Arguments used by trade associations during the early development of a new front-of-pack nutrition labelling system in Brazil

Objective: To analyse the arguments used by the food industry during the early development of the new nutrition front-of-pack labelling (FOPL) in Brazil. Design: A thematic qualitative analysis was performed using an inductive approach. All data were collected and analysed between December 2018 and April 2019. Data included documents published by the Brazilian government, including industry's contributions to a technical public consultation, as well as industry material and newspaper articles. Setting: Brazil. Participants: Seven trade associations and one industry group. Results: During the early stages of the FOPL policy development, food industry actors presented themselves as legitimate actors, by highlighting their economic contribution to the country, their role in safeguarding consumers' right to choose and their range of solutions in addressing the non-communicable disease epidemic. They also questioned the policy process by criticising the role of the Brazilian Health Regulatory Agency and the science that informed the policy. Finally, food industry actors highlighted the supposedly lack of coherence between national, regional and international policies, as well as other socio-economic risks. A small set of evidence published in non-academic, non-peer-reviewed reports was used by industry actors to support these arguments. Conclusions: Collectively, these arguments reinforced the position of the food industry as a necessary part of the discussion on FOPL and shifted the blame away from unhealthy products to individual behaviours. It is crucial that public health initiatives, such as the introduction of a new FOPL, are no co-opted and negatively influenced by economic actors who may try to delay the policy process.