Mandating the Health Star Rating: What Happens Next — and What Should Be Considered?
Health Ministers recently asked Food Standards Australia New Zealand (FSANZ) to prepare a proposal to mandate the Health Star Rating (HSR) system within the Australia New Zealand Food Standards Code. The decision follows voluntary uptake reaching 39% in Australia and 36% in New Zealand — well below the agreed 70% target.
Despite the tone of recent media coverage, it is important to clarify that mandating the HSR is not yet a done deal. FSANZ has been asked to develop a formal proposal and undertake two rounds of public consultation before reporting back to Ministers for a final decision. That process matters as it provides an opportunity for industry, health professionals and stakeholders to contribute constructively to the discussion.
At Food & Nutrition Australia, we recognise the intent behind front-of-pack labelling systems — to simplify nutrition information and assist consumers to make informed choices. However, we also believe this moment warrants deeper reflection on whether the HSR, in its current form, is the right tool to mandate.
Reducing Food to a Formula
The Health Star Rating is fundamentally a nutrient-profiling algorithm. It assesses foods based on a balance of “negative” nutrients (such as saturated fat, sodium and energy) and “positive” components (such as fibre, protein and fruit/vegetable content).
While this approach provides a standardised scoring method, it also reduces food to a mathematical formula — effectively translating complex, culturally embedded foods into a single number between 0.5 and 5 stars.
Food, however, is not just a collection of isolated nutrients. It exists within dietary patterns, portion sizes, culinary traditions and social contexts. A system that assigns a summary score risks reinforcing the idea of “good” and “bad” foods — rather than supporting balanced, overall dietary habits.
Many foods that would receive lower star ratings are foods typically consumed occasionally or in small amounts. The presence of a low rating on some of these products may not necessarily improve dietary behaviour, but it may increase confusion — or even guilt — around food choices.
Whole Foods and Category Anomalies
While not intended to be used on whole foods, the HSR has been adopted in many instances. For example, on packaged nuts, fresh milk, natural yoghurt, frozen fruit and vegetables and canned legumes. The application of the HSR system to whole foods however raises important questions.
Eggs, for example, receive 4 stars under the current algorithm. Yet eggs are widely recognised as one of the most nutrient-dense foods available, providing high-quality protein along with a broad range of essential micronutrients, none of which are accounted for in the HSR algorithm. Some stakeholders argue that eggs should automatically receive 5 stars because of their high nutrient density. Others note that the system was never designed for minimally processed whole foods and therefore no exemptions will be applied.
This highlights a broader issue: how should whole foods be treated under a mandatory scheme?
If the HSR becomes compulsory, clarity will be needed regarding exemptions. Will fresh meat, eggs, dairy, fruit and vegetables be excluded? How will fresh, whole, processed, unprocessed be defined? Will single-ingredient foods be treated differently from formulated packaged products?
Without careful consideration, mandating the system could inadvertently create inconsistencies or distortions that do not align with broader dietary guidance.
Consumer Understanding: A Persistent Challenge
Ministerial statements also referenced consumer research showing strong support for the HSR concept — alongside ongoing misunderstanding about how it should be used.
The HSR is intended to help consumers compare similar products within a category — for example, one breakfast cereal against another — rather than compare entirely different foods. Yet many consumers interpret it as an overall health endorsement or a ranking across the entire food supply.
If confusion persists under a voluntary system, the question becomes whether mandating the label will resolve that misunderstanding — or simply scale it.
Effective nutrition communication requires context. A front-of-pack symbol cannot replace broader education about dietary patterns, portion sizes and food diversity.
Trust, Transparency and Unintended Consequences
Ministers expressed concern that low uptake has undermined the system’s effectiveness and consumer trust.
However, mandating a system that remains contested may introduce new tensions — particularly if sectors perceive the algorithm as misrepresenting their products or failing to reflect nutritional nuance.
There is also the broader behavioural question: does rating food numerically risk reinforcing moral judgments around eating? In an era where disordered eating patterns and food anxiety are rising, the framing of food as “higher” or “lower” in stars deserves careful consideration.
The Role of Consultation
The next stage — FSANZ developing a formal proposal and conducting public consultation — is critical.
This process provides an opportunity to ask important questions:
Which foods should be exempt?
Should whole, minimally processed foods be treated differently?
Does the current algorithm appropriately reflect nutrient density and dietary guidelines?
How will consumer education be strengthened alongside any regulatory change?
What are the implementation costs and reformulation pressures for industry?
Mandating the HSR would represent a significant regulatory shift. It needs to be informed not only by uptake targets, but by evidence of effectiveness, clarity and alignment with broader public health strategy.
A Call for Thoughtful Engagement
At Food & Nutrition Australia, we support transparent, evidence-based nutrition policy that supports people to eat better. We also believe that food is complex — biologically, culturally and socially — and that front-of-pack labelling systems must be evaluated through these broader lenses.
The coming consultation period is an opportunity for respectful, evidence-led discussion.
Is mandating the Health Star Rating the right next step?
Or is this the moment to refine, or change, the system to better reflect the diversity and complexity of our food supply?
We encourage stakeholders across the food value chain to engage thoughtfully in the process.
The future of food policy deserves nothing less.