On 17 July 2020, the Australia and New Zealand Ministerial Forum on Food Regulation (Forum) finalised its response to all Recommendations of the Health Star Rating Five Year Review; endorsed a Review Implementation Plan; and agreed an implementation start date of 15 November 2020.

Health Star Rating System Five Year Review - Implementation Plan (PDF 163 KB)
Health Star Rating System Five Year Review - Implementation Plan (Word 25 KB)

A summary of the Forum’s response to each of the Review Recommendations, and the changes that these will effect are detailed below. Further detail is available in the Review Report, the Forum Response and under Targets and Intended Products.

A two year transition period for the implementation of changes will apply, with all changes to be fully implemented by 14 November 2022.

A stock-in-trade provision of 12 months has been permitted following the two-year implementation period for products that were already using the HSR system on pack prior to 15 November 2020, and have a shelf life of 12 months or longer.

Recommendation 1 - The HSR System be continued

Forum decision

December 2019 – Supported in full

Implications for the system

  • Implementation of the system continues.

Recommendation 2 - HSR graphic Option 5, the energy icon, be removed from the HSR system

Forum decision

December 2019 – Supported in full

Implications for the system

  • From 15 November 2020 the energy icon used alone (with no accompanying star rating) will no longer be a valid HSR display option.
  • Products labelled after 15 November 2020 will not be able to use the energy icon alone.
  • Products already labelled with the energy icon alone will need to remove and update with a permitted HSR graphic.

Recommendation 3 - Governments, industry, public health and consumer bodies continue to promote the HSR system

Forum decision

December 2019 – Supported subject to funding

Implications for the system

  • Government communications to be rolled out.
  • Stakeholders are encouraged to continue promoting the HSR system.

Recommendation 4a - Fruits and vegetables that are fresh, frozen or canned (with no additions of sugar, salt or fat) should automatically receive an HSR of 5

Forum decision

November 2020 – Agreed to the application of an automatic 5 star rating to fresh and minimally processed fruit and vegetable products (only) with the following definition to apply:

  • Fresh and minimally processed fruit and vegetables means - All whole fresh fruit (except coconut) and vegetables, fungi and legumes (except peanuts) as sold with no processing, plus these same products that have only been peeled, cut and/or surface treated and/or blanched and/or frozen (not dried), or canned without the addition of fat, sugars/sweeteners or salt.

Implications for the system

  • From 15 November 2020 businesses will be able to apply an automatic 5 star rating to products that meet the definition for fresh and minimally processed fruit and vegetables.

Recommendation 4b - Total sugars should be more strongly penalised

Forum decision

July 2020 - Agreed that recommendation 4b would be supported as proposed in the Review Report, noting future opportunities to re-assess alignment with dietary guidelines will occur following their review and update in Australia.

Implications for the system

  • From 15 November 2020 the points table for application of baseline points for sugar in HSR categories 1D, 2 and 2D will be extended to 25 points (from the previous 22).
  • Businesses will need to run products already labelled through the revised HSR Calculator to determine whether existing labels need to be updated with a revised rating as a result of this change.

Recommendation 4c - Sodium sensitivity should be improved for products high in sodium

Forum decision

July 2020 - Agreed that recommendation 4c would be supported as proposed in the Review Report, noting future opportunities to re-assess alignment with dietary guidelines will occur following their review and update in Australia.

Implications for the system

  • From 15 November 2020 the upper limit of the points table for application of baseline points for sodium in categories 1D, 2 and 2D, will be reduced from maximum of 30 baseline points for sodium content > 8,106mg/100g to a maximum of 30 baseline points for
    sodium content >2,700mg/100g.
  • Businesses will need to run products already labelled through the revised HSR Calculator to determine whether existing labels need to be updated with a revised rating as a result of this change.

Recommendation 4d - Dairy categories should be redefined

Forum decision

July 2020 - Agreed that recommendation 4d would be supported as proposed in the Review Report.

Implications for the system

  • HSR categories 2D and 3D have been rescaled - Businesses will need to run products already labelled through the revised HSR Calculator to determine whether existing labels need to be updated with a revised rating as a result of this change.
  • From 15 November 2020 custards, evaporated milks, dairy‑based desserts (such as mousses, crème caramels, panna cottas) cream cheeses, creams, sour creams, crème fraiche and mascarpone are considered Category 2D products (rather than Category 2) - Businesses will need to run products already labelled through the revised HSR Calculator to determine whether existing labels need to be updated with a revised rating as a result of this change.

Recommendation 4e - Jellies and water-based ice confections should be re-categorised

Forum decision

December 2019 – Supported in full

Implications for the system

  • From 15 November 2020, jellies and water-based ice confections are categorised within HSR category 1 – Non-dairy beverages, jellies and ice confections.
  • The new HSR Calculator for HSR category 1 – Non-dairy beverages, jellies and water-based ice confections should be used to determine Health Star Ratings.
  • Businesses will need to re-calculate the star rating for all jellies and water-based ice confections, noting that the ratings for most products will change and a label update will be required.

Recommendation 5 - Changes be made to the way the HSR is calculated for non-dairy beverages to better discern water (and drinks similar in nutritional profile) from high energy drinks.

Forum decision

December 2019 – Supported, subject to a definition being developed and agreed for ‘unsweetened flavoured water’ and subsequently agreed that the following definition would apply:

Unsweetened flavoured waters means - Packaged beverages similar in nutritional profile to water that may contain only:

    • carbon dioxide, whether added or naturally occurring;
    • permitted flavouring substances (as defined by Standard 1.1.2-2 of the Code)
    • mineral salts at Good Manufacturing Practice (GMP) (Schedule 16 of the Code)
    • additives that provide a specific safety or stability function at GMP (Schedule 16 of the Code)

and must not contain:

    • added sugars, sweeteners, colours, sodium, caffeine, quinine, or any other ingredient that contains energy and is not expressly permitted above (e.g. protein).

Implications for the system

  • From 15 November 2020 manufacturers will need to use the new Category 1 - Non-dairy Beverages calculator to determine the rating for non-dairy beverages.
  • An automatic 5 star rating continues to apply to packaged water as defined in Standard 2.6.2 of the Code.
  • An automatic 4.5 star rating will apply for unsweetened flavoured waters.

Recommendation 6 - HSR system implementation continue to be jointly funded by Australian, State and Territory and New Zealand governments.

Forum decision

December 2019 - Supported, with an amendment from four to five years to align with timeframes associated with recommendation nine.

Implications for the system

  • The HSR system will be jointly funded by Australian, State and Territory and New Zealand governments until (at least) 14 November 2025.

Recommendation 7 - Minor changes be made to the governance of the HSR System.

Forum decision

December 2019 – Supported, subject to funding availability.

Implications for the system

  • Management of the HSR Calculator and TAG database has been transferred to Food Standards Australia New Zealand.
  • The HSR Advisory Committee terms of reference and membership has been refreshed.
  • Mechanisms (including the above steps) are being put in place to increase the transparency of the HSR System.
  • A revised monitoring approach is being developed.

Recommendation 8 - Enhance the critical infrastructure to support implementation and evaluation of food and nutrition‑related public health initiatives

Forum decision

December 2019 – Supported, subject to funding availability.

Implications for the system

  • Food Standards Australia New Zealand is developing a branded food database, to support the implementation and monitoring of health and food regulatory initiatives.
  • A review of the Australian Dietary Guidelines was initiated in July 2020.

Recommendation 9 - The HSR system remain voluntary, but with clear uptake targets set.

Forum decision

July 2020 – Agreed to interim uptake targets of 50% at three years and 60% at four years, and a final target of 70% at five years, across all intended products.

Implications for the system

  • Uptake will be measured by total number of SKUs against the following targets:
    • 50% uptake across intended products by 14 November 2023.
    • 60% uptake across intended products by 14 November 2024.
    • 70% uptake across intended products by 14 November 2025.

Recommendation 10 - The existing Guide for Industry to the HSR Calculator and the HSR System Style Guide be combined, revised and strengthened

Forum decision

December 2019 – Supported in full

Implications for the system

  • A new guidance document has been developed with input from stakeholders.

Matters considered alongside Review but not reported in the Review Report

As-prepared requirements

The Forum has agreed to the below (revised) requirements for the form of the product to which the HSR should apply:

In most cases the HSR should be calculated and displayed on the basis of the product as it appears on the shelf. Specific exemptions apply for products which must be rehydrated, diluted or mixed with water, or drained of water or brine. The HSR for these products can be calculated on the basis of the product ‘as prepared'.  If the HSR is based on product ‘as prepared’ according to one of these specific exemptions, the label should clearly specify the directions for that preparation

Implications for the system

  • Products that do not meet the revised exemption requirements will need to have their HSR determined using the nutrition information for the product as sold.
  • HSR labels applied under the previous ‘as-prepared ruling’ will need to be updated before the transition period expires (14 November 2022).

Criteria for milk and dairy beverage alternatives

In the interest of aligning with dietary guidelines, the Forum has agreed to the below (revised) criteria for milk and dairy beverage alternatives:

Milk and dairy beverage alternatives derived from legumes, cereals, nuts or seeds must contain ≥100mg calcium per 100mL in order that the product’s HSR be determined with a categorisation of Category 1D – Dairy Beverage.

Implications for the system

  • Products that do not meet the revised criteria will need to have their HSR re-calculated using a categorisation of Category 1 – Non-dairy Beverages and using the new non-dairy beverages calculator.