Public submissions to the five year review of the Health Star Rating system

Overview

Introduction

The Health Star Rating (HSR) Advisory Committee (HSRAC), responsible for overseeing the implementation, monitoring and evaluation of the HSR system, is undertaking a five year review of the HSR system. The HSR system is a front-of-pack labelling (FoPL) scheme intended to assist consumers in making healthier diet choices. The findings of the review will be provided to the Australia and New Zealand Ministerial Forum on Food Regulation (Forum) in mid‑2019.

In parallel with this consultation on the HSR system five year review, the HSRAC is conducting a dedicated investigation of issues and concerns raised about the form of the food (‘as prepared’) rules in the Guide for Industry to the HSR Calculator. These enable additional nutrients to be taken into account when calculating star ratings based on foods prepared according to on-label directions. A specific consultation process seeking input into this investigation opened on 19 May 2017 and will close at 11.59 pm 30 June 2017. The form of the food (‘as prepared’) consultation can be viewed on the Australian Department of Health’s Consultation Hub.

The HSR system

The HSR system is a public health and consumer choice intervention designed to encourage people to make healthier dietary choices. The HSR system is a voluntary FoPL scheme that rates the overall nutritional profile of packaged food and assigns it a rating from ½ a star to 5 stars. It is not a system that defines what a ‘healthy’ or ‘unhealthy’ food is, but rather provides a quick, standardised way to compare similar packaged foods at retail level. The more stars, the healthier the choice. The HSR system is not a complete solution to assist consumers with choosing foods in line with dietary guidelines, but should be viewed as a way to assist consumers to make healthier packaged food choices.  Other sources of information, such as the Australian Dietary Guidelines and the New Zealand Eating and Activity Guidelines, also assist consumers in their overall food purchasing decisions.

The HSR system aims to:

1. Enable direct comparison between individual foods that, within the overall diet, may contribute to the risk factors of various diet related chronic diseases;

2. Be readily understandable and meaningful across socio-economic groups, culturally and linguistically diverse groups and low literacy/low numeracy groups; and

3. Increase awareness of foods that, within the overall diet, may contribute positively or negatively to the risk factors of diet related chronic diseases.

The HSR system consists of the graphics, including the words ‘Health Star Rating’, the rules identified in the HSR system Style Guide, the algorithm and methodology for calculating the HSR identified in the Guide for Industry to the HSR Calculator, and the education and marketing associated with the HSR implementation.

The HSR system is a joint Australian, state and territory and New Zealand government initiative developed in collaboration with industry, public health and consumer groups. The system is funded by the Australian government, the New Zealand government and all Australian jurisdictions during the initial five year implementation period.

From June 2014, food manufacturers started to apply HSRs to the front of food product packaging. Further information on the HSR system is available on the HSR website. The New Zealand Ministry for Primary Industries (MPI) website also provides information on the HSR system in New Zealand.

Purpose and scope of the review
The five year review of the HSR system 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 (Terms of reference for the five year review).

With a focus on processed packaged foods, the objective of the HSR system is:

To provide convenient, relevant and readily understood nutrition information and /or guidance on food packs to assist consumers to make informed food purchases and healthier eating choices.

The HSRAC has agreed that the areas of communication, system enhancements, and monitoring and governance will be considered when identifying whether the objectives of the HSR system have been achieved.

Although HSRAC will need to be a part of the review process, a degree of independence is required and independent management and oversight of the review is an important factor to ensure credible and unbiased reporting. An independent consultant will be engaged to undertake the review. Specific detail about the scope of the review will be outlined in the statement of requirement for the independent consultant. A timeline for the five year review of the HSR system has been drafted and will be updated throughout the review.

Next steps in the review process

As part of the five year review, HSRAC is seeking evidence based submissions on the consultation questions provided in this discussion paper.

This consultation is open to the public, state and territory governments, relevant government agencies, industry and public health and consumer groups.

Making a submission

The HSRAC is seeking submissions on the merits of the HSR system, particularly in response to the consultation questions below. The aim of the questions is to assist respondents in providing relevant commentary. However, submissions are not limited to answering the questions provided.  Please provide evidence or examples to support comments. Some areas of this review are technical in nature therefore comments on technical issues should be based on scientific evidence and/or supported by research where appropriate. Where possible, please provide citations to published studies or other sources.

While the HSRAC will consider all submissions and proposals put forward, those that are not well supported by evidence are unlikely to be addressed as part of the five year review.

Enquiries specifically relating to this submission process can be made via email to: frontofpack@health.gov.au. Please DO NOT provide submissions by email.

• A PDF of the consultation survey is attached for your convenience.

After the consultation period closes the HSRAC will consider the submissions received and will prepare a summary table of the issues raised which will be published on the HSR website. All information within the summary table will be de-identifiable and will not contain any confidential material.

HSRAC will treat information of a confidential nature as such. Please ensure that material supplied in confidence is clearly marked 'IN CONFIDENCE' and is provided in a separate attachment to non-confidential material. Information provided in the submissions will only be used for the purpose of the five year review of the HSR system and will not be used for any other purpose without explicit permission.

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For further information about the HSR system, including its resources and governance structure, please refer to the Australian HSR website and the New Zealand MPI website.