Responses from commercial actors acknowledged the necessity of acting to address obesity, but universally opposed the sugar tax as a means of doing so. In general, obesity was framed by these actors as a complex, multifaceted problem:

The causes of obesity however are numerous and are a complex combination of too much food consumption and far too little physical exercise by modern society. (Local business)

One possible outcome of this framing is an implicit rejection of obesity as an ‘industrial epidemic’,[29] driven by the activities of the ultra-processed food industry. Instead, causation is attributed to multiple complex factors:

Obesity is largely the result of an imbalance in excess energy consumption and too little energy expenditure over time… obesity has been fuelled by a variety of complex environmental, social, economic, behavioural, and/or other factors. (International business association)

This framing may thus serve to both deflect attention from commercial activity as a driver of obesity and diminish the potential effectiveness of an intervention focusing on just one element of this complex causation. For commercial actors, the ‘complexity’ framing thus supported their opposition to the proposed sugar tax on the basis this was not addressing most of the (complex) drivers of obesity.

Alongside this ‘complexity’ framing (used here to cast doubt on the efficacy of sugar taxes as a response to obesity), commercial actors employed three framings that supported their suggestions for alternative policy responses. These focused on partnership approaches between the health sector and industry, the role of the market in providing a range of products (emphasising the health benefits of those products), and the importance of personal responsibility in addressing the causes of obesity.

This frame suggests that obesity will be solved through a partnership approach. Commercial actors strongly favoured this frame – i.e., for business to be present alongside government in developing responses to obesity – with public-private collaboration depicted as the most promising way forward. This argument was reinforced by the complexity framing: the rationale being that, since obesity is caused by a complex system, it requires a ‘holistic’ approach and the involvement of industry to develop suitably innovative ‘solutions’. The partnership framing was evident in submissions across the range of commercial respondents, with the scale of such partnerships ranging from international (“the global community”) to local (”all Bermudians”):

… members have long made robust commitments to help address some of the complex health and nutrition-related challenges facing the global community… These types of partnership-based initiatives are more effective than taxes in lowering the amount of calories consumed and making a positive impact on public health/obesity. (International business association)

Adopting a multi-stakeholder approach, including Industry-Government partnership is really important in achieving a team effort to address this important issue. The food industry has a key responsibility and members recommend to partner with the Government in addressing this issue with a holistic approach. (Regional business association)

… we must all work together to try to do everything possible to ensure a healthy future for all Bermudians (Local business).

The partnership framing presented the ultra-processed food industry as a responsible social actor whose voluntary actions demonstrated a collective commitment to reducing obesity:

There is also a strong industry commitment regarding responsible communication to consumers, for example controlled marketing to children; innovation as well as renovation to significantly reduce levels of sugar, fat, saturated fat and salt; nutrition labelling to support consumers in making healthy choices; guidance on recommended serving sizes; and voluntary front of pack nutrition labelling. (Regional business association)

In addition to positioning themselves as important partners in policy making, the International Council of Beverages Associations argued their industry delivered important economic benefits that also supported health. Taxation was thus presented as inappropriate since it would not only undermine partnership between industry and government, but would have a detrimental impact on health:

The economic impact of selective taxation may also have detrimental effects on health. The economic growth created by beverage and retail industries contributes positively toward health outcomes… By singling out sugar and/or SSBs for discriminatory tax treatment, governments… are pursuing policies that have a disproportionate detrimental impact on the very populations they are supposed to help, and therefore may worsen health outcomes. (International business association)

Local businesses placed particular emphasis on the threat the proposed sugar tax posed to existing partnerships. They argued the tax would damage tourism and hospitality, which were central to the Bermudian economy. By emphasising this centrality, local businesses effectively argued that a sugar tax would threaten the sustainability and even the identity of the Bermudan community:

Bermuda must avoid any change that could hurt the hospitality and tourism industry as both are so imperative to our economy. (Local business)

At this point we really need to ask ourselves, “Are we truly in the hospitality industry or not?” If we accept the tax, I would suggest our answer was a loud “No!” and we better start looking for another pillar to our economy. (Local business)

Commercial respondents also sought to present the market as a source of alternative ‘solutions’ to obesity and other health challenges. Arguments here emphasised the value of a diverse market providing options to address a range of needs, including products that were nutritious, pleasurable and beneficial sources of energy. Within this range a consumer would be able to select a varied and ‘balanced diet’.

Regional and local business actors described products high in sugar as an important source of energy, which in turn could promote exercise:

Sugar sweetened beverages and other food products with added sugar contribute energy to consumers. (Regional business association)

Sports drinks, while containing added sugar, are formulated to help replenish the nutrients athletes lose (including sugars)… Sports drinks are marketed towards active consumers and encourage people to exercise, which is important to help improve the health of Bermudians. (Local business)

Several respondents also sought to present these products as providing important nutritional value:

Some of these products are fortified with other micronutrients (vitamins and minerals) that contribute to meeting these daily nutrient reference values. (Regional business association)

Putting a tax on “plain” sugars… will discourage the home made process of creating foods of potentially the best nutritional value of all. (Local business)

100% juices and milk-based beverages are inherently nutrient dense (International business association).

A related argument sought to present high-sugar products as beneficial for emotional wellbeing. As with the claims above, this argument suggests the proposed sugar tax may have unintended adverse health effects because consumption of these products can bring health benefits. It also implies that the products themselves are not unhealthy; rather, health risks (such as obesity) arise when people fail to consume them in moderation:

The whole concept of the tax is to discourage people from partaking in a pleasurable experience which, in moderation, is not harmful… this is paternalistic governance at its most invasive (Local business).

As a mother I actively reduce my children’s intake of sodas and ‘junk foods’, as an individual I’ve developed a healthy diet and increased my exercise programmes, as an employer I have implemented 90-day health and fitness programmes for my bakery team. All of these health initiatives allow for the moderate consumption of luxury foods. (Local business)

Commercial respondents also queried the link between high-sugar products and obesity. Relevant arguments challenged the focus on sugar and questioned the likely efficacy of sugar taxes in managing obesity:

… the intake of sugar has been decreasing in several countries - including Bermuda - yet the prevalence of overweight and obesity have either stayed the same or increased. (International business association)

… soda and sugary drink purchase and consumption has been in decline for several years in Bermuda (Local business).

In highlighting alternative approaches to tackle obesity, commercial actors favoured interventions that ‘supported’ individuals to make informed choices and consume high-sugar products in moderation. This framing emphasises the role of personal responsibility in tackling obesity, thus diverting attention from high-sugar products and the businesses that produce and sell them. Proposed interventions included public education campaigns to inform dietary choices and promote physical activity, enabling people to exercise ‘choice’ and make ‘educated decisions’ about their diets:

Choice should be made through free will guided by educated decisions not regressive dictates. (Local business)

Nutrition education combined with guidance on consumption levels is important so that consumers can understand how they can manage their intakes whilst enjoying a varied and balanced diet. (Regional business association)

To effectively combat obesity, ICBA thus believes public health efforts must focus more broadly on public education regarding the total diet, the importance of physical activity, and the provision of clear and fact-based nutrition information to consumers. (International business association)

Responses from some local businesses appeared to question the government’s commitment to tackling obesity, suggesting they would invest more in education if this was a genuine policy goal:

Perhaps if government initiated an awareness campaign… then the Government’s stated end goal of reducing staggering health care costs becomes more genuine to me. (Local business)