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

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 Spices Mixing and baking The imported ingredients (spices) are fundamentally different from, and do not have the identity, nature or essential character of the finished product (cake).
Apple pies Pastry, sugar Apples, spices Forming a pie and baking 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 prawns Prawns, egg Crumbs, spices Cultivating and shelling prawns and raising chickens (from which eggs are, gathered) before crumbing 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 snack Flour, eggs, water (to form batter) Prawns, squid, seasoning Mincing, mixing, forming and battering 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 apricots Syrup Apricots Peeling, cooking and canning 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 juice Water, sugar, preservatives Orange juice concentrate Reconstitution 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 prawns Crumb, egg Prawns, spices Crumbing, packing, freezing 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 peas   Peas Mashing and packing 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).