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Substantial transformation


According to Australian Consumer Law (Schedule 2 of the Competition and Consumer Act 2010), a food is substantially transformed in a country when either:

  • each of its significant ingredients was grown in that country and all, or virtually all, processing  occurred in that country
  • as a result of one or more processes undertaken in that country, the product is fundamentally different in identity, nature or essential character from all of its ingredients or components that were imported into that country

Visit our product labelling page to discover more information about country of origin food labelling.

Examples of substantial transformation

Product Australian ingredient/ component Imported ingredient/ component Substantially transformative or material process/change Primary reason why it is considered to be substantial transformation
Cake Sugar, eggs, flour Spice Mixing and bakin The imported ingredients (spices) are fundamentally different from, and do not have the identity, nature or essential character of the finished product (cake)
Apple pie Pastry, suga Apples, spice Forming a pie and bakin The imported ingredients (apples, spices) are fundamentally different from, and do not have the identity, nature or essential character of the finished product (apple pie)
Frozen crumbed prawn Prawns, eg Crumbs, spice Cultivating and shelling prawns and raising chickens (from which eggs are, gathered) before crumbin The imported ingredients (crumb, spices) are fundamentally different from, and do not have the identity, nature or essential character of the finished product (frozen crumbed prawns)
Frozen battered seafood snac Flour, eggs, water (to form batter Prawns, squid, seasonin Mincing, mixing, forming and batterin The imported ingredients (seafood) are fundamentally different from, and do not have the identity, nature or essential character of the finished product (frozen battered seafood snack)

Examples of what isn’t substantial transformation

Product Australian ingredient/ component Imported ingredient/ component Substantially transformative or material process/change Primary reason why it is NOT considered to be substantial transformation
Canned apricot Syru Apricot Peeling, cooking and cannin The imported ingredients (fresh apricots) are not fundamentally different from, retain their identity and nature, and have the essential character of the finished product (canned apricots)
Orange juic Water, sugar, preservative Orange juice concentrat Reconstitutio The imported ingredient (orange juice concentrate) is not fundamentally different from, retains its identity and nature, and has the essential character of the finished product (orange juice)
Frozen crumbed prawn Crumb, eg Prawns, spice Crumbing, packing, freezin The imported ingredients (prawns) are not fundamentally different from, retain their identity and nature, and have the essential character of the finished product (frozen crumbed prawns)
Mashed pea   Pea Mashing and packin The imported ingredients (peas) are not fundamentally different from, retain their identity and nature, and have the essential character of the finished product (mashed peas)

Read next

Use the country of origin labelling tool to help you develop your own standard mark or country of origin statement.

Learn about country of origin food labelling and how to maintain compliance.