The Health Star Rating (HSR) Advisory Committee is undertaking a five year review of the HSR system, which will consider if, and how well, the objectives of the HSR system have been met, and identify options for improvements to and ongoing implementation of the system.

The HSR system is a voluntary front of pack labelling scheme that rates the overall nutritional profile of packaged food and assigns it a rating from ½ a star to 5 stars. It is a joint Australian, state and territory and New Zealand government initiative developed in collaboration with industry, public health and consumer groups. From June 2014, food manufacturers started to apply HSRs to the front of food product packaging.

Nutrition Australia submitted a response to several of the review questions, which is summarised below.

We congratulate the government for establishing the Health Star Rating and for taking feedback at this critical review point. We acknowledge the complexity of the initiative and with further changes it will be a convenient, easy to understand tool to assist consumers to make healthier choices.

Nutrition Australia considers the HSR has considerable potential as a successful public health intervention if:

• foods and drinks are scored in a way that aligns with the Australian Dietary Guidelines by scoring whole and minimally-processed foods from the five core food groups, higher than foods and drinks which are not recommended for regular consumption.

  The Federal Government’s Australian Dietary Guidelines (ADGs) recommend the types and amounts of foods we should aim to eat each day for overall health and wellbeing. This is based on the how many serves we should aim to consume from each of five core food groups each day: fruit; vegetables and legumes/beans; grain (cereal) foods; lean meats and poultry, fish, eggs, tofu, nuts and seeds and legumes/beans; milk, yoghurt cheese and/or alternatives.

  The ADG also categorises energy-dense, nutrient-poor foods and drinks as ‘discretionary items’ that are not recommended as part of a healthy, balanced diet.

  Nutrition Australia believes that the HSR does not currently score foods in a way that aligns with a recommended heathy diet according to the ADGs.

  It is imperative that any front of pack labelling scheme that aims to improve healthy eating aligns with the Australian Dietary Guidelines. The HSR should support the implementation of the ADG by steering consumerchoices towards foods from the five core food groups, and away from energy-dense, nutrient-poor discretionary items.

• the HSR was made mandatory, and for all packaged food and drink items including fresh foods (eg, fruits, vegetables and meats), and premade items, such as salads and sandwiches.

  The HSR is currently a voluntary system, and not all items have a rating. As suchthe HSR only allows shoppers to make an informed choice between a limited range of items at present.

  Additionally, some consumers have expressed concern that the HSR appears on the more expensive ‘big name’ branded items, with limited use on the cheaper/home brand options. This limits shoppers’ ability to select healthier cheaper items using the HSR as a guide.

• the score could be used to judge the relative healthiness of items across food categories, not just within specific categories.

  The HSR allows consumers to compare the relative healthiness of items within the same category, but it doesn’t allow consumers to compare items across categories. This isespecially relevant if they are seeking healthier options of any type, such as comparing a muesli bar to a cheese snack.

  Nutrition Australia believes the score should be able to be used as an indicator of relative healthiness compared to ANY other item.

In addition, we made recommendations regarding:

Consumer education
There has been a notable lack of mass communication to educate consumers about the HSR. Nutrition Australia beliesves the implementation of HSR should be one strategy and supported by consumer education across all media, and in partnership with nutrition and health promotion organisations.

Governance
Nutrition Australia considers the involvement of food industry in the design and oversight of the HSR a concern. The system aims to reduce the purchase and consumption of unhealthy foods and drinks, and as such, manufacturers of those foods (or their industry representatives) have a conflict of interest in designing such a scheme.

We believe that the food industry should be widely consulted in the development and review of the HSR system, but should be distanced from the final decision making and oversight of this particular, vital, public health initiative.