Nutrition Australia response to Health Star Rating draft Five Year Review Report

The Australian Government’s Health Star Rating (HSR) system is a voluntary front of pack labelling scheme that rates the overall nutritional profile of packaged food and drinks. It is designed to make it easier for consumers to choose healthier options when shopping.

The five year review of the HSR system is currently underway and a draft report containing 10 recommendations was open for consultation in early 2019. 

Nutrition Australia submitted a response to the draft report as some of the proposed changes still do not align with the Australian Dietary Guidelines (ADGs).

Overall, Nutrition Australia would like to see foods and drinks scored in a way that aligns with the ADGs, to assist consumers in choosing nutritious foods and drinks from the five core food groups, and away from heavily processed, less nutritious options.
 

Our key recommendations were:

  • All oils which contain predominantly polyunsaturated and monounsaturated fats are should be scored equally.*
  • Further work is required to ensure core dairy foods receive more health stars than discretionary dairy products.
  • Foods should receive more modifying points based on wholegrain content.
  • The HSR should distinguish between naturally-occurring sugars and added sugars.
     

We conducted a survey to find out what you thought about our recommendations, and more than 260 people responded.

Keep reading to see what you had to say:

 

Healthier oils and oil-based spreads

*We have since reviewed our position on the Health Star Rating of healthy oils, and it is now below. Whilst this was not included in our recent submission, Nutrition Australia will be advocating for the following to be included in the Health Star Rating system in future.

All healthier oils and oil-based spreads (containing predominantly unrefined unsaturated fats) should be rescaled and given positive modifying points whilst oils that contain trans fats, polar compounds and polyunsaturated fats should receive negative modifying points. If this is not possible, edible oils should be removed from the HSR System altogether until the modifying points can be reviewed and included.

The HSR system proposes to rescale the oils and oil-based spreads category to improve the HSRs of healthy oils to better represent their nutritional value. Broadly, products with saturated fat content of less than 12% would receive a HSR of 5, while products with saturated fat content more than 25% would receive a HSR of 2. Nutrition Australia is supportive of oils and oil-based spreads being rescaled, however, other factors in addition to saturated fat need to be taken into account.

We believe that all healthier oils and oil-based spreads that contain predominantly unrefined unsaturated fats* (such as extra virgin olive oil and avocado oil) should be rescaled and given positive modifying points. (Unrefined oils are naturally extracted from the fruit or seed, whereas refined oils are extracted or processed using chemicals, high heat and/or pressure which can produce artificial compounds such as trans fats and polar compounds.  New research demonstrates that many factors influence the healthfulness of oils and oil-based spreads and saturated fat is not the only determining factor.  As such, we also believe that negative modifying points should be allocated to oils and oil-based spreads that contain trans fats, polar compounds and excessive polyunsaturated fats.

While we acknowledge the complexities to alter the HSR calculator, we feel strongly in our position that oils and oil-based spreads need to be scored on other factors besides saturated fats to ensure that the HSR system is in line with the ‘latest scientific nutrition evidence’.

If this is not possible, the HSR System should be removed from edible oils altogether until the modifying points can be included.

 

Dairy food

Further work is required to ensure core dairy foods receive more health stars than discretionary dairy products.

92% of survey respondents agreed.

Nutrition Australia is supportive of the proposal to redefine category 2D to include dairy desserts and other chilled dairy products, and category 3D to include surface ripened cheeses. However we believe further work is required to promote healthier dairy options that align with the ADGs.

The rescaling proposed does not yet ensure that core dairy foods (such as yoghurt and cheese) receive more health stars than discretionary dairy products (such as dairy desserts).

 

Fibre and wholegrain

Foods should receive more modifying points based on wholegrain content.

96% of survey respondents agreed.

While we acknowledge the complexities outlined in the report around including wholegrain in the HSR calculator, we feel strongly in our position that wholegrain content still needs to be considered in order for the HSR calculator to better align with the ADGs. 

The ADGs provide clear evidence on the benefits of consuming wholegrains, and states “Enjoy grain (cereal) foods, mostly wholegrain and/or high cereal fibre varieties.” However, the current HSR calculation does not differentiate between products containing wholegrains and those containing refined grains, eg bread, rice, flour, and breakfast cereals.

Some wholegrain foods may indirectly benefit based on their level of fibre, but Nutrition Australia does not believe fibre is not a suitable proxy for wholegrains (this is also noted in the draft report). We feel it is important to discourage industry from adding fibre substrates, such as inulin, to increase a less healthy product’s HSR. As such, the calculator should score foods containing wholegrains higher than those without.

The calculator already offers modifying points for the presence of fruit, vegetables, nuts and legumes in products, and we believe it will better align with the ADGs by adding wholegrains to this list.

 

Sugars

The HSR should distinguish between naturally-occurring sugars and added sugars.

94% of survey respondents agreed.

Although Nutrition Australia supports increasing the baseline points awarded for total sugars to reduce the HSRs for products high in total sugars, we have concern with it not distinguishing between natural sugars and added sugars, and we encourage a solution that will distinguish the two to be further.

Some foods which have inherent sugars (ie, from fruit or dairy) and no added sugar may still be impacted by the changes to total sugars. For example, the report states that yoghurts are likely to get a decrease of 0.5 stars.

 

What is the Health Star Rating?

The Health Star Rating (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. More than 10,000 products now display a HSR.

Nutrition Australia congratulates the government for establishing the Health Star Rating and for taking feedback since its inception in 2014. 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.

 

You can view Nutrition Australia’s past submissions to the HSR review here.

 

 

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