Introduction by Croakey: Australian food manufacturers may finally be subject to mandatory health star ratings as the evidence mounts against their compliance with the voluntary ratings to date.
Dr Alexandra Jones and Damian Maganja, from the George Insitute’s Food Governance program, report below on their new research showing that industry is not slow to take up Health Stars because of the costs of redesign and relabelling but rather because they don’t have to.
Alexandra Jones and Damian Maganja write:
The food industry can make widespread and rapid changes to food labels when required to do so by law. ‘Required by law’ is the key part. When labelling information is voluntary, industry uptake is far more lacklustre.
That might sound obvious, but there’s been a dearth of real-world evidence on food label implementation to equip policymakers in this space.
In new work published in this month’s World Health Organization (WHO) Bulletin, we used a natural experiment to compare uptake of Australia’s voluntary Health Star Rating nutrition label with that of a mandatory Country-of-Origin Label over the same period.
The new Country-of-Origin Label was applied rapidly to appear on 93 percent of products by 2023. By contrast, Health Stars uptake was languishing at 39 percent after 10 years.
It’s a disappointing result for the attempt by Australia and New Zealand to implement a simple, at-a-glance nutrition label to rate foods from 0.5 to 5.0 stars, guiding consumers away from unhealthy and towards healthier choices.
There are a few interesting takeaways here.
The first is that most products have elected not to display Health Stars, even when they have updated product packaging to display Country-of-Origin Labelling. This debunks the frequent industry claim that the cost of redesign and relabelling is the primary hurdle to action.
Second, uptake of Country-of-Origin Labelling in a handful of categories where that label was voluntary was also poor (less than half of all products), strengthening our resolve that results are related to differences in mandatory and voluntary status, rather than the popularity of a specific label.
The work adds to recent findings highlighting that voluntary use of Health Stars remains heavily skewed towards high scoring products, with thousands of low scoring products still hiding their ratings.
This means voluntary Health Stars are functioning primarily as a marketing tool for industry. To make them work for consumers, Stars must be made mandatory sooner rather than later.
What needs to happen next?
The good news is that Food Ministers in Australia and New Zealand have already formally registered their disappointment that Health Stars uptake is “significantly off track” from the governments’ pre-specified targets for the system to remain voluntary.
They’ve now tasked Food Standards Australia New Zealand and the Food Regulation Standing Committee with starting preparatory work to enable Health Star Ratings to be mandated efficiently in the very likely event that the final target of 70 percent uptake by November 2025 is not met.
What that preparatory work might look like is still emerging.
What is known is that there’s already a huge body of independent evidence to support the premise and overall validity of Health Stars, while also offering key areas for improvement.
We know, for example, that government-led schemes are more trusted, such that simple tweaks to the way Health Stars are led and reviewed could increase independence, protect from industry interference, and ultimately make the system more valuable to consumers.
We also know that despite attention on high profile outliers, Health Stars’ algorithm does score most things about right. Consumers will ideally believe this more when they see low ratings on all products that receive them, but it’s also important that we create processes for the algorithm to be reviewed periodically (and independently of industry) in the future to ensure it remains up to date.
In the 10 years since the policy was introduced, other countries have also implemented similar labels that can provide lessons, for example, on the value of adding specific colours or placement requirements to improve the visibility of the Health Star graphic.
The key will be balancing the potential merit of these refinements with the risk of slowing the main task of mandating what is already a reasonable system overall.
In particular, it is critical that a recently announced but less urgent review of back-of-pack nutrition labelling does not derail the priority task of finally bringing Health Stars to the front of all packs.
Twelve years to act
Australian and New Zealand governments have indicated they won’t introduce legislation until the industry misses its final 2025 target (and that is formally recorded and reported on).
The earliest realistic date when regulation requiring a mandatory Health Star Rating would begin roll-out would seem to be 2026, and this timeframe has also been suggested by the Federal Assistant Minister for Health and Chair of the Food Ministers’ Meeting, Ged Kearney.
That will be 12-and-a-half years since food and drink companies were first given the chance to commit to displaying the label. Surely that’s enough notice?
Australia and New Zealand would achieve a global first in transitioning a voluntary front-of-pack label to a mandatory one if this takes place.
Others countries, however, have gone straight to a mandatory front-of-pack label. By doing so they have avoided some of the hard experiences our governments have presided over when attempting close partnerships with the makers of unhealthy foods to promote health.
In this respect, Health Stars join a swathe of self-regulatory food policy initiatives with laudable objectives that have failed to deliver real health benefits in a voluntary form.
Australia’s experience also provides evidence for updating global guidance, including a new Draft Guideline from the World Health Organization on Nutrition Labelling, to explicitly recommend mandatory front-of-pack labels as best-practice in delivering maximum benefit to consumers.
It is a unique piece of evidence to support mandatory labelling.
Back home it’s great to see improved and visible government leadership to take meaningful regulatory action, including from Assistant Minister Kearney. More than 20 public health and consumer groups have recently reiterated their support for this to happen.
After a decade of government investment and failed industry commitments, it’s now time to translate proclaimed good intentions into real action.
Read Croakey’s extensive archive on the commercial determinants of health
