Lobbying registrations by type of actor and initiative in favor of healthy eating
The voice of industry stakeholders dominated the lobbying landscape during the policy period of the Healthy Eating Strategy, as demonstrated by the proportion of filers affiliated with industry (88%) and businesses and organizations (90%) in lobbying registrations and number of interactions. between industry-affiliated stakeholders and TCPDs (86%). The study results show proportionately more interactions with industry stakeholders than a recent publication (86% versus 56%) that examined interactions with Health Canada on the topic of the Healthy Eating Strategy in using the MCHE database over a shorter period (24). Additionally, the results are consistent with a recent publication that examined lobbying in the context of marketing to children in Canada and the failure of Bill S-228 on marketing restrictions (23). The proportionately low number of non-industry stakeholders lobbying on the subject of the Healthy Eating Strategy is concerning given that they defend public health rather than economic interests.
Healthy eating initiatives of interest in lobbying registrations varied by stakeholder type. The vast majority (86%) of organizations and companies represented in lobbying registrations relating to marketing to children were affiliated with the industry. In addition to the food and beverage industry, the media and communications industry has also been actively involved in lobbying activities around marketing to children. This is not surprising, given that these industries may view marketing restrictions as a direct threat to their commercial and economic interests. Furthermore, this highlights economic actors beyond the agri-food industry who have direct interests in nutritional policies and who should not be overlooked when implementing measures to safeguard public policy development. . Although it is impossible to determine the impact of lobbying in this study, these results suggest that industry views were most important at the time when Bill S-228, which proposed restrictions on marketing was under consideration, which may have played a role in its eventual abandonment in 2019 (14, 31). These results are also consistent with the recent publication by Mulligan et al., which included data from both the Registry of Lobbyists and the MCHE database (23).
Canada’s Food Guide has also received considerable attention from the food and beverage industry, particularly the dairy industry. Partial restrictions on lobbying were put in place during the revision of the Food Guide to minimize potential conflicts of interest with Health Canada. In fact, officials at Health Canada’s Office of Nutrition Policy and Promotion, the office responsible for revising Canada’s Food Guide, did not interact with food and beverage industry stakeholders for the development process (12). Therefore, lobbying may have occurred, but only from other government offices or departments outside the Office of Nutrition Policy and Promotion. This is evidenced by the considerable number of industries that have directly mentioned the Food Guide in their lobbying statements. Although it is impossible to measure the impact of lobbying in this study, significant changes to the most recent version of Canada’s Food Guide suggest that these protective measures could have been effective. For example, despite intense lobbying from the dairy industry, dairy products were removed from the food group and placed in the general category of protein foods in the revised guide (32) reflecting current scientific evidence rather than economic interests.
The majority of companies and organizations registered to lobby on the issue of front-of-pack labeling (86%) were industry affiliated, and most were from the food and drink industry, in particularly in the dairy and “other food and beverage” industries. In fact, the dairy and beverage industries have expressed serious concerns that this type of labeling would unreasonably penalize their products (33,34,35,36). Remarkably, less than half (44%, not = 21) of all companies and organizations explicitly registered to lobby on the issue of front-of-package nutrition labeling. However, using the MCHE database, Vandenbrink et al. showed that in interactions between Health Canada and industry stakeholders, the most frequently discussed topic was front-of-package labeling (24). The differences in results may be explained in part by the deliberate exclusion of broad terms such as “nutrition labeling” from the current study’s search strategy, which provides a conservative estimate of lobbying on this particular topic, as well as by the different timing of it. The studies. Additionally, the present study identifies who signed up to lobby on the topic of front-of-package labeling, rather than instances of communication specific to front-of-package nutrition labeling; these may have been more numerous, but this could not be examined using the current dataset.
Less than a quarter of businesses and organizations signed up to lobby on the topic of nutritional quality of the food supply, a policy area that would primarily affect the processed and packaged food industry. In fact, most organizations and companies fell into the “other food and beverage production and manufacturing” category. The small number of organizations and companies that have registered to lobby on this topic may be explained by the voluntary nature of the sodium reduction goals (37), the historic nature of the initiatives on sodium and trans fats (initiated in the early 2000s (38, 39)), and the search strategy, which deliberately excluded lobbying records referencing historical trans fat and sodium reduction initiatives (Supplementary Table S1) to obtain a conservative estimate of lobbying activities.
Although this study is unable to assess the causal effect of lobbying, this lobbying data may reflect the political direction and current status of the Strategy’s main policies: the only initiative with extensive safeguards during the policy development process (i.e., Canada’s Food Guide) resulted in significant changes and successful implementation. On the other hand, the policy that received the most attention from the industry (i.e., marketing to children) resulted in implementation failure. Additionally, front-of-pack labeling, for which there was pressure and no additional safeguards put in place, was not implemented as of publication date. On the other hand, initiatives relating to the nutritional quality of the food supply received only some lobbying attention, which may be related to the fact that there was little action immediately required from the share of the food industry (for example, given the voluntary nature of sodium reduction). initiative).
Communications by type of stakeholder and classification of public office holders
Industry-affiliated stakeholders have been shown to have more interactions with TCPDs of all ranks, including those in higher positions of power, than non-industry stakeholders. In fact, industry-affiliated stakeholders were responsible for 14 times more communications with the two highest ranks of TCPDs (within “parliamentarians and their staff”) compared to non-industry stakeholders, suggesting rules unequal playing field and a strategic advantage of the industry to influence the government. civil servants. Access to policymakers in positions of power has been studied in Australia, where food industry players have been shown to have strategic relationships and access points to policymakers, providing them with greater lobbying ability and influence on nutritional policy compared to other professionals (22).
Boundaries
There are many limitations to the data available in the Registry of Lobbyists. First, lobbying activities have probably been underestimated to the extent that Lobbying law does not require registration of private citizens, volunteers and in-house lobbyists when lobbying is not a significant part of their organization or corporation’s functions (30). Second, because the content of each specific communication is not disclosed, communications can relate to any topic declared by a registrant who has registered to lobby on the topic of the Healthy Eating Strategy in name of an organization or company. To address this issue, the present study analyzed both recordings and instances of communication; the results should be considered in light of this limitation. Additionally, the Registry’s communications data, used to classify TCPDs, was sometimes incomplete (e.g., the unit of direction was missing from the entry), requiring assumptions related to the government official’s position. For example, TCPDs were assumed to have represented the same management unit if they were present in multiple communications as long as their title and institution remained the same. Targeted online searches were conducted when necessary (i.e., if missing information was needed to classify TCPD). Additionally, some TCPDs held more than one position at a time, and only one of these positions was listed on the register. Therefore, for those with a dual role (e.g. where a minister is also a member of Parliament, two distinct roles in our rating system), the ranking was based on the title indicated in the specific communication. A recent report from the Commissioner of Lobbying offers preliminary recommendations to improve Lobbying lawin Canada (40). These recommendations would address many of the limitations outlined in this study, such as changing the threshold for recording internal lobbying activities and expanding reporting requirements for communications reports.
Finally, the search strategy used to identify lobbying activities in the context of the Healthy Eating Strategy likely presents a conservative estimate of lobbying cases. First, initiatives were only taken into account if they were explicitly mentioned by the declarant. Additionally, general terms such as “labeling” and “nutrition” were omitted as not specific to the Healthy Eating Strategy, although they could include discussion of associated policies and initiatives. Second, two initiatives (Nutrition North Canada and changes to Nutrition Facts tables) were excluded from the study.
