Star Watch: Findings from the Health Star Rating System's Five Year Review
What you need to know
- The draft five-year review of the Health Star Rating (HSR) System has now been published.
- Importantly for industry, the Draft Review reports that HSR ratings influence customer purchasing behaviour and product choices. The Draft Review also reports that the HSR has encouraged positive reformulation of products to increase HSR ratings.
- The Draft Review sets out 10 recommendations that include changes to the HSR algorithm and the means by which the HSR System is implemented. The Draft Review is now being finalised and will be provided to the Australian New Zealand Ministerial Forum on Food Regulation (MFFR) in mid-2019.
What you need to do
- Food manufacturers should be alert for any further recommendations made by the MFFR in the final report, which is expected to include recommendations that will affect the calculation of HSRs for some products as well as the manner in which the HSR is to be displayed.
Introduction
The Health Star Rating (HSR) System was introduced to assist consumers to make fast and informed purchases and healthier eating choices. See our articles in the November 2017 and October 2018 editions of Food Law Update which discuss the HSR system in further detail.
The HSR System was introduced in April 2014 for an initial five year period. Matthew Peggs Consulting (MPC) was engaged to assess the effectiveness of the system during the initial term, to report on any deficiencies and make recommendations accordingly.
MPC released its Draft Review of the System (Draft Review) on 25 February 2019. The Draft Review will be provided to the MFFR mid-2019, and a final report is expected to be released in late 2019. The final report will make a number of recommendations which could significantly affect organisations who have adopted the HSR System or intend to do so in the near future.
The Five Year Review: Findings
Overall, the Draft Review reports that the HSR System is both:
- well-used, recognised and relied upon by consumers in order to make healthier choices when purchasing packaged food products and beverages; and
- encouraging positive reformulation of less healthy products, with food manufacturers providing examples of products that have been reformulated to increase their HSR.
A survey of Australian consumers purchasing a HSR-displaying product within a three-month window reported that almost two-thirds had been influenced by the product's HSR. One third of consumers were influenced to purchase a product with a higher rating.
A separate study reported that three in five Australians who bought a product displaying the HSR had been influenced by the HSR rating. Of those consumers, one in two purchased a product they would not normally buy due to the presence of the HSR, and close to nine in 10 of these shoppers said they would continue to buy the product.
In New Zealand, 28% of consumers report using the HSR to help choose packaged food, with 88% choosing the product with more stars.
It was also reported in the Draft Review that the HSR System has encouraged positive reformulation of food and beverage products. For example, since the introduction of the HSR System, 79% of products displaying the HSR in New Zealand have been reformulated to change at least one key nutrient by a minimum of 5%. In Australia, a significant portion of products displaying the HSR have been reformulated to contain statistically significant reductions in energy and saturated fat content compared to those not displaying the HSR.
The Five Year Review: Recommendations
The recommendations contained in the Draft Review are set out in the table below. These recommendations may be subject to change in the final report.
| Recommendations | Reported Reasoning |
| The System should be continued | The System is well used, reliable and recognised by consumers, and assists consumers to make healthier food choices. |
|
The energy icon be removed from the HSR graphic options
|
The energy icon is poorly understood by consumers, and provides insufficient information to support choice. |
| Government and stakeholders continue to promote the HSR system over the next two years | Promotion of the System is warranted in order to support the changes. Changes to the System should be communicated, and specific areas of consumer misunderstanding or gaps in awareness should be targeted. |
| Amend the way the HSR is calculated for foods |
The algorithm underlying the HSR Calculator should be amended to i) better align with Dietary Guidelines; ii) reflect emerging evidence; iii) address consumer concerns; and iv) encourage positive reformulation. A package of six interrelated changes are proposed:
|
| Amend the way the HSR is calculated for non-dairy beverages | Changes should be made to the way the HSR is calculated for non-dairy beverages based on adjusted sugars, energy and FVNL (fruit, vegetable, nut and legume) points, to better discern waters (and similar drinks) from high energy drinks. |
| HSR System implementation to continue to be funded | The System should continue to be jointly funded by governments for a further four years in order to ensure that changes are made to better align with Dietary Guidelines and address consumer concerns. |
| Minor changes be made to the governance of the HSR System |
Changes should be made to the way the System is governed (including the composition and role to the HSR Advisory Committee), in order to:
|
| Enhance critical infrastructure | Critical infrastructure is required to support implementation and evaluation of food and nutrition-related public health initiatives, including the HSR System, be enhanced. |
| HSR system remains voluntary | The System should remain voluntary, but with clear uptake targets set by governments (eg the HSR must be displayed on 70% of target products by end 2023) and all stakeholders working together to drive uptake to enable the System to have a significant public health impact. |
| The existing Guide for Industry to the Health Star Rating Calculator and the Health Star Rating System Style Guide be combined, revised and strengthened | To create a single resource that describes the System, its objectives and industry obligations. |
What is next?
The Draft Review will be provided to the MFFR in mid-2019 with the final report set to be released later in the year. The recommendations made in the final report may lead to significant changes which could affect food and beverage manufacturers who have opted-in to using the HSR System or intend to in the near future.
Authors: Joanna Lawrence, Counsel; Melanie Kitchin, Lawyer, and Dario Aloe, Lawyer.
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