FSANZ Health Star Rating Submission Guide for Olive Growers
Food Standards Australia New Zealand (FSANZ) is currently conducting a survey regarding a potential mandate for the Health Star Rating (HSR) system. The current HSR algorithm is fundamentally flawed when it comes to edible oils, often penalising pure, natural Extra Virgin Olive Oil (EVOO) over highly refined seed oils.
The Australian Olive Association is making its own submission, but every submission counts in ensuring our industry isn’t unfairly penalised by a rigid unfit algorithm. To make it as easy as possible for you to lodge an official response by July 5 and protect our industry, we have put together a submission guide.
This guide highlights the most critical survey questions and provides draft wording you can copy, adapt, and use for your own business submission.
Why Your Submission Matters
If the HSR becomes mandatory under the current rules, it poses a direct threat to how consumers view EVOO. Here are the key issues our industry needs to highlight in this survey:
- The Algorithm is Not Fit for Purpose: The current system relies too heavily on a simple saturated fat calculation. It completely ignores the degree of processing, refining, oxidative stability, and the rich bioactive compounds that make EVOO a healthy choice.
- It Risks Misleading Consumers: Mandating a flawed system could drive consumers toward heavily processed oils and away from natural foods, entirely contradicting decades of nutrition science.
- Inconsistent and Unfair Scoring: Because edible oils are single-ingredient products, a tiny compositional variation of less than 1g of saturated fat per 100g can alter a product’s rating by half a star. This means two identical bottles of EVOO could end up with different ratings depending on the database used.
- Severe Commercial Consequences: Scoring below the 3.5-star threshold isn’t just bad PR. It can actively disqualify EVOO from being used in school canteens, institutional menus, and government-funded programs, or being featured in major retail promotions.
How to Use the Submission Guide
The HSR submissions guide document outlines the exact questions FSANZ is asking, along with pre-drafted responses tailored for olive growers.
- Open the Survey: Access the FSANZ consultation portal here.
- Locate the Key Questions: The survey questions are not mandatory – you only need to answer the questions that have been highlighted in the HSR submissions guide document.
- Customize the Wording: We have included template language (e.g., “I/we/[insert company] do not support…”) that you can easily personalize with your own business details.
- Demand an Exemption: Our collective voice needs to be clear—edible oils and cooking fats must be exempt until the algorithm is independently reviewed and made fit for purpose.
Our Core Message: We support clear front-of-pack labelling, but EVOO is not just a source of fat. It is a minimally processed food with a massive body of evidence proving its cardioprotective and anti-inflammatory benefits. The HSR needs to reflect that science.
Please take 15 minutes out of your day to complete the survey. Every submission counts in ensuring our industry isn’t unfairly penalised by a rigid algorithm.
Submissions close 5 July.