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Prevention: Food labelling

Health Star Rating System: proposed improvements

Last updated 06-06-2019

A formal five-year review into the Health Star Rating System is currently underway. Independent consultants made a series of recommendations in a draft review report released in February 2019. The draft report recommended some improvements sought by public health and consumer groups however some key concerns remain.

Key Evidence

01

Rules around products not consumed ‘as sold’ (e.g. Milo) are due to change

02

The draft review recommended a 5-star rating for fruit and vegetables

03

Public health and consumer groups want the system to be mandatory

Public health and consumer groups in Australia support front-of-pack interpretive labelling such as the Health Star Rating system. The Australian Chronic Disease Prevention Alliance* says such systems are a way of improving consumer awareness and understanding of nutritional information and encouraging healthier food choices.1 There is evidence that the Health Star Rating System is creating behaviour change,2 and the George Institute says the system is performing well overall.3

While generally supportive of the Health Star Rating System, public health and consumer groups sought a range of improvements to the system in submissions to a formal five-year review conducted by an independent consultancy. After considering 483 public submissions, the consultants made a series of recommendations in a draft of the five-year review report released in February 2019.4 After considering further feedback, the consultants will provide a final report to the Australian and New Zealand Ministerial Forum on Food Regulation in mid-2019. Ministers are due to respond to the report and its recommendations in late 2019.

There has already been movement on one issue, with Australian and New Zealand Health Ministers with responsibility for food regulation agreeing in June 2018 to limit application of Health Star Ratings to products ‘as sold’.

For products that are not intended to be consumed ‘as sold’, Health Star Ratings could previously be calculated for the product ‘as prepared’ according to the instructions on the packaging. On this basis, the sugary chocolate and malt powder Milo could claim a Health Star Rating of 4.5 stars (when prepared with three teaspoons of Milo in a glass of skim milk).

Under the tightened rules limiting application of Health Star Ratings to products ‘as sold’, specific exemptions will apply for products which must be rehydrated with water (such as powered soups), diluted with water, drained of water or drained of brine.5 The tightened rules are to be implemented as part of the outcomes of the five-year review.


Source: Nestle Australia

Key recommendations of the draft five-year review that address concerns of public health and consumer groups

1. Changing the way Health Star Ratings are calculated to better align with dietary guidelines by:

  • Giving a Health Star Rating of 5 for fruit and vegetables that are fresh, frozen or canned without added fat, sugars or sodium
  • Increasing the Health Star Ratings of ‘five food group’ dairy foods (such as yoghurts and cheeses), while reducing the ratings for less healthy alternatives.

2. Ongoing promotion to position Health Star Ratings in the context of broader healthy eating messages

Some consumers perceive the Health Star Rating System as promoting processed foods over a healthy, balanced diet that is consistent with the Australian Dietary Guidelines.3 Obesity researcher Dr Kieron Rooney, quoted in the Sydney Morning Herald, cites the example of the 4.5 star-rated Up and Go breakfast drink. “Look at the long list of ingredients, with at least four sources of added sugars. This is an ultra-processed industrialised product and not as the Health Star Rating and marketers would have you believe – a healthy alternative to eating a simple, unprocessed breakfast,’’ he said.6 The Obesity Policy Coalition has argued that significant funds are needed to promote the key messages of the Health Star Rating System firmly in the context of a healthy, balanced diet,2 while the Australian Chronic Disease Alliance1 and George Institute3 have also called for consumer education to be strengthened.

The review said initial narrow campaign messaging had been adjusted to promote the Health Star Rating System in the context of healthy eating more broadly and recommended that this continue over the next two years. It recommended that promotion also target specific areas of consumer misunderstanding, such as by clarifying that not only healthy foods carry Health Star Ratings and emphasising that the system should only be used to compare products within a category.

3. Strengthening supportive resources

The review recommended regular updates to the dietary guidelines and national health and nutrition surveys, and establishment of a dataset of branded food products.

4. Removing the energy icon option

The review noted that the energy icon is not well understood by consumers and does not provide sufficient information to support choice. It stated that the energy icon is most often used on non-dairy beverages and confectionery and that, in those categories, health stars are also used making it difficult for consumers to compare products.

Improvements sought by public health and consumer groups that were not included in the recommendations of the draft five-year review

1. Changing the way Health Star Ratings are calculated for sugars

a. The review acknowledged that many stakeholders advocated for the inclusion of added or free sugars in the Health Star Rating System to better align with dietary guideline recommendations to reduce intake of added sugars. The review recommended strengthening the negative impact of total sugars rather than introducing the concept of added sugars, largely due to the complexity involved. Public health and consumer groups continue to advocate for the inclusion of added sugar in the Health Star Rating System, particularly given that Food Ministers are concurrently assessing whether added sugars should be included on food labels.

b. The review suggested a strengthening of the impact of total sugars in the Health Star Rating calculator. Given the review noted sugar as the “most significant area of stakeholder concern” with the Health Star Rating calculator, public health stakeholders contended that there should be further strengthening of the impact of total sugars, beyond that recommended in the review.7

2. Changing the way Health Star Ratings are calculated with regard to protein

The review did not recommend measures to reduce the impact of protein in the calculation of the Health Star Rating and expressed the view that changes to sugar and sodium better target products of concern. Public health groups contended that reducing the impact of protein would reduce the ability for less healthy products to increase their Health Star Rating through protein.8

3. Changing the way Health Star Ratings are calculated for some beverages

Several public health stakeholders felt the Health Star Rating was not working optimally for beverages but had concerns about changes proposed in the review. The review found that while Health Star Ratings for sugar-sweetened soft drinks tended to be appropriately low, higher ratings were needed to encourage consumption of low or sugar-free flavoured waters or other drinks that were closer in nutritional value to water. Changes proposed to the calculator for these products would mean that a Health Star Rating of 5 for plain waters, 4.5 for unsweetened flavoured waters, between 2.5 and 4 for fruit and vegetable juices (based on sugars and energy content), and between 0.5 and 2 for sugary soft drinks.

Several public health stakeholders had two significant reservations about these changes. The first concern was that some fruit juices still scored highly under the model proposed. The second concern was that unintended consequences may arise from the broad range of substances (such as artificial sweeteners) allowed to be added to unsweetened, flavoured waters that would receive a Health Star Rating of 4.5.7

4. Making the system mandatory

Only about 31% of eligible products on supermarket shelves feature a Health Star Rating.4 The voluntary nature of the Health Star Rating system has resulted in variable uptake between product categories, and even within them. Food manufacturers are displaying ratings on products that score most highly and omitting ratings from products with lower scores.9 For example, an Obesity Policy Coalition (OPC) survey of snack bars found that more than 63% did not display Health Star Ratings and these were the least healthy options, with some brands using stars only on their higher rating products.2

Groups including the Australian Medical Association, Royal Australasian College of Physicians, OPC, the Australian Chronic Disease Alliance, the George Institute, the Public Health Association of Australia and consumer group CHOICE have called for Health Star Ratings to be made mandatory for all packaged foods. The review recommended the system continue as a voluntary scheme, but the government should set a target for Health Star Ratings to be displayed on 70% of products by the end of 2023.

* Alliance comprises: Heart Foundation, Cancer Council Australia, Kidney Health Australia, Diabetes Australia and Stroke Foundation.

References

1. Australian Chronic Disease Prevention Alliance. Consultation on the five-year review of the Health Star Rating system. Sydney, Australia 2017. Available from: https://docs.wixstatic.com/ugd...
2. Obesity Policy Coalition. Submission to the 5-year review of the Health Star Rating system. Melbourne, Australia 2017. Available from: http://www.opc.org.au
3. The George Institute for Global Health. Submission to the 5 year review of the Health Star Rating system. 2017. Available from: https://www.georgeinstitute.org.au/sites/default/files/hsr-submission-aug17.pdf
4. mp consulting. Health Star Rating System Five Year Review Report. 2019. Available from: https://consultations.health.gov.au/
5. Commonwealth of Australia. Health Star Rating System webpage - Form of the Food (‘As Prepared’) Rules. 2018. Available from: http://healthstarrating.gov.au
6. FitzSimons P. 'It's freaking hopeless': why the Health Star Rating System has to go. Sydney Morning Herald, 2017. Available from: https://www.smh.com.au/opinion/its-freaking-hopeless-the-health-star-rating-system-has-to-go-20170611-gwp0mb.html
7. The George Institute, Submission to the 5 year review of the Health Star Rating System, Sydney, Australia, 2019. Available from: https://www.georgeinstitute.or...
8. Obesity Policy Coalition, Submission to the 5 year review of the Health Star Rating, Melbourne, 2019.
9. Australia and New Zealand Ministerial Forum on Food Regulation. Final Communique 29 June 2018. Canberra, Australia 2018. Available from: http://foodregulation.gov.au