Health Star Rating System: proposed improvements
Rules around products not consumed ‘as sold’ (e.g. Milo) are due to change
Food ministers have agreed to a 5-star rating for fruit and vegetables
Public health and consumer groups want the system to be mandatory
Public health and consumer groups in Australia support front-of-pack interpretive food 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
Health Star Rating System five-year review
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 five-year review report released in February 2019.4 After considering further feedback, the consultants provided a final report to the Australia and New Zealand Ministerial Forum on Food Regulation which was released publicly in August 2019.5 In December 2019, the Ministerial Forum released a document detailing its response to each of the recommendations of the five-year review.6 Implementation timeframes are due to be considered by the food ministers’ forum in 2020.
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.7 The tightened rules are to be implemented as part of the outcomes of the five-year review.
Key accepted improvements of Health Star Rating review
The key recommendations of the five-year review of Health Star Ratings accepted by food ministers and address concerns of public health and consumer groups include:
1. Changing the way Health Star Ratings are calculated to better align with dietary guidelines:
- Giving a Health Star Rating of 5 for fruit and vegetables that are frozen or canned without added fat, sugars or sodium. Food ministers noted that this should be in addition to promoting fresh, unpackaged fruit and vegetables outside the Health Star Rating system.
- Increasing the Health Star Ratings of ‘five food group’ dairy foods (such as yoghurts and cheeses), while reducing the ratings for less healthy alternatives.
- Adjusting the algorithm underpinning the Health Star Rating System to more strongly penalise total sugar (not added sugar) and sodium.
*Food ministers will consider additional advice from the Food Regulation Standing Committee and Food Standards Australia New Zealand on the impact of these changes before making a final determination.
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.8 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.
Food ministers agreed to continue promotion of the Health Star Rating System over the next two years, subject to funding. In particular, they said it would be important to communicate the reason for changes to the Health Star Rating System in order to maintain consumer trust and understanding. Food ministers agreed that the system should be promoted in the context of healthy eating more broadly. They agreed there was a need to target specific areas of consumer misunderstanding, which consultants said included: clarifying that foods are not necessarily healthy just because they carry Health Star Ratings; and emphasising that the system should only be used to compare products within a category.
3. Strengthening supportive resources
The Health Star Rating review recommended regular updates to the dietary guidelines and national health and nutrition surveys, and establishment of a dataset of branded food products. Food ministers said they supported this recommendation, subject to funding, adding that: “… the costs associated with regular national health and nutrition surveys is known to be high and the financial viability of such a proposal will need to be assessed. Further work and substantial planning will be required to implement many of the initiatives recommended.”
4. Removing the energy icon option
The Health Star Rating 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 with stars being used on some products and others displaying only the energy icon, making it difficult for consumers to compare products. Food ministers agreed to remove the energy icon option because unlike the stars, it was not an interpretative food labelling option that provided overall guidance on products within a given category.
Improvements to the Health Star Rating System not included in the recommendations
Public health and consumer groups sought the following improvements to the Health Star Rating System that were not included in the recommendations of the five-year review.
1. Changing the way Health Star Ratings are calculated for added sugars
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.
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.9
3. Making the Health Star Rating 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.10 For example, an Obesity Policy Coalition 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, Obesity Policy Coalition, 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 within five years and, if this did not occur, the government should make the system mandatory. Food ministers accepted the recommendation that the Health Star Rating System remain voluntary and committed to “high interim and final uptake targets”, with details to be finalised as part of an implementation plan.6
* Alliance comprises: Heart Foundation, Cancer Council Australia, Kidney Health Australia, Diabetes Australia and Stroke Foundation.