Understanding the Politics of Food Regulation and Public Health: An Analysis of Codex Standard-Setting Processes on Food Labelling

Background: The importance of the international food regulatory system to global health, is often overlooked. There are calls to reform this system to promote healthy and sustainable food systems centred on the Codex Alimentarius Commission (Codex), the United Nation’s (UN’s) standard-setting body. Yet this presents a significant political challenge, given Codex has historically prioritized food safety risks over wider harms to public health, and is dominated by powerful food exporting nations and industry groups with a primary interest in trade expansion. To better understand this challenge, we examine who participates and contests Codex standards, using the development of the new Guidelines on Front-of-pack Nutrition Labelling (FOPNL) as a case study. Methods: The study involved: (i) collecting Codex Committee on Food Labelling (CCFL) documents (2016-2023); (ii) identification, categorization, and enumeration of actors involved in the development of the Guidelines; and (iii) guided by a constructivist framework, analysis of how actors framed and contested key provisions of the Guidelines. Results: Country representation was skewed towards high-income (47.9%). Member state delegations were dominated by non-health ministries (59.8%) and industry actors (16.1%). Industry actors comprised the large majority of observers (84.2%) and civil society actors representing public health interests the least (12.2%). Commercial actors used frames supporting positive FOPNL messages (eg, low in salt) opposing negative ones (eg, "high-in" sugar warnings) and called for product exemptions (eg, sports foods and baby foods). Public health actors used frames supporting simplified FOPNL to reduce consumer confusion, that hold up public health goals, and prevent inappropriate marketing. Conclusion: Participation in the Guidelines development process suggests stronger preferences for trade facilitation and commerce over public health. Ambitions to reform the international food regulatory system may require an examination of who participates and how to address this asymmetrical representation of interests. These results suggest the need to greatly strengthen public health representation at Codex.