Health Star Rating (HSR) - Review, Consultations etc

Dear all,

We would love your feedback on the health star rating system. Many of you would have seen the health star rating logo appear on food labels over the past two years. While the system’s intent is to help consumers make healthier choices, they could be working better.

We have an opportunity to improve health stars. The government is reviewing the system and they want to know how it is working and whether it can be improved.

We have developed 5 main asks that need to be addressed for health stars to help people make healthier choices. But we would love if you could have your say on health stars - where they are working, where they are not and where they could be improved. The more the Government hears from individual consumers, the more likely we will see changes at the five year review that will meet consumers’ needs.

Here are the steps to have your say;

  1. Visit the Dept of Health’s Consultation page;

  2. There are many questions, but to make it easier for you, just answer the one mandatory question - Q4 and place all your feedback in this field. If you want help on what to write, you can;

  3. Use the points in our five asks image

  4. Contact us; we are happy to help. Call me on 02 9577 3307 or email on

  5. On the next page, you must enter your personal information. Click on this and answer the four identifying questions.

  6. Click ‘Finish’ then click ‘Submit Response’ for your views to be formally considered.

Thank you very much!

We are also going to be calling on our campaign supporters to follow this process, so any feedback that you have on our instructions would be very valuable.

Thanks again.


I’ll admit to completely ignoring the health stars. I’ve just had a search through the pantry and could only find the stars on organic soy milk, 5* and lemon juice 4.5*, nothing else had them. Much of the food we buy is organic and unprocessed - mainly grains, fruit & veg etc, with only a small amount of processed, such as crackers, cheese, butter, olive oil, long life milk (for yoghurt making) etc.

I think I have enough knowledge (and high enough care factor) to know what foods I want to eat that are not going to be bad for my health, so don’t consider a star rating system useful personally.

However, I’m sure plenty of people do use them, although from what I have read, some of the claimed ratings are pretty dubious.

EDIT: submission completed (compulsory parts)
Strange that after giving them your email as part of your ID, they need to ask for it again when you finish and submit it, for a link to a pdf of your submission.


Submitted my concerns to the site and have included here my input:

"It’s my belief there are products that are getting more Stars in their ratings than are deserved. An example is Milo getting 4.5 stars yet having 45% sugar as an ingredient, the way the 4.5 stars are supported/marketed is that Milo is normally made into a drink with milk. Does that make sugar in itself healthy because I then choose to consume it with a glass of milk? The item itself should be only able to support it’s own HSR not because you may consume it with something else.

There are instances of Breakfast Cereals that have high sugar content, high sodium, and high energy for a given serving that get high star ratings but a very similar product from another manufacturer/supplier gets a lower star rating. Look at NutriGrain and Coles Brand of a similar product. NutriGrain receives 4 stars and Coles 2.5 stars. But even without the comparisons a product that has high sugar, and/or fat, and/or sodium should not be able to support such a high rating.

This also brings me to the amount of added sugar in products (empty kilojoules). This should be clearly addressed by the HSR and where sugar is added it should reduce or be reflected in the HSR.

Children are often targeted by unhealthy food choices and all food products or at the very least all food products marketed at Children should have the accurate HSR prominently displayed on the packaging.

I also think that common convenience foods such as standard burgers from major commercial players such as Hungry Jacks and McDonalds or the KFC chicken ranges should be rated for their HSR and this should be displayed on the packaging, in the Stores and in any advertising of the product.

My final point is that the HSR wherever possible should be used to promote Whole Foods rather than the processed alternatives such as in the choice between Fruit Juices and Fruit Drinks."


Thanks so much @gordon, appreciate you submitting to the Govt on this. Were the instructions clear enough?

That’s excellent @grahroll, thank you very much for submitting your concerns, they are all very pertinent (and align to a lot of our asks :slight_smile: ). Appreciate your help!

Hi Katinka, yes, it was all pretty straightforward to do.

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My answers for the HSR System:
Q2: The HRS system is ineffective in that it only shows ‘relative’ scores across similar products.

It can not be used as an ‘absolute’ guide, as at present foods with high fat, sugars, salts etc can get a high rating. Moreover, all food products should have a HSR.

Q3: Stakeholder engagement? What community engagement has occurred? I don’t remember any.

The HRS system is ineffective in that it only shows ‘relative’ scores across similar products.

It can not be used as an ‘absolute’ guide, as at present foods with high fat, sugars, salts etc can get a high rating. Moreover, all food products should have a HSR.

Products can make their assessment based on the fallacious claim that their product will be diluted or mixed, when in reality they can be consumed as is.

Native and added sugar content (in all possible forms) should be measured for the assessment.

Processed foods should not have a higher HSR than natural whole foods, unless scientifically proven to have a higher nutritional content.


Response submitted. I answered quite a few of the questions, including this statement:

There should be provision for challenges to specific HSRs by individuals and/or community representative bodies, and public scrutiny where a rating is challenged.


The issue I have with the stars is if a product doesn’t get 5 stars, it is very difficult for the consumer to work out what caused the lower star rating drom the information on the packaging.

This is particularly important for those trying to reduce fat, salt or sugar from one’s diet.

It would be good if any shown rating of less than 5 stars has a code indicating what elements contributed to the lower rating.

For example, a simple S for sugar, Na for salt or sodium, F for fat. These could be easily added to the standard star symbol and allows one to chose between say two products which may have the same lower start rating but one is high n in Fat while the other is High in salt. Once the high element is known, one can look at the nutritional panel to see what levels are present in the product.

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From an email recieved from NSW Health dept.

Thank you for your recent contribution to the Five Year Review of the Health Star Rating system consultation.

The Health Star Rating (HSR) Advisory Committee – the group responsible for overseeing the voluntary implementation of the HSR system – is reappraising the form of the food (‘as prepared’) rules in The Guide for Industry to the HSR Calculator. The ‘as prepared’ provision has been raised by public health and consumer groups as a misleading ruling that needs to be addressed.

Following the public submission process run in May/June 2017, three stakeholder workshops will be held in Sydney, New Zealand and Melbourne from late September to mid October 2017. The purpose of the workshops is to consider the pros and cons of potential options to address the ‘as prepared’ issue in the context of the objectives and principles of the HSR system…


Yeah I got an invite to register but I can’t go.

I received an invitation too.

They didn’t mention anything about paying our airfares as the workshops are only being held at Sydney, Auckland, & Melbourne.

It would seem that the rest of us (Aust/NZ) aren’t important enough to consult.

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I just read Choice’s August 2016 report on health star ratings, and am shocked! I cannot rely upon the 4.5 stars that Milo boasts, as I shovel it into my mouth untainted by any breast-bedrawn bovine beverage?


(Okay. ‘Bedrawn’ was a long bow… and maybe I should have omitted the breast - but best beget bygones.)


George Institute has published a report of the state of food supply, “Own Brand” products (and others) and their health ratings. Woolworths came out on top of the “Own Brand” ones. A2 Milk achieved a rating of 100% of it’s products above 3.5 HSR, the only one to achieve this.

The pdf of the report can be found at:


The (independent) George Institute should be commended for their work in this field it has the potential to place pressure on the manufacturers and private labels to improve the quality and nutrition of their foods (viz. Increase the HSR).

The report is also well presented and easy to understand which is essential when communicating the information more broadly.

I hope that they will continue the work and comparisons in the coming years.


Stakeholder Engagement – Implementation of Recommendations from the Five Year Review

In December 2019 Ministers of the Australia and New Zealand Ministerial Forum on Food Regulation (Forum) published their Response (below) to the Health Star Rating system five-year Review Report (below, Review Report) and its ten recommendations for enhancing the HSR system.

In the Response, the Forum requested that the Food Regulation Standing Committee (FRSC) provide further advice on a number of implementation parameters, and develop an Implementation Plan for changes to the HSR system.

Information can be found at Formal review of the system after five years of implementation (June 2014 to June 2019)

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The Australia and New Zealand Ministerial Forum on Food Regulation (Forum) met on Friday 17 July 2020 and finalised its response to matters outstanding from the formal response to the HSR system five-year Review (Review). The communiqué from the Forum meeting can be found on the Food Regulation website at It includes an addendum outlining in detail the Forum’s decisions on Review recommendations that were outstanding.

The direct link to information is Australia and New Zealand Ministerial Forum on Food Regulation Communiqué 17 July 2020


An article has discussed the HSR for Fruit Juices of which some have now been given only 2.5 stars as compared to their previous much higher and up to 5 star ratings (and rates them near to the same level as Soft Drinks). I think the entire article is worth reading.

Why the change? Because the amount of sugar that juices contain, an example was that a 600 ml bottle of Original Juice Co Black Label Orange Juice contains around 12.9 teaspoons of sugar in comparison a “600mL of Sprite containins 13 teaspoons, while Coca Cola contains 16 [teaspoons]”.

Fruit Growers are upset with the changes. However, Dr Jones a member of the group that helped change the ratings noted that the Industry was interested in their profits and said that the “system must remain impartial to industry interests and agendas to ensure consumers’ health needs are met” & “The World Health Organisation really recommends when you’re working on scoring systems for labelling, or marketing restrictions of any of these policies, that you keep industry out of that discussion just because they have a conflict of interest and they can’t be objective about it”.

Yet we have the Federal Agriculture Minister, David Littleproud, wanting to give Fruit Juice an automatic 4 star rating but Dr Jones argues that “the new calculation accurately reflected the dietary guidelines and shouldn’t be altered to give misleading advice to consumers”.

Why should fruit juice be given an automatic high rating? Shouldn’t it be given them on merit. Once the system can be abused by giving ratings based on anything but the data it becomes a useless or conflicted tool to help consumers health choices. I strongly resent the efforts to game the system to promote claims not supported by the real data, memories of 4.5 stars for Milo anyone??

Any thoughts from CHOICE on how this might be used in their campaign on “added sugar” (not that in this case that sugar is added), their work towards better HSR decisions, and looking at the WHO recommendation about food labelling in general eg sizes and visibility of informational panels and keeping Industry influence out of those decisions?


Another article regarding it.

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I note that the industry speaker immediately went for;

  • it will cost jobs
  • the naturalistic fallacy.