Yes - for consumers Lack of understanding of how HSR is calculated Problems with the current guidance that allow these products to display a Health Star Rating (HSR) based on the product ‘as prepared’ according to the instructions on the product packaging. This effectively means that the HSR of these products can be altered by the nutritional components of the assumed added ingredients. Ordinarily the consumer would believe the ratings pertain solely to the product, rather than based on the specific particular instructions which may envisage other ingredients added to the main product that may heavily influence the HSR result that is tied to the pack. Public Health Yes - for consumers Lack of understanding of how HSR is calculated Majority of consumers look at the star rating at face value. Food companies can easily take advantage of this. People assume its healthier to have products mixed together rather than on their own. General Public Yes - for consumers Lack of understanding of how HSR is calculated Misleading and uninformative. Why is a certain food rated highly? What's the criteria? General Public Yes - for consumers Lack of understanding of how HSR is calculated A lot of people do not have the intelligence to read past the stars label. They see the stars and assume it's a health food. The stars rating system is misleading. General Public Yes - for consumers and industry Lack of understanding of how HSR is calculated Many products, such as spreads, cereals, sauces and dips, are not consumed 'as sold' and are prepared in combination with other foods. Yet these products display 'as sold' health star ratings and only select products can display ratings on an 'as prepared' basis. It is difficult for consumers to interpret which products are rated on an ‘as sold’ or ‘as prepared’ basis. In addition to inconsistent ratings, calculating star ratings based on different food combinations reduces consumers’ ability to compare products within categories and choose healthier options. Public Health Peak Body No - for industry Targeted consumer education required Further education required to explain the definition of 'as prepared' to avoid any potential confusion. Industry No - for industry Targeted consumer education required Future social marketing campaigns should indicate that on some food products the HSR applies to the food as prepared and consumed according to the manufacturer's instructions. Future campaigns to consumers, NGOs and media organisations should include elements regarding the 'as prepared' rules and be accompanied by a strong public relations presence that includes the Government Industry Peak Body and industry x2
Yes - for consumers Comparability with like products The current interpretation of the 'as prepared' guidance does not allow people to easily or fairly compare similar products. Calculating HSRs as-prepared creates an uneven playing field, especially when companies are basing their HSRs on different directions for consumption. The current arrangements make it difficult for people to make food comparisons is the fact that food manufacturers are using the optimal preparation of their product to derive the highest HSR. Consumer Group No Comparability with like products One of the key purposes of the HSR system is to provide ' a quick standardised way to compare similar packaged foods at retail level'. It is important that if a product is sold in two versions (for example powdered and reconstituted) it carries the same nutritional information to avoid confusing the consumer. Any amendment to the' as prepared' rules should uphold the objectives of allowing consumers to compare like products. Industry peak body and industry x2 Yes - for consumers Not aligned with HSR system objectives The current guidance on ‘as-prepared’ outcomes that do not align with the desired HSR aims. It produces outcomes that are contrary to the objectives of HSRs and removes the ability for consumers to simply compare products within a category. Consumer Group Yes - for consumers Not aligned with HSR system objectives Is not aligned with the aim of the HSR. Public Health Yes - for consumers Not aligned with HSR system objectives As it stands, companies are using the optimal preparation of their product to derive the highest possible HSR. However, without the nuance of the ‘as sold’ and ‘as prepared’ comparison, and without any intuitive link between the HSR displayed and the actual contents of the packaging, the utility of the system to consumers is sacrificed to confer eligible manufacturers maximum marketing benefit. This is fundamentally and unacceptably at odds with the aims and objectives of HSR as a public health and consumer choice initiative and therefore, being part of the guide to industry rather than the algorithm (that has a five year no-change policy) ought to be rectified as soon as possible. Public Health