The concept of substantial transformation is the basis used throughout the EU and elsewhere to define the origin of goods as being from the country where the last substantial economic change was made to them. In my view it should not be used to disguise the origin of certain products or to mislead the consumer as to the origin of raw materials.
I have made my concerns in this respect known to the EU Commission both in the context of the review being carried out by them on "Labelling, competitiveness, consumer information, better regulation for the EU" and in the Council of Ministers as well as in bilateral contact with Commissioners Fischer Boel and Kyprianou.