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A product can claim to have been last substantially transformed in a country if:

  1. it was ‘grown’ or ‘produced’ in that country, or
  2. processing in that country has resulted in an end product that is fundamentally different from its imported ingredients or components in either:
  • identity or
  • nature or
  • essential character.


The following would be a substantial transformation:

  • the mixing and baking of raw imported ingredients into food items e.g. combining butter, sugar, flour and eggs and baking a cake

  • moulding imported sheet metal into a car panel

  • building a table from imported wood.

The following wouldn't be a substantial transformation:

  • chopping up imported fruit to make a fruit salad

  • printing a design onto an imported t-shirt

  • cutting blocks of imported soap into individual bars.

This means that businesses should be careful when making a 'made in' claim about products with imported ingredients or components. If processing in that country hasn't clearly resulted in a new product with identifiably different characteristics you are at risk of breaching the ACL.

For example, if the processing undertaken has only served to add decorative elements or 'finish off' the product (like adding buttons onto an imported jacket or browning imported par-baked bread), this would not be enough to support a 'made in' claim.