: Entity A's supply of Mattress Protector 8 is GST-free under subsection 38-45(1) of the GST Act. | Detailed Reasoning - Is Pillow Protector 1 and Pillow Protector 2 identical to another one of Entity A's products?: We consider the reasons discussed above about determining whether the 'thing' supplied for the purposes of subsection 38-45(1) of the GST Act is the same or identical applies equally to Pillow Protectors 1 and 2. Based on the information provided, we consider that Pillow Protectors 1 and 2 are identical to each other. We also consider that Pillow Protector 1 and 2 is not identical to other products sold by Entity A. Therefore, Pillow Protectors 1 and 2 must be considered together for the purposes of subsection 38-45(1) of the GST Act. | Detailed Reasoning - Specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability: We consider the reasons above about when something is specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability applies equally to Pillow Protectors 1 and 2 Based on the information provided, we consider that Pillow Protectors 1 and 2 is specifically designed for people with an illness or disability and is not widely used by people without an illness or disability. The two tests under paragraph 38-45(1)(b) of the GST Act are satisfied. | Detailed Reasoning - Conclusion: Entity A's supply of Pillow Protectors 1 and 2 is GST-free under subsection 38-45(1) of the GST Act. | Detailed Reasoning - Is Pillow Protector 3 identical to another one of Entity A's products?: We consider the reasons discussed above about determining whether the 'thing' supplied for the purposes of subsection 38-45(1) of the GST Act is the same or identical applies equally to Pillow Protector 3. Based on the information provided, we consider that Pillow Protector is not identical to other products sold by Entity A and is not the supply of the same 'thing' for the purposes of subsection 38-45(1) of the GST Act. | Detailed Reasoning - Specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability: We consider the reasons above about when something is specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability applies equally to Pillow Protector 3. Based on the information provided, we consider that Pillow Protector 3 is specifically designed for people with an illness or disability and is not widely used by people without an illness or disability. The two tests under paragraph 38-45(1)(b) of the GST Act are satisfied. | Detailed Reasoning - Conclusion: Entity A's supply of Pillow Protector 3 is GST-free under subsection 38-45(1) of the GST Act. | Detailed Reasoning - Is Pillow Protector 4 and Pillow Protector 5 identical to another one of Entity A's products?: We consider the reasons discussed above about determining whether the 'thing' supplied for the purposes of subsection 38-45(1) of the GST Act is the same or identical applies equally to Pillow Protectors 4 and 5. Based on the information provided, we consider that Pillow Protectors 4 and 5 are identical to each other. We also consider that Pillow Protector 4 and 5 is not identical to other products sold by Entity A. Therefore, Pillow Protectors 4 and 5 must be considered together for the purposes of subsection 38-45(1) of the GST Act. | Detailed Reasoning - Specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability: We consider the reasons above about when something is specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability applies equally to Pillow Protectors 4 and 5 Based on the information provided, we consider that Pillow Protectors 4 and 5 is specifically designed for people with an illness or disability and is not widely used by people without an illness or disability. The two tests under paragraph 38-45(1)(b) of the GST Act are satisfied. | Detailed Reasoning - Conclusion: Entity A's supply of Pillow Protectors 4 and 5 is GST-free under subsection 38-45(1) of the GST Act. | Detailed Reasoning - Is Pillow Protector 6 identical to another one of Entity A's products?: We consider the reasons discussed above about determining whether the 'thing' supplied for the purposes of subsection 38-45(1) of the GST Act is the same or identical applies equally to Pillow Protector 6. Based on the information provided, we consider that Pillow Protector 6 is not identical to other products sold by Entity A and is not the supply of the same 'thing' for the purposes of subsection 38-45(1) of the GST Act. | Detailed Reasoning - Specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability: We consider the reasons above about when something is specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability applies equally to Pillow Protector 6. Based on the information provided, we consider that Pillow Protector 6 is specifically designed for people with an illness or disability and is not widely used by people without an illness or disability. The two tests under paragraph 38-45(1)(b) of the GST Act are satisfied. | Detailed Reasoning - Conclusion: Entity A's supply of Pillow Protector 6 is GST-free under subsection 38-45(1) of the GST Act. | Detailed Reasoning - Is Pillow Protector 7 identical to another one of Entity A's products?: We consider the reasons discussed above about determining whether the 'thing' supplied for the purposes of subsection 38-45(1) of the GST Act is the same or identical applies equally to Pillow Protector 7. Based on the information provided, we consider that Pillow Protector 7 is not identical to other products sold by Entity A and is not the supply of the same 'thing' for the purposes of subsection 38-45(1) of the GST Act. | Detailed Reasoning - Specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability: We consider the reasons above about when something is specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability applies equally to Pillow Protector 7. Based on the information provided, we consider that Pillow Protector 7 is specifically designed for people with an illness or disability and is not widely used by people without an illness or disability. The two tests under paragraph 38-45(1)(b) of the GST Act are satisfied. | Detailed Reasoning - Conclusion: Entity A's supply of Pillow Protector 7 is GST-free under subsection 38-45(1) of the GST Act. | Detailed Reasoning - Is Pillow Protector 8 identical to another one of Entity A's products?: We consider the reasons discussed above about determining whether the 'thing' supplied for the purposes of subsection 38-45(1) of the GST Act is the same or identical applies equally to Pillow Protector 8. Based on the information provided, we consider that Pillow Protector 8 is not identical to other products sold by Entity A and is not the supply of the same 'thing' for the purposes of subsection 38-45(1) of the GST Act. | Detailed Reasoning - Specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability: We consider the reasons above about when something is specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability applies equally to Pillow Protector 8. Based on the information provided, we consider that Pillow Protector 8 is specifically designed for people with an illness or disability and is not widely used by people without an illness or disability. The two tests under paragraph 38-45(1)(b) of the GST Act are satisfied. | Detailed Reasoning - Conclusion: Entity A's supply of Pillow Protector 8 is GST-free under subsection 38-45(1) of the GST Act. | Detailed Reasoning - Is Quilt Protector 1 identical to another one of Entity A's products?: We consider the reasons discussed above about determining whether the 'thing' supplied for the purposes of subsection 38-45(1) of the GST Act is the same or identical applies equally to Quilt Protector 1. Based on the information provided, we consider that Quilt Protector is not identical to other products sold by Entity A and is not the supply of the same 'thing' for the purposes of subsection 38-45(1) of the GST Act. | Detailed Reasoning - Specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability: We consider the reasons above about when something is specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability applies equally to Quilt Protector 1. Based on the information provided, we consider that Quilt Protector 1 is specifically designed for people with an illness or disability and is not widely used by people without an illness or disability. The two tests under paragraph 38-45(1)(b) of the GST Act are satisfied. | Detailed Reasoning - Conclusion: Entity A's supply of Quilt Protector 1 is GST-free under subsection 38-45(1) of the GST Act. | Detailed Reasoning - Is Quilt Protector 2 identical to another one of Entity A's products?: We consider the reasons discussed above about determining whether the 'thing' supplied for the purposes of subsection 38-45(1) of the GST Act is the same or identical applies equally to Quilt Protector 2. Based on the information provided, we consider that Quilt Protector 2 is not identical to other products sold by Entity A and is not the supply of the same 'thing' for the purposes of subsection 38-45(1) of the GST Act. | Detailed Reasoning - Specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability: We consider the reasons above about when something is specifically designed for people with an illness or disability, and not widely used by people without, an illness or disability applies equally to Quilt Protector 2. Based on the information provided, we consider that Quilt Protector 2 is specifically designed for people with an illness or disability and is not widely used by people without an illness or disability. The two tests under paragraph 38-45(1)(b) of the GST Act are satisfied. | Detailed Reasoning - Conclusion: Entity A's supply of Quilt Protector 2 is GST-free under subsection 38-45(1) of the GST Act. [1] Although the GST classification applies to the product throughout the supply chain, a private ruling only applies to the applicant of the private ruling. [2] See also Goods and Services Tax Industry Issues Pharmaceutical Health Forum Medical aid or appliance specifically designed for people with an illness or disability and Goods and Services Tax Industry Issues Pharmaceutical Health Forum Medical aid or appliance widely used by people without an illness or disability. [3] As considered in the sales tax case of Commissioner of Taxation of the Commonwealth of Australia v Thomson Australian Holdings Pty Ltd [1989] FCA 382 ( Thompson) at [4]. [4] Snugfit Australia Pty Ltd and Commissioner of Taxation [2013] AATA 802 at [10] confirmed that the 'essential character' test from Thompson is equally applicable in the context of section 38-45 of the GST Act. [5] See also Goods and Services Tax Industry Issues Pharmaceutical Health Forum Medical aid or appliance specifically designed for people with an illness or disability. [6] See also Goods and Services Tax Industry Issues Pharmaceutical Health Forum Medical aid or appliance widely used by people without an illness or disability.