Australia – Seeing Stars: The New Health Star Rating System And Its Relationship With The “New” Health Claims Standard.

2. the HSR plus additional information on specific nutrient content (see below)

How are HSRs calculated?

 

HSRs are calculated through an analysis of four components of food associated with chronic diseases:

 

• energy;
• saturated fat;
• total sugar; and
• sodium.

 

For a given product, a baseline score is allocated based on the content of each of the above components.  "HSR modifying points" are then allocated based on the following "positive aspects":

 

• percentage of fruits, vegetables, nuts and legumes (FVNL);
• protein content; and
• fibre content.

 

Modifications to the algorithm exist for the calculation of HSRs for dairy foods, given their importance in nutrient intake and their narrow range of FVNL and fibre content.

 

The overall HSR score determines the star rating.  The higher the score, the lower the HSR.  There are ten possible HSRs, ranging from ½ star (least healthy) to 5 stars (most healthy).  In a given food category, a product with a lower HSR has a lower nutritional profile than a product with a higher HSR. 

 

Criticisms of the HSR System

 

Some criticisms levelled against the HSR system include that: 

 

• it does not provide information about the quantity of each food to be consumed in a healthy diet;
• the HSR was ultimately designed to reduce the intake of certain nutrients (saturated fats, sugar and sodium), and considers nutrients in isolation.  As a result, a high HSR gives no indication that a food contains all nutrients required in a healthy diet; 
• given the weightings given to protein and fibre in the above algorithm, food technologists have begun 'manipulating' processed foods in order to obtain higher HSRs.  For example, food technologists have begun adding powdered dietary fibres, such as inulin, as well as soy protein isolate to their products to improve their ranking without greatly improving overall nutritional value; 
• food manufacturers have also been criticised for labelling food packets with a HSR that is only accurate when the packaged food is prepared in a particular way.  For example, some products are being labelled with high HSRs that are only relevant when the products are prepared with, for example, skim milk.  The HSR of the products as stand-alone products are much lower and this is not always apparent to consumers; and
• the system may be perceived by the consumer as an indication of the overall health profile of a food product, instead of the product's health profile within a certain category of food.  As explained above, the HSR is an indication of the relative health profile of a food product as compared to similar food products, when compared based on the amount of isolated nutrients, rather than the overall nutritional profile of a food product. 

 

The relationship between the HSR and the Health Claims Standard

 

The opt-in nature of the HSR system is different from the legislative-based Health Claims Standard.  The Health Claims Standard prescribes certain conditions that a product must meet for manufacturers to be permitted to make health claims or nutrition content claims about a food product.

 

The algorithm underlying the HSR calculation is based on (but modified slightly from) the Nutrient Profiling Scoring Criterion (NPSC) developed by Food Standards Australia New Zealand as a means of regulating health claims, and which considers the energy, saturated fat, sugar and salt content, together with FVNL, protein and fibre content. 

 

The NPSC has only two outcomes, namely if a health claim can or cannot be made in relation to a food product.  The HSR rates foods on a scale of ½ star to 5 stars, and is designed to compare foods within a category.  

 

While the information underlying both calculation systems is the same, the HSR rating of a product may not be the same as the NPSC score.  For example, a recent study surveyed the NPSC and HSR ratings of products in four core dairy categories (milk, hard cheese, soft cheese and yoghurt) and found that while there was generally good agreement between NPSC and HSR scores, there were numerous anomalies.  For example, 11% of the sampled products either met the NPSC but rated 2.5 or less stars, or did not meet the NPSC but rated 3 or more stars.  Most of the foods that met the NPSC but scored fewer than 3 stars were flavoured or dessert-style yoghurts, while most of the foods that did not meet the NPSC but scored 3 stars or above were milk or hard cheese products.

 

Notably, the requirements under the Health Claims Standard 1.2.7 do not apply to a "permitted Health Star Rating symbol".  This exception extends to both stand alone HSRs and those HSRs accompanied by information relating to the product's energy or nutrient content (see Fig 1(a) and (b)).  Food manufacturers must therefore ensure that they correctly calculate the HSR of their food products (to ensure that any use of the symbol is "permitted") and must continue to ensure that any other claims made on their food product labels comply with the Health Claims Standard.

 

If using HSRs, care must be taken to ensure that any additional claims made about a product's energy or nutrient content are not misleading, as this may give rise to consumer claims or action by the ACCC under section 18 of the Australian Consumer Law.  For example, consumer advocate group Choice has identified certain labelling practices, including:

 

• a star rating for the nutritional profile of a product when that product is prepared with particular additional ingredients  (such as that discussed above); and
• higher star ratings on panels included in order to explain the health star rating system on the packaging of products, where that product actually scores a lower star rating.

 

Further public education would also increase the benefits that can be offered by the HSR system.  Where consumers do not understand how the system works, they may think products are healthier than they really are.  

 

Through further education, potential consumers may have a greater awareness that even though a product has a 4 health star rating, it may have an undesirably high sugar or saturated fat content.