Is substantial transformation based on the whole product or just imported ingredients?

Food businesses have become increasingly aware of the complexity of the concept of substantial transformation under Australia’s Country of Origin Labelling framework. Whether a product has been substantially transformed will greatly impact the origin claim that the product is able to make. But what exactly does one compare when determining whether a product has been substantially transformed? Should you be looking not only at the final step of transformation of the overall product but also the effect of the imported component of ingredients in the transformation?