The Health Star Rating (HSR) Five-Year Review
The Health Star Rating (HSR) is the government’s front-of-pack labelling scheme in Australia and New Zealand that aims to help assist shoppers quickly and easily assess the healthiness of packaged food and drinks. It commenced in 2014. The five-year review of the Health Star Rating (HSR) is currently underway and is considering how well the system is meeting its objectives and if it could be improved. A draft five-year review report was released for Public consultation (now closed) containing ten recommendations. Targeted feedback was sought on these recommendations. The suggested nutrition-related changes to the HSR calculator are in recommendations 4 & 5 (in bold below).
1. The HSR system be continued.
2. The energy icon (option 5 in the style guide) be removed from the HSR graphic options.
3. Governments, industry, public health and consumer bodies continue to promote the HSR system. Government promotion over the next two years should:
4. A package of changes be made to the way the HSR is calculated for foods to better align with Dietary Guidelines; reflect emerging evidence; address consumer concerns and encourage positive reformulation. These changes would see decreases in HSR of approximately 8% products (mostly discretionary foods), and increases to the HSRs of approximately 15% products (mostly core food group foods such as fruits, vegetables, yoghurts ad cheeses).
5.Changes be made to the way the HSR is calculated for non-dairy beverages based on adjusted sugars, energy and FVNL (Fruit, Vegetable, Nut, Legume content) points to better discern water (and drinks similar in nutritional profile to water) from high energy drinks.
6. HSR system implementation continue to be jointly funded by Australian, State and Territory and New Zealand governments for a further four years.
7. Minor changes to governance of the HSR system to:
8. Enhance the critical infrastructure to support implementation and evaluation of food and nutrition‑related public health initiatives, including the HSR System, through regular updates to Dietary Guidelines and national health and nutrition surveys and the establishment of a comprehensive, dataset of branded food products.
9. The HSR System remain voluntary, but with clear uptake targets set by governments (the HSR must be displayed on 70% of target products by end 2023) and all stakeholders working together to drive uptake.
10. The existing Guide for Industry to the Health Star Rating Calculator and the Health Star Rating System Style Guide be combined, revised and strengthened, providing greater certainty for stakeholders.
Added vs total sugars
There was no recommendation made around added versus total sugars However, it was area of stakeholder concern, most commonly raised in relation to some high sugar breakfast cereals and snack bars. Their reasons noted in the draft report include:
The review says the treatment of sugars in the HSR Calculator is contested. They noted it is desirable to better align the HSR with Dietary Guidelines, address some of the consumer perceptions around the HSR’s treatment of sugars and further encourage reformulation of foods to reduce added sugars.
To do this they make Recommendation 4B which says that total sugars be more strongly penalised. Increasing the points for total sugars content means products high in total sugars would get lower HSRs.
The SRAS submission
The SRAS made a submission to the review, in order to provide additional scientific evidence where possible. Below is a summary of the input provided by SRAS.
Recommendation 2: HSR graphic option 5, the energy icon, be removed from the HSR system
The SRAS does not support this recommendation as it runs contrary to scientific evidence regarding the importance of the role of dietary energy in health and does not address one of the key problems in the Australian diet – excess energy contribution from energy rich, nutrient poor discretionary or occasional foods. Removal of the energy icon would represent a misalignment with the Dietary Guidelines, which emphasise the importance of choosing food and drinks to meet (match) energy needs. It may also have the unintended consequence of emphasising specific nutrients such as fat or carbohydrate as a guide for food choice and energy balance rather than energy. Using total sugars as a proxy for energy is not in line with the evidence. A convincing link between added sugars and obesity, independent to the contribution to overall energy intake, is lacking.
There is some consumer confusion about energy content of foods, and socio-economic differences in the way energy content is perceived in relation to healthiness. Instead of removing the energy icon, the SRAS supports the conclusion of research cited in the draft review that recommends a comprehensive and widely communicated campaign to increase consumer understanding of energy and kilojoule information on food labels, especially in people from lower socioeconomic groups as they have a greater burden of obesity and diet-related disease. The researchers said, “it is critical to improve nutritional literacy regarding these concepts (energy and energy terms) to empower consumers with the knowledge to make better choices when shopping”.
Comments on Recommendation 4b: Total sugars be more strongly penalised by revising the sugars table for Categories 1, 1D, 2 and 2D to a maximum of 25 points for >99g/100g
SRAS queries the proposed change to the treatment of total sugars within the HSR system. Further penalising sugars in the HSR will confirm consumer misunderstanding about sugars. Concerns raised about sugars in core foods such as yoghurt and breakfast cereals are unfounded, ie
Reducing the HSR of nutritious core foods could reduce their consumption and this runs contrary to the purpose of the HSR and Dietary Guidelines.
SRAS recommends consumer concerns around sugar be addressed in an alternative way, most appropriately by providing evidence-based information and education, and targeting specific consumer concerns.
A word on dental caries
There has been discussion that including added sugar in the HSR would help reduce dental caries. The SRAS notes this is not supported by the current evidence. Dental caries is a multi-factorial disease. Frequent consumption of any fermentable carbohydrate can contribute to caries development and not just foods containing sucrose. Limiting frequency of exposure to all fermentable carbohydrates as well as sufficient oral hygiene is important, and evidence shows can be more effective in reducing caries prevalence than just modifying sugar intake.
Recommendation 5: Changes be made to the way the HSR is calculated for non-dairy beverages, based on adjusted sugars, energy and FVNL points, to better discern water (and drinks similar in nutritional profile to water) from high energy drinks.
The Review includes stakeholder feedback that the HSR does not support consumers to choose healthier options in the non-dairy beverage category because plain water and pure fruit juices score 5 while low- or no-calorie flavoured waters score around 2. They say this a concern due to sugar content of juice. They propose low- or no-calorie flavoured waters (many of which contain artificial sweeteners) get a high HSR, followed by low-sugar juices (eg tomato and grapefruit) while other naturally sweeter juices would be penalised for their sugar content similarly to soft drinks, sports drinks and iced teas.
The SRAS queried the rationale for making this recommendation, which appears to be based on the perception of what is a ‘healthy drink’ rather than scientific evidence. To paraphrase the submission, it argues that sugar content is not the only determinant of the healthiness of a drink. They suggest a more prudent approach is to rank the HSR of beverages in line with the scientific evidence of their contribution to health.
In relation to artificially sweetened beverages, the SRAS provided some new evidence from a systematic review and meta-analysis conducted to inform the WHO guidelines, which concluded there is no compelling evidence to demonstrate health benefits of non-sugar sweetener use, and potential harms cannot be excluded.
FSANZ is currently working through submissions to the Draft Five Year Review after which the final Review will be released and is expected by the end of 2019.