Health Star Rating (HSR) System – Proposal P1067

About the Consultation

FSANZ Proposal P1067 – Health Star Rating System

The proposed reforms under Proposal P1067 would transition the Health Star Rating (HSR) system from a voluntary scheme to a mandatory front-of-pack nutrition labelling requirement across Australia and New Zealand.

The HSR system is designed to provide consumers with a simple and consistent way to compare the nutritional profile of packaged foods. The proposal follows concerns from Food Ministers that voluntary uptake targets were not achieved, with inconsistent implementation limiting consumer confidence and reducing the effectiveness of the scheme.

For industry, the proposal has implications beyond packaging design. Mandatory HSR requirements will influence how nutrition data, product attributes and regulatory information are managed across physical packaging, e-commerce platforms and digital product registries.

GS1 Australia’s submission highlighted the importance of globally aligned data standards and digital infrastructure in supporting consistent implementation, particularly as food labelling increasingly operates across both physical and digital environments.

How to Have Your Say

Stakeholders are invited to:

• Review the Consultation Paper and Supporting Documents released by FSANZ

• Provide responses through the FSANZ Consultation Hub

• Upload supporting submissions and evidence-based feedback

• Respond to the consultation questions relating to implementation, costs, digital labelling, consumer understanding and enforcement
  

Key Documents & Links

• FSANZ Proposal P1067 Consultation Page
• Proposal P1067 – First Call for Submissions
• Supporting Documents (SD1–SD6)
• FSANZ HSR Preparatory Work and Background Material
• Australian Dietary Guidelines and related evidence base

• Support for digital labelling approaches – GS1 Australia highlighted growing pressure on packaging space and encouraged consideration of standards-based QR codes and GS1 Digital Link technology as a mechanism to provide supplementary nutrition and consumer information digitally.

• Improved transparency and verification – Mandatory declaration of algorithm inputs and supporting nutritional data would improve trust, enable third-party verification and support future digital applications and consumer tools.

• Alignment between physical and digital retail environments – The submission noted the importance of synchronising changes to physical labels with digital product catalogues and e-commerce systems to ensure consumers receive consistent information regardless of channel.

• Phased and practical implementation – GS1 Australia encouraged sufficient transition periods and alignment with other packaging or nutrition changes to reduce unnecessary compliance costs for industry.

The accompanying discussion paper also outlined how initiatives such as GS1 Digital Link and industry programs like SmartFacts could support future-ready, digitally enabled nutrition communication and transparency.

Supporting Documents

• GS1 Australia Submission – Proposal P1067 Health Star Rating System (to follow - just finalising)

• GS1 Standards and the Health Star Rating System – Discussion Paper (to follow - just finalising)