  The hard X-ray (2-10keV) luminosity of a star-forming galaxy tracks its
population of high mass X-ray binaries and is essentially unobscured. It is
therefore a practically unbiased measure of star-formation in the host galaxies
of gamma-ray bursts (GRBs). Using recent and archival observations of GRBs with
the XMM-Newton and Chandra X-ray observatories, limits are placed on the
underlying X-ray emission from GRB hosts. Useful limits on the current massive
star-formation rates (SFRs), unaffected by obscuration, are obtained for the
hosts of three low redshift GRBs: GRB980425, GRB030329 and GRB031203. These
limits show that though the specific SFRs may be high (as in dwarf starburst
galaxies), none have massive obscured star-formation at the levels implied by
the sub-mm detection of some GRB hosts. It is also shown that in cases where
the faint luminosities of the late time afterglow or supernova emission are of
interest, the contribution of the host galaxy to the X-ray flux may be
significant.
