FSANZ is asking: should Health Star Ratings be mandatory?

On 7 May 2026, Food Standards Australia New Zealand opened the first call for submissions on Proposal P1067, which considers whether the Australia New Zealand Food Standards Code should be amended to require packaged foods to display an HSR symbol. Submissions close at 11:59 pm Canberra time on 21 June 2026. If you make and sell packaged food, this is the moment to weigh in, because what you say in the next few weeks will shape what your labels look like for years.

Here is what FSANZ is actually asking, and why this proposal deserves your attention.

Why this proposal exists right now

The short version: industry uptake fell short of what ministers expected. The voluntary HSR system has been in place since 2014, with a target of 70% of intended products displaying the rating by 14 November 2025. By the time the deadline arrived, fewer than 40% of eligible products were carrying it. On 13 February 2026, food ministers asked FSANZ to prepare a proposal on mandating the system, and P1067 is the result.

FSANZ’s position, based on its preparatory work since 2024, is that mandating HSR appears warranted. The agency points to consumer research, focus groups, technical assessments, and analysis of the HSR algorithm itself to support the view that interpretive front-of-pack labelling can help consumers better understand the nutritional profile of foods and make more informed choices. The argument is that inconsistent uptake across products limits the system’s effectiveness and erodes consumer trust, and that a mandatory approach would deliver consistency, comparability, and accessibility that voluntary uptake has not.

That is the case being put forward. The submissions process is where stakeholders get to test it.

What FSANZ is actually proposing

The first call for submissions sets out three core regulatory approaches. Understanding each one matters because they are not abstract; they will reshape how your packaging looks and what your team needs to calculate.

The first proposal is that the HSR symbol would be required on most packaged foods for retail sale where a Nutrition Information Panel is required. That is a broad scope. If your product carries an NIP today, you should assume the proposal would capture it unless there is a specific exemption.

The second proposal is that the design and location of the HSR symbol would be standardised. Under the current voluntary system, there is style guidance, but there is no enforceable rule in the Code about exactly how the symbol must appear or where it must sit on the pack. Mandating both would remove discretion and force consistency across categories that currently look quite different on shelf.

The third proposal is that the use of a prescribed HSR algorithm would be required. The HSR algorithm is the calculation that translates a product’s nutrition profile into a star rating, and it has been refined since the system launched. Locking the algorithm into the Code means a single, enforceable method for every brand, no proprietary interpretations, no informal variations.

FSANZ has also flagged that consumer education will sit alongside any mandating decision. Stars on pack only deliver value if consumers understand what they mean.

What FSANZ wants you to comment on

This is where founders and food brand decision-makers often get stuck. The proposal is open for comment, but the consultation paper does not just ask “do you support this?” It asks for evidence and stakeholder views on a series of specific technical questions, and the supporting documents released on 7 May give you a strong signal about where FSANZ wants input.

There are six supporting documents released with the call for submissions, and each points to a focus area where evidence would carry weight. There is a consumer literature review covering how shoppers interpret and use HSR. There is a nutrition labelling focus group report on consumer understanding. There is a performance assessment of the HSR algorithm itself, including how it ranks foods within and across categories. There is a technical evaluation of the symbol design and how it is presented on the pack. There is a broader technical assessment, and there is a preliminary cost-benefit analysis.

If you are running a food business, the cost-benefit document is the one I would not skip. It outlines what FSANZ believes the regulatory burden of mandating HSR would look like for industry. If your real-world implementation costs, software, packaging redesign, algorithm verification, product reformulation decisions, and ongoing compliance differ from what FSANZ has modelled, that is exactly the kind of evidence the agency needs to hear.

The algorithm performance document matters too, particularly if you sell in a category where you believe the HSR poorly reflects nutritional reality. Concerns about how the algorithm treats specific food groups have been part of the HSR conversation for years. This is the formal channel to raise them, backed by data.

Why submissions from smaller brands matter more than people assume

There is a misconception in the food industry that consultation submissions are the domain of large manufacturers and peak bodies. That is true in terms of volume, but it is not the full picture. FSANZ assesses submissions on their merit and on the evidence they bring, not on the size of the organisation behind them.

If you operate a small or mid-sized brand and a mandatory HSR would meaningfully affect your packaging, your formulation, or your category positioning, your submission is exactly the kind of input the process is designed to capture. The first call for submissions is the moment to put concerns on the record, including concerns about scope, exemptions, transition timelines, and the practical implications for businesses operating without large regulatory affairs teams.

This proposal is being assessed under FSANZ’s major procedure, which means two rounds of public consultation. A second round, focused on the draft variation to the Code, will follow once FSANZ has worked through the feedback from this round. Comments made now help shape what that draft actually looks like. Waiting until round two to engage means responding to a proposal that has already been substantially formed.

How to make a submission

Submissions are lodged through the FSANZ Consultation Hub, and the consultation page links directly to the submission portal: consultations.foodstandards.gov.au/fsanz/p1067-health-star-rating-system. The call for submissions document and all six supporting documents can be downloaded from the P1067 proposal page on the FSANZ website.

The hub allows you to upload a written submission and respond to specific consultation questions. You can mark commercially sensitive information as confidential. Submissions will be published on the FSANZ website following the consultation period unless marked confidential.

FSANZ will also hold stakeholder webinars during the consultation period to support understanding of the proposed approaches. If you want to be on the list for those, you can join the FSANZ HSR mailing list by emailing nutritionlabelling@foodstandards.gov.au.

Submissions close 11:59 pm Canberra time on 21 June 2026.

If you are not sure whether your product would be captured

Most brands underestimate how broadly a mandatory HSR could land. If your product carries a Nutrition Information Panel today, the proposal would likely capture it, and “likely captured” is not where you want to be sitting when a draft variation lands and the transition clock starts.

The brands that move first will be the ones who understand the proposal now, draft considered submissions, and start scenario-planning their packaging and formulation before the second round of consultation. The brands that wait will be reacting to a Code change that has already been substantially shaped without their input.

If you want a clearer picture of where food brands commonly go wrong with labelling and health claims well before the HSR conversation even enters the room, download our FREE guide on the six biggest labelling and health claim mistakes we see in practice.
Get the free guide: https://learn.nprconsulting.com.au/labelling-health-claims