Commercial interests in health policy dialogues: a qualitative content analysis of NEDLAC’s engagement with South Africa’s Health Promotion Levy

Non-communicable diseases (NCDs) are rising rapidly in South Africa, prompting the introduction of the Health Promotion Levy (HPL) in 2018 to reduce the consumption of sugar-sweetened beverages. However, the levy remains below the rate recommended by the World Health Organization. One of the central institutions involved in the policy process leading up to and following the introduction of the HPL was the National Economic Development and Labour Council (NEDLAC), a statutory body designed to promote dialogue between government, business, labour, and community constituencies. This study examined NEDLAC’s mandate and its actual role in the HPL process, with particular attention to the inclusivity and transparency of its deliberations. Using an exploratory case study design, the research drew on qualitative content analysis of documents obtained through an access to information request made under South Africa’s Promotion of Access to Information Act 2 of 2000. The findings indicate that NEDLAC’s engagement with the HPL process fell short of its mandate to advance social equity and inclusive participation in economic decision-making. Community representatives, one of NEDLAC’s four official constituencies, were absent from all deliberations on the levy. In contrast, business representatives dominated the discussions, often advancing arguments aligned with the interests of the sugar industry and emphasising potential job losses despite limited supporting evidence. Moreover, the process lacked transparency, particularly regarding the authorship of NEDLAC’s HPL Report and the presentation of evidence used to support its conclusions. NEDLAC’s handling of the HPL illustrates how participatory governance structures may, in practice, enable industry influence and weaken public health objectives. To enhance the integrity and effectiveness of policy dialogue on health-related fiscal measures, NEDLAC should adopt clearer procedural guidelines to ensure inclusive representation, strengthen transparency through public access to documentation, and institutionalise the role of civil society in its processes. Such reforms are essential to align participatory mechanisms with public health goals and to safeguard them from corporate capture.