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HSR and nutrition information panel labelling update 

8 October 2024

The AFGC attended a meeting Tuesday 1 October of the Bi-National Food Industry Dialogue (BFID), where Food Standards Australia New Zealand (FSANZ) provided an update on their scoping work on improving front- and back-of pack nutrition labelling.  

Key points 

  • FSANZ has worked with state and territory and New Zealand food regulators through the Food Regulation Standing Committee (FRSC) on the proposed scope for the nutrition information panel (NIP) review and are currently scoping the health star rating (HSR) project.  
  • Both projects will run in parallel, with FSANZ to provide an update on the approach to the Food Ministers Meeting (FMM) in November 2024.  
  • Stakeholder consultation on the scoping work is likely to occur before the end of the year. 
  • On the HSR, FSANZ confirmed they will be looking at ways to strengthen the system, but this will not include a full HSR or algorithm review.  
  • For the NIP, FSANZ will be building on the results of consumer research as part of their work on alcohol (P1049 and P1059) and added sugar (P1058) labelling, with the aim to enhance consumer use and understanding.  

Between now and late 2025, FSANZ will gather evidence, commission consumer research, conduct cost benefit analyses, and technical assessment of both the HSR and NIP. This will be summarised in a report to go to the Food Ministers in early 2026, along with reporting against the final HSR uptake target. Proposals may then be raised subject to the FMM decision on HSR and NIP review outcomes. 

HSR industry survey – Department approaching respondents  

Separately, the Department of Health and Aged Care (DoHA) is approaching companies that participated in the HSR industry survey last year, seeking to further discuss key issues. The Department is also keen to understand the outcomes companies are seeking. Providing further feedback is voluntary and confidential. 

A summary of the online survey of industry views on the HSR system was published on the Health Star Rating website along with the report of the 2023 HSR uptake. Key findings included that around a third of respondents (n=27) intended to apply the HSR to additional products in the next 12 months, nearly half (n=38) of respondents indicated public health was a key reason for implementing the system, and barriers to implementation included cost, lack of space on smaller labels, and commercial reasons.   

AFGC action  

The AFGC held member roundtables in May 2024 to inform and understand member perspectives on the regulatory and political risks around preventive health, including the potential mandating of HSR labelling.  Key outcomes included the need for sufficient transition times (2 years or more), limiting changes to the algorithm (to mitigate risks for other inclusion of other elements, or further tightening) and alignment with other label changes to reduce costs to industry. 

The AFGC will continue advocate that any proposed label changes must be based on evidence, and consideration of costs and practicalities for industry to implement.  

The AFGC will convene a working group to provide feedback on questions (see below) that FSANZ raised at the BFID meeting to inform their scoping work. Please contact Anne-Marie Mackintosh if you wish to be part of the working group.  

Member considerations 

Members are encouraged to consider applying HSR labelling across portfolios if/when other label changes are in the pipeline. This will enable implementation within your own timeframes and help mitigate the cost of multiple label changes. Please note that the industry has been criticised for placing HSR on higher scoring products only.  

For members that have been contacted by DoHA for further discussion on the HSR industry survey, the AFGC encourages dialogue with the Department as it is an opportunity to raise concerns and issues specific to your business. Members may also wish to consider the broader impact on the industry if the algorithm were markedly changed and possible unintended consequences if this were to occur.  

Contact  

For more information contact Anne-Marie Mackintosh, Associate Director – Nutrition and Regulation anne-marie.mackintosh@afgc.org.au or 0448 170 568.