The “health star rating” system that the Food Safety Standards Authority of India (FSSAI) plans to adopt in order to help consumers reduce their intake of unhealthy foods is “not evidence-based” and has failed to alter buyer behaviour, claim over 40 global experts in a letter to Union Health Minister Mansukh Mandaviya. They argue that “warning labels” instead have been most effective in various countries.
In a meeting on February 15, 2022, the FSSAI decided to adopt the “health-star rating system”, which gives a product 1/2 a star to 5 stars, in its draft regulations for front of package labelling (FOPL). The decision was based on the recommendations of a study by the IIM Ahmedabad the regulator had commissioned in September 2021. In the same meeting, the regulator decided that FOPL implementation could be made voluntary for a period of four years.
These experts have said the health star rating (HSR) system adopted in countries like Australia and New Zealand has not resulted into any meaningful behaviour change and that eight years after their implementation there is “ still no evidence of HSRs having a significant impact on the nutritional quality of people’s food and beverage purchases”.
For example, a systematic review carried out in 2019 that evaluated HSR labels through three randomised controlled trials found that they didn’t impact food purchases, such as calories or sugar or sodium purchased.
The letter written on April 18 has been endorsed by Barry M Popkin, University of North Carolina; Professor Tim Lang, City University of London; Mike Rayner from the University of Oxford; and Frank Hu from Harvard TH Chan School of Public Health, among others.
‘Misrepresents nutrition science’
Secondly, the nutrition researchers and academics argue that the HSR system “misrepresents nutrition science”. They explain that the underlying premise of the HSR is that positive ingredients such as fruits and nuts can offset negative nutrients such as calories, saturated fat, total sugar, sodium to calculate the number of stars ascribed to a product.
“This algorithm of adding and subtracting nutrients does not fit with our understanding of biology. For example, the presence of fruit in a fruit drink juice does not offset the impacts of added sugar in the body. There is no empirical evidence to suggest that adding these ingredients will lessen the negative impact of these foods on the body,” the letter asserts.
They also say that that the HSR system can lead to a “health halo”, which can confuse consumers as stars can be interpreted as an endorsement of a product.
They have called front-of-package warning labels such as black octagonal warnings that indicate when food and drink products are high in sodium, sugar, salt and fats as “the most effective models to date in informing consumers of the nutritional quality of packaged products”. This endorsement is based on evidence from countries such as Canada, Israel, Chile, Perú, Brazil, Argentina and Mexico that have made FOP warning labels mandatory.
Studies have shown that since the labels began appearing on packages in Chile in 2016, they have contributed to shifts in social norms and buyer behaviour in purchasing healthier foods and drinks and specifically they have reduced consumption of sugar sweetened beverages leading to reformulations of food and beverages in removing sodium and sugar.
The letter has raised questions over the IIM-Ahmedabad study and called its conclusions “completely wrong from a scientific perspective” and suspects “underlying bias or preference for the HSR”, which led to shifting outcomes to achieve favourable results. For instance, the experts say while the study found that warning labels were more effective in reducing consumer intention to buy products with harmful nutrients, it recommended HSR based on answers to subjective questions such as perceptions of different kinds of labels.
