Health Star Ratings - issues

The government is considering changes to the ‘as prepared’ rule for health star ratings.

Currently a company can calculate its star rating based on the product ‘as prepared’ with other ingredients, which can result in the product receiving more stars. For example, Milo made up with skim milk gets 4.5 stars, but on its own gets 1.5 stars. M. A packet cake mix on its own, might get 1 star. But made up with eggs, milk and butter it might get more.

An argument for allowing a health star rating ‘as prepared’ is that you can compare similar products that sit in different categories – packet cake mixes with ready-made cakes in the bakery section, for example. On the flipside it could be argued that requiring a star rating to be based on the product ‘as sold’ would allow for a more direct and fair comparison between equivalent products.

We want to understand how you use health stars to compare foods. Would you compare star ratings of cake mixes with ready-made cakes, or just with other cake mixes? Which approach would you find most helpful – star ratings based on ‘as prepared’ or ‘as sold’?

EDIT: Here’s the latest development in health star ratings:


I can see the rarionale behind the as prepared health stars, but beleive that this is not in the interests of the consumer…it is only in the interests of the manufacture to use an as prepared that maximises the star rating.

I can see manufacturers manipulating this to their advantage as the as prepared on the packet will be based on ingredients which increase the star rating. I can also see manufacturers providing additional/optional recommendations to the consumer (add 1/2 cup sugar for a sweeter cake, add 250mL of melted butter instead of water for a more luxurious cake etc). Most will possibly do this as the as prepared will most likely be not very inviting.

To compare what is in the packet being purchased. A consumer can then determine based on the star rating of other products (say butter compared to skim milk) of other ingredients added to complete the product formulation.

Star rating for as prepared would only be useful if they were the only things given the star rating…but as everything will have the star rating, one should only need to know the rating of each product purchased and make decision on all ingredients/substitutes based on it.

Having higher star ratings as prepared may also lead to misconception of the product being healthier than it actually is and also lead to consumers modifying the ingredients to less healthy ones thinking it is still okay.


The issue I see for ‘as prepared’ is the inevitable rorting, eg similarly to how the manufacturers are free to define what a ‘serving’ is, regardless that a packet might have 1.62375 serves in it and most reasonable people would think it as a single serve.

Most things can be prepared in so many ways, with more probably to be discovered if ‘as prepared’ got up.

s/The Cynic


Tagging @Health-Campaigner and @Defender-Black groups in case they can provide some input for Katinka on health star ratings.


Shouldn’t that be the other way around? Adding milk would certainly reduce the concentration of sugar!

IMO ‘as sold’ should be used to avoid the rorting as done with Milo (although I think I read this was recently changed?).


I think as sold would be the logical way to go . There would be too many variables in putting a star rating on the as prepared product . We live in a world where the majority of people/consumers believe time to be a premium commodity . They will always prepare a packet cake , pudding etc in the fastest way possible ignoring maybe the manufacturers recommendations to achieve the end product . /

Yes definitely the as sold in my opinion .


Definitely ‘as sold’ in the simple case.

… and it has to be absolutely believable. To me this means independent testing - if they are prepared to pay someone else to independently Halal or Kosher certify it, they can pay for legit stars as well - at least the majority of consumers would benefit from this, and really it should not cost much at all.

In the complex case, I think there is an argument for ‘prepared’ in some cases? if a product simply cannot be used ‘as sold’ and requires adding something other than water? I can’t think of an example, so maybe that kills my point … anyone?

Also, there should be a rule against health stars for something silly - like bottled water, or saffron fronds - don’t want to see health stars where they don’t make sense - maybe those examples are extreme :slight_smile: I seem to recall seeing health stars or indications of same on foods where it was obvious and puerile.


A health star rating on a packet cake, based upon ‘as sold’, simply does not reflect what is going into the mouth. Were I a packet cake maker trying to benefit from such a principle, I would include most of the ingredients in the packet but then require the cook to add sugar! I understand the concerns about companies bodgying their ‘as consumed’ figures as Nestle did with Milo, but the ‘as sold’ figure is going to be meaningless in many cases.

Perhaps there is a possibility of policing ‘as consumed’ based upon how the majority of the population actually consumes a particular product. There is no way then that Nestle could continue claiming that everyone uses Milo with skim milk. (Personally, I prefer it plan.)

So I would much prefer the ‘as prepared’ model - except perhaps when dealing with strawberries and the possible addition of whipped cream.


Stars says it’s healthy! Right?

Even a Mars Bar gets some stars! Right?

So only put “Stars” on Products that are
(a) healthy
and (b) form an essential part of a healthy diet

For the rest give nothing or perhaps death symbols like a “skull and cross bones”. The more bad symbols the less you should partake of it.

And as the manufacturer has zero control over any added ingredients giving any stars for a part meal is misleading.

I can prove this by my scientifically proven research and analysis:
For Milo I always put in a few extra heaped spoonfuls and eat one while trying to make it all dissolve. So one spoonful with milk = 1.5 stars, so three in the milk and one to chomp is four spoons = 1.5x4 or 6 stars! Right?

Similarly eating a quarter of an apple is good but four quarters equals a whole apple is even better.

And apologies to pirates - perhaps a little circle with the letters ‘NOT Good’ stamped over a Tony Abbott smile would be less discriminating on food to avoid. For getting the message out about what we should not do Tony has always been a gold standard. Similar use of a well recognised image to convey the message just like Dick Smith on the Aussie Mite label says “Aussie made”. Subject to Tony accepting and Dick not having rights on using faces on packaging.


or even the possible addition of sugar? :wink:

I would second that excepting it would be emotive in industry and difficult to establish how the majority consume a product. What information do I get if I actually eat my cereal dry from the box as compared to the majority who might use full cream milk? OK, it is impossible to serve everyone equally, but. The (il)logical end point would be multiple recipes and information overload.

There is a certain beauty about that because you would have purchased a healthier product and it is on you to make it less healthy. So maybe back to ‘as sold’?


Great pick up @gordon - don’t know how we got that wrong!! Have edited.


There is no solution to the problem as it is usually put. You cannot make a single rating system accurately reflect the ‘healthiness’ of products that may be anywhere from the whole pack eaten at a sitting by one person out of the pack, to an ingredient (or group of ingredients) that required other things to be added and further processing and where one pack might make many servings. In trying to coerce such dissimilar things into one category measured by one indicator it is inevitable some will be misrepresented and that those who want to manipulate the system will find a way to do it.

Add to this the problem that there is no way to usefully define ‘serving’ or ‘serving suggestion’ as human inventiveness will overtake anything you can imagine. Aside from the obvious one of eating Milo out of the tin with a spoon I know of cases of:

  • drinking sweetened condensed milk out of the can,
  • eating Weetbix with tomato sauce instead of milk,
  • eating cold condensed soup out of the can with a fork,
  • and for something different, one person eating 3/4 of a large rich cheesecake (6-8 slices) in one sitting.

People like to be outraged by Milo getting a good score, they would be better off using their energy to do something useful like locking the tin in a box and wearing the key on a chain. What is the solution that dispenses with this outrage that does not create another anomaly elsewhere just as stupid?

Wherever the result it will be a compromise. Whatever the compromise few will be happy. Somewhere there is a meeting room where this matter is being thrashed out where there are a lot of head-shaped dents in wall and the bars on the window are not for keep people out.


That’s outrageous! Disgusting! Who eats Weetbix with tomato sauce? Margarine I can understand - but sauce?


Maybe we could have two ratings on each packet, one that shows the rating as is and then a smaller one next to it that represents “when prepared as directed”. I don’t bother looking at the stars anyway. Too busy squinting at the price per kilogram or per litre (etc) on the shelf tags most of the time to see what’s the best value for money.


This is a very good point. If the healthy stars are for the as prepared, it will allow manufacturers to come up with some wacky or unusual serving suggestions to maximise their star rating. Already there are some wacky/unrealistic serving suggestions shown on packaging.

I am sure that a majority of us would not follow the serving suggestions shown on a product.

Even for cake mixes which the label is often reasonably prescriptive in their method for preparing a cake, have many other uses. In today’s internet recipe world, one can come up with methods very different to that recommended on the packets. This is something we often do.

Other examples are for spreads. The manufacturer could nominate its as prepared serving suggestion as being on 100% brown rice cakes (which have very low salt and fat content)…when in reality the spread is used on lower star rating breads/toast. Yeast spreads can also be added to water as a hot drink…maybe it could be added to hot water at a concentration such that it achieves a 5 star rating and this is used as the as prepared rating on the label.

Where alternative methods (serving suggestion) are used for any product, the star rating is meaningless if based only on the as prepared method shown on the packaging. In such case, the as bough star rating is far more relevant.

Using as prepared is fraught with danger and open to abuse from manufacturers. This has already been shown by Milo and I am sure it was allowed, there would be 100s of other manufacturers changing the labels on their products to flaunt any relaxed star system.


Unless I am mistaken, the cheesecake comes ‘unsliced’ - so while I may have been known to eat a good amount in a sitting, it is only ever one slice … it might be a 90 or 180 degree slice, but one slice …


Sometimes we (consumer advocates) can get too close to a problem on the woods-n-trees principle.

A pure approach to food labelling would suggest (like many here) that assessment must be on the package contents, rather than what’s made up from them. So we’d likely see most concentrated items getting horrific star ratings, simply because they’re concentrated.

This creates a problem with public use and understanding. If all products in a well-used category like cake mixes carry a skull-&-crossbones type label, consumers will quickly tend to shrug their shoulders and ignore all the labelling.


To be a valid indicator, the star rating should actually be an empirical verifiable fixed measure. So one spoonful of Milo = X (whatever the star rating), two spoonfuls = ½X (whatever the star rating) etc. One glass of milk = Y (whatever the star rating). One glass of mile + one spoonful of milo = X+Y

A packet mix = Z (whatever the star rating), add one glass of milk and it becomes Z+Y, etc.

As it currently stands, you cannot compare foods, you can only compare with ‘like’ products. That is the star rating of a ready made cake does not equate with the same star rating for a box of packet mix.
And, something which is relatively unhealthy can have the same health star rating as something healthy. The average consumer won’t stop and think about the relative differences between the same number of health stars on different product lines (e.g. using the above milo/milk example: X may actually = 10Y etc).

If it became ‘as prepared’, for example with cake mixes, each manufacturer will recommend adding different quantities of different ingredients in their recipes. Then the star rating would be devoid of meaning as a comparative measuring tool.

Having the ‘as sold’ is better than ‘as may be consumed’ by someone, but neither of them are of much value in giving consumers a real idea of how healthy their diet actually is.


Without a doubt in my mind what you put with it should not affect the health star rating.

‘As sold’ is a fair way to go as there is no room for unhealthy or low star foods to hide that they are unhealthy. Therefore the consumer is in a far better position to make a educated decision on whether the product they are purchasing is actually healthy or a ‘wolf in skim milks disguise’.

Now I, as a consumer, think this would be a great idea but the food industry will be lobbying hard for this not to happen.
Time will tell who’s side the government is really on(forgive my cynicism I am really trying to cut down).


Only if they are high in salt, fat, sugar and/or low in fibre. In such case it provides a flag to use in moderation or not to be eaten excessively as a daily food.

I could see salt getting five stars ‘as prepared’ when it is added at very small concentrations to say a five star fresh vegetable like brocolli. In reality, a user of salt may use far more on the same food…or use it more broadly over all foods which would potentially lower the star rating of the other/all foods. The total consumption of salt used would exceed guidance dietary levels.