Yes - for Comparability with like products The current interpretation of the 'as prepared' guidance does not allow people to Consumer Group consumers easily or fairly compare similar products. Calculating HSRs as-prepared creates an uneven playing field, especially when companies are basing their HSRs on different directions for consumption. The current arrangements make it difficult for people to make food comparisons is the fact that food manufacturers are using the optimal preparation of their product to derive the highest HSR. No Comparability with like products One of the key purposes of the HSR system is to provide ' a quick standardised Industry peak body way to compare similar packaged foods at retail level'. It is important that if a and industry x2 product is sold in two versions (for example powdered and reconstituted) it carries the same nutritional information to avoid confusing the consumer. Any amendment to the' as prepared' rules should uphold the objectives of allowing consumers to compare like products. Yes - for Not aligned with HSR system objectives The current guidance on outcomes that do not align with the Consumer Group ‘as-prepared’ consumers desired HSR aims. It produces outcomes that are contrary to the objectives of HSRs and removes the ability for consumers to simply compare products within a category. Yes - for Not aligned with HSR system objectives Is not aligned with the aim of the HSR. Public Health consumers Yes - for Not aligned with HSR system objectives As it stands, companies are using the optimal preparation of their product to Public Health consumers derive the highest possible HSR. However, without the nuance of the sold’ and ‘as prepared’ comparison, and without any intuitive link between the HSR ‘as displayed and the actual contents of the packaging, the utility of the system to consumers is sacrificed to confer eligible manufacturers maximum marketing benefit. This is fundamentally and unacceptably at odds with the aims and objectives of HSR as a public health and consumer choice initiative and therefore, being part of the guide to industry rather than the algorithm (that has a five year no-change policy) ought to be rectified as soon as possible.
Yes - for consumers Comparability with like products The current interpretation of the 'as prepared' guidance does not allow people to easily or fairly compare similar products. Calculating HSRs as-prepared creates an uneven playing field, especially when companies are basing their HSRs on different directions for consumption. The current arrangements make it difficult for people to make food comparisons is the fact that food manufacturers are using the optimal preparation of their product to derive the highest HSR. Consumer Group No Comparability with like products One of the key purposes of the HSR system is to provide ' a quick standardised way to compare similar packaged foods at retail level'. It is important that if a product is sold in two versions (for example powdered and reconstituted) it carries the same nutritional information to avoid confusing the consumer. Any amendment to the' as prepared' rules should uphold the objectives of allowing consumers to compare like products. Industry peak body and industry x2 Yes - for consumers Not aligned with HSR system objectives The current guidance on ‘as-prepared’ outcomes that do not align with the desired HSR aims. It produces outcomes that are contrary to the objectives of HSRs and removes the ability for consumers to simply compare products within a category. Consumer Group Yes - for consumers Not aligned with HSR system objectives Is not aligned with the aim of the HSR. Public Health Yes - for consumers Not aligned with HSR system objectives As it stands, companies are using the optimal preparation of their product to derive the highest possible HSR. However, without the nuance of the ‘as sold’ and ‘as prepared’ comparison, and without any intuitive link between the HSR displayed and the actual contents of the packaging, the utility of the system to consumers is sacrificed to confer eligible manufacturers maximum marketing benefit. This is fundamentally and unacceptably at odds with the aims and objectives of HSR as a public health and consumer choice initiative and therefore, being part of the guide to industry rather than the algorithm (that has a five year no-change policy) ought to be rectified as soon as possible. Public Health
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