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Moving from silos to synergies: strengthening governance of food marketing policy in Thailand | Globalization and Health

Interests

Several actors from health sector identified restricting unhealthy food marketing such as UPF as an issue that the government should be prioritizing. Civil society actors and technical experts remarked on the importance of a clear understanding of food marketing practices, especially their concerns on the adequacy of existing controls given developments in digital media, but not specific to marketing of food products.

Traditional forms of controlling the marketing of consumer products is not keeping pace with the advertisers and marketing agencies (TE1).

A number of actors from government, technical expert and international organisation supported tighter controls on food marketing and some viewed UPF as priority target or “low-hanging food to target” (IO1). One government actor supported that “if I had to choose just one target, it would be the UPF that has to be taken out of the Thai diet” (GO3). Meanwhile, another government official indicated that “in any policy discussion, the health of the consumer is always the sub-text. ‘Safety first’ is the overriding principle” (GO5).

Participants from government, technical experts and food and advertisement industry acknowledged the existence of collaboration within and between a range of government and non-governmental organisations. The connection between government organisations and the food industry was frequently noted, with some participants linking such relationships to the reluctance among government actors to intervene and/or the desire to align with interests of key food industry actors.

It would not be a constructive approach since industry is already skeptical of us. They do not want any interference in their business. […] if we classify foods as “healthy” or “unhealthy” then it is a form of stigmatizing products or parts of the food industry, and that will create enemies in a hurry. If we portray a product as evil, then we will never be able to get cooperation from Industry to improve food marketing policy and practices (TE1).

Some government, civil society and international actors cited tensions between institutional interests across economic and health spheres. Economic development was prioritised over health by some government actors in non-health departments, therefore obstructing a food marketing regulation agenda. One civil society actor expressed difficulty to work with some Ministries due to conflicting economic interests which make food marketing issues highly salient.

My view is that it would be more difficult to try to push change through the Ministry of Commerce since they are so closely linked with the economy. Thus, they don’t really want to team up with us (since our campaign would reduce sales of certain products if successful) (CV4).

Institutions

Formal structures

Participants from all sectors except the food and advertisement industries described inadequacies of existing organisational structures within government and coordinating mechanisms as posing challenges to introducing policy restrictions on food marketing. This was attributed to national institutional arrangements that had been insufficient to support and link relevant actors to help introduce such policies, especially regarding authority, cross-sectoral issues, and power imbalances.

So the center of power depends on which aspect of marketing you are looking at. […], there are two power centers: The Office of the Consumer Protection Board and the FDA [Food and Drug Administration]. If they can join forces and draft new laws, and then work with the Ministry of Digital Economy and Society and the NBTC [Office of the National Broadcasting and Telecommunications Commission] to develop some controls, then that should provide broad protections (TE1).

Relevant government departments and agencies were regarded as having fragmented responsibilities and restrictions on their roles, and as such there is reluctance among the departments to extend their mandates or take responsibility for action in this space. It was perceived by one international actor (IO1) that food marketing agenda is “so cross cutting” as it “sits in many different agencies, so it has many masters and no real owners.”

Government departments were viewed as working separately from each other due to different policy objectives, limited authorities and “the changing powers-that-be” (CV4). Accordingly, they failed to find ways of working across silos, and as such failed to effect policy.

the NBTC had control over the dozens of TV channels on air, but they did not want to exert that control. There was no agency to step up to control content. The Board of the NBTC was basically a policy unit, while the units with the mandate to act were the line agencies within the NBTC. But those agencies first needed a policy from the Board in order to act. Further, the agencies didn’t feel they had enough manpower to implement that kind of policy on broadcast content. So, they focused on other areas that were easier to control (CV4).

To tackle the problem of siloed working, one government actor reported that their department has created formal mechanisms to “improve collaboration through the task force mechanis” so that it can “advocate on this very [marketing] issue and produce some concrete results” (GO3). Other government actors described a primarily “rule-bound sense” of policy process with limited discussion on formal mechanisms or dynamics.

we would like to be involved more with online marketing. Now, all we can do is to ask for the cooperation of the online platforms to police themselves and alert us if something does not meet [our] standards or is unsafe. We have some MOUs in this regard […] We are restricted in how far we can reach into marketing practices. So, there will have to be changes to the law. Somebody has to set some standards. If we go too far in controls, we could be sued (GO5).

However, these formal mechanisms were viewed by technical experts and civil society actors as insufficient for promoting coordination across departments and sectors and advocating for policy and better nutrition. One technical expert felt that “the legal process is too slow and inflexible to adapt to the rapidly changing marketplace. […] It’s like we are chasing our own shadow” (TE1).

Informal structures

Some participants viewed informal structures, spaces or networks such as personal contacts and informal one-to-one meetings with policy makers or law makers themselves, as creating significant opportunities for influencing policy decisions. Some government actors reported setting up informal meetings at first to “set some targets and define the stakeholders” (GO3) and “check existing evidence and explore who might support or oppose the policy” (GO7). Civil society and technical actors used informal channels to access information from other actors in policy network.

I think it would be more in the non-formal meetings where the final decision takes place. Usually, after the large, open meetings take place, then there will be a smaller group which meets to take stock of what the direction should be. The policy makers have their own, larger agendas which they need to adhere to. Sometimes, they realize that it won’t be possible to get a consensus among the academic/technical specialists since there is not enough evidence. So, they proceed with an ad hoc decision based on an informal consultation (TE4).

Broader policy context

The WHO’s “Set of recommendations on the marketing of foods and non-alcoholic beverages to children” [2] was identified by several interviewees as a national and/or regional roadmap that could guide the government on designing new policies to reduce the impact on marketing of unhealthy foods to children.

Currently, there is more collaboration among ASEAN member countries, and some have stepped up to host the advocacy effort to control cross-border marketing. A minimum set of recommendations for advocacy is included in the 2025 Plan of ASEAN, and members will review the full set of WHO recommendations to see which they can collaborate on (GO3).

Some actors suggested a more comprehensive, multi-sectoral approach for food marketing that can empower people, families and communities to take control of their media use behaviours.

It’s not like there is one organization you can appeal to for change [in food marketing]. It has to be a family-driven and community-based approach to control online media. What is more, people on the Internet are using Avatars to hide their identity. So, it is becoming increasingly difficult to identify who is who on the Internet. So, this problem extends way beyond food marketing. It has to be addressed holistically – not just sector by sector. This is because it is threatening to transform entire societies and economies. So, any approach has to be broader than health (TE4).

Some government and civil society actors also remarked on “catalytic events” that pose opportunities for increasing marketing restrictions by creating venues for policy discussions where nutrition actors can seek a seat at the table and position nutrition within the larger policy issues such as discussions of “Thailand 20-year Strategy”, “Sustainable Development Goals” and “Global NCD targets,” and “visits by United Nations Interagency Task Force on NCDs” (GO2, GO7, CV2).

It was noted by one food industry actor that food and nutrition standards setting should be primarily based on societal conditions such as modernisation and food innovation.

With modernization, people now can buy processed food and beverage that can be stored almost indefinitely and still be pure and safe to consume when needed. This also means that nutritious food can be distributed to even the most remote parts of the world and still retain its flavor and nutritional value. There is also the convenience factor of being able to buy a food or beverage and then consume it at one’s leisure. As society becomes more mobile, processed food and drink will become indispensable. We will never go back to ancient times when all food and water had to be collected and consumed where one lived (IS1).

Ideas

Participants from all sectors discussed the influence of “technical norms” on government decision making, through appeals for evidence-based decision-making, or by “external reference points” to the evidence produced by the WHO or other authoritative sources regarding efficacy.

We have had repeated consultations with the WHO in this area about recommendations for control of food marketing […] If the scientific evidence is strong, then it is easier to forge cross-sector collaboration […] then industry will cooperate (GO3).

Some government in health sector and civil society actors remarked on the idea of “social proofing” where they use experiences of other governments where their adopted policy is successful to help them determine actions.

Japan had been successful in controlling advertising by working through their Ministry of Commerce. They used a strategy of equality in advertising. […] the Ministry of Commerce argued successfully that the producers had created a virtual monopoly by using prize drawings as an incentive. […] suggested that we try to work through Thailand’s Ministry of Commerce (CV4).

Despite these acknowledgements, some government actors felt about unclear evidence, proving potential harm of unhealthy food marketing to health.

I don’t think that connection is that clear yet. Marketing is geared toward generating profits and expanding the business. Health is probably not seen as an additive factor in that equation. Health is a rather complex and abstract concept, and food is just one component of that. […] It is too complex to say that this food will always be good for you or that another food is always harmful (GO5).

The commitment to evidence-based policy making was also articulated by one food industry actor. This was accompanied by raising concerns about the relevance and quality of research findings and bias on selection of data for analysis, drawing on examples relating to sugar-sweetened beverage taxation.

I respect any scientific evidence if collected in good faith. But some of the food quality studies might have suffered from methodological weaknesses. They might not have done control trials. There is the case of the “Australian paradox” which found that after implementing controls on sugar consumption, the rates of diabetes and related NCD did not decline. New Zealand has looked at the impacts as well, and they decided not to impose a sugar tax since there was no clear evidence that doing so would improve health outcomes and reduce NCD related to sugar consumption. So, I think Thailand’s imposing a sugar tax was probably not too fair. However, if industry funds the research, then people won’t believe the findings (IS1).

There was a strong emphasis on consensus building with food industry as important influence on agenda-setting in policy to restrict food marketing.

instead of trying to punish industry and food marketing of unhealthy foods, we can take a more positive approach and encourage them to focus more on these food innovations that are becoming popular around the world. That way, we would be allies and not adversaries (CV4).