The issue concerning non-derived representations (Adams and Aizawa also speak here of non-derived contents) is complex (see Clark (2005) (2008) for discussion) but one point to notice is that such contents/representations are indeed present (assuming the idea is coherent, as I now think it is) in the putative overall cognizing system comprising bio-stuff and further resources. So the real question here concerns the acceptability of derived representations or contents as genuine elements in a cognitive process that quite clearly involves many non-derived ones too.In first part of this comment, Andy has in mind the fact that when Otto uses his notebook, A&A will maintain that there are representations bearing non-derived content in Otto's brain, even if there are representations bearing only non-derived content in Otto's notebook. So, requiring that cognitive processes involve non-derived content or non-derived representations won't do anything to show that Otto provides an instance of extended cognitive processing.
I think Andy's point here is well taken. He draws attention to a weakness in the way A&A have formulated the non-derived content condition. It is not enough to say that cognitive processing must involve non-derived content; it is not enough to say that non-derived content must be present in a cognitive process. Something a bit stronger, or more explicitly stronger, appears to be needed. So, I think the thing to say is that the cognitive vehicles of representation must bear non-derived content. The representational vehicles in Otto's notebook don't satisfy this condition. Maybe there is some problem with this as well, but there you have it.
I've commented on this point before here. It's also in print as footnote #10 in my paper, "The Coupling-Constitution Fallacy Revisited" in Cognitive Systems Research.