What’s the “problem” represented to be in food investment policy?

In Thailand, public sector investment policies, which aims to promote and facilitate public and private investments, were perceived by government actors from food, agriculture and investment sectors as offering a solution for economic improvement, enabling progress in the transition to a high income country. Technological innovation in food production and processing was perceived as a key driver of economic growth; however, government investment in this sector was thought to be insufficient, and thus it was felt that the private sector must be part of the solution. This was reflected by some government actors in the food and investment sector discussing how they commissioned services in accordance with executive policies. In this context, both Thailand’s 20-year National Strategy and the Thailand 4.0 policy promote and support innovation and higher technologies. Core actions of these policies include supporting “S-curve industriesFootnote 1” which include food industry, “Food for the Future” initiative, and “Bio-Circular-Green Economic Model or BCGFootnote 2.” These policies aim for Thailand to become “a developed country with security, prosperity and sustainability.”

The projects under [name of government agency] aim to transform the country into “Thailand 4.0” which means the use of digital technology and innovation in industry as much as possible. The hope is that these innovations will add significant value to Thai products and production processes. The food industry is one of twelve targeted industries in this initiative [S-curve]. The slogan of the program is “Food for the Future.” There are three target areas in this program: Functional Food, Food Ingredients, and Final Food Product […] These three dimensions of Food for the Future are linked with the master plan for food processing industry that was recently issued by the Ministry of Industry (GO4).

Although government actors in investment generally welcomed investments that promote nutrition/health, they noted that this target was not their “bottom line”, unlike priorities such as “food innovation” or food production using “modern technology.” One government actor said:

In the case of the food industry, we look at the process of production of food and beverage products, additives/adornments, etc. One criterion is that the methods used in the production process are modern (GO2).

The emphasis on modern food production and processing was observed by some actors to be problematic for nutrition. As one technical expert mentioned, improving nutrition requires consumption of minimally processed foods and reduced consumption of highly processed foods such as UPF, due to their association with increased health risk. Balancing this with the economic interests of investment policy makers was perceived as challenging.

We can see more clearly how over-consumption of UPF could become a health problem. If you process some raw product too much, at some point it isn’t food (nutritious) anymore […] if the processing involves adding large amounts of sugar and sodium, then that could become a problem […] You would have to find a way to link the concept of UPF with health and trade and investment so that policy makers could more easily see the connections. (TE1).

This expert elaborated further that nutrition/health was only invoked by policy makers in investment as a rhetorical device to promote investment.

they [investment policy makers] seem to be narrowly considering what is feasible for the economy, or what has the potential for the most cost-benefit advantage for the country. They are not considering the health of the population in these policy decisions. […] Some might use that [nutrition] as an advertising pitch – that it will be good for your health – but that is not the focus of the discussion or decision-making (TE1).

What assumptions underlie the representation of the “problem”?

Investment policy discourse in Thailand has its roots in a political and economic context. A major idea evident across the interviews was the influence of a “productivist” policy paradigm which puts the government’s focus on industrially driven food and agriculture and expansion to increase productivity and economic growth. Actors from all sectors acknowledged that this paradigm dominates the food investment sector.

We are always on the look-out for new markets and countries to trade with. We want Thai farmers and producers to diversify more in order to have alternatives when the price of a certain product falls or there is a glut in the market (G06).

Another government actor in investment noted that an economic argument would be required for the consideration of UPF in food and investment policy, such as cost-effectiveness of using food processing-based classification system.

We would like to know in advance how much economic benefit would be derived by a certain technological input [from using food classification system based on processing such as UPF] (GO4).

One government actor in investment emphasised the status of “modern food production” and “foreign direct food investment” as priorities under the revised Investment Promotion Act No. 4 B.E. 2560 (2017) and an investment law named “Competitiveness Enhancement Act”, to create new BOI benefits, which include an increase in technology transfer to the host country.

This was Thailand’s way of shifting emphasis to upgrading the technological infrastructure and potential of the country across the board. The sectors of interest included biotechnology, nano-technology, advanced-material technology, and digital technology. Any investor which offered these technologies plus a partnership with the relevant Thai educational institutions (to receive technology transfer) then that investor would immediately receive 10-year tax exemption. If the enterprise had other special R&D features and areas of excellence, then the duration of exemption could be further increased (GO2).

Concerns were also raised by actors from civil society and technical experts, where it was felt that the dominant “productivist” paradigm could undermine the extent to which the government is held to account for nutrition and health outcomes. This was reflected in the prominence of business organisations by the actors.

The fact that the government hesitated on withdrawing [from joining the CPTPP due to concerns of Thai farmers and civil society that this agreement prevents them from saving and reusing seeds containing patented plant material] means that there is a counterbalance between the social sector against the Federation of Thai Industries and the Thai Chamber of Commerce. Therefore, it is possible to say as well that, supposedly if there is an issue concerning the [public health] measures affecting the investors on processed food, essentially these two organizations will be relevant (CS2).

Government actors from food and commerce sectors mentioned the international trade and investment regime as a constraining force that underpinned the problem representation in food investment policy. Government actors perceived that compliance with the Codex Alimentarius, and other obligations created by international trade and investment agreements, allow priority for ensuring food safety standards, but largely are in place to facilitate the flow of global trade to support the country’s food supply chain over investment in healthy diets.

we are bound by these trade agreements [on agricultural products]. So the government can’t deviate too much from those guidelines and standards. It’s not just the Ministry of Commerce acting alone here. […] We have to see if the terms of Codex are complied with […] There are the Technical Barriers to Trade of the WTO that Thailand has to comply with. The purpose is to prevent trade partners from applying undue pressure on each other (GO5).

One government actor in investment mentioned that they are looking at the use of digital technology and innovation in the industry in order to add significant value to Thai products and production processes. The food industry is one of their ten targeted industries. However, when it comes to health, they did not count health as an industry, and as such nutrition did not seem relevant to their work.

We don’t view health as an industry. Health is one component in the development of the “Smart City.” That concept involves social indicators of improvement. But that area is not my forte, so I am not sure where nutrition would fit in. The focus is more on lifestyles and access to safe food (GO4).

Despite these acknowledgements, some government and commercial actors believed that results from modern food production and processing are critical to food security and nutrition.

Processing food is an important strategy to achieve food security (GO4).

How has this representation of the “problem” come about?

The revised Investment Promotion Act No. 4 B.E. 2560 (2017) was identified as posing a barrier to the Board of Investment of Thailand (BOI) being able to prioritise nutrition within investment policy. This reflects the Act’s emphasis on increasing technology-based industries such as processed food and agro industries.

after the revised law was passed, there was a shift in emphasis from activity-based to technology-based enterprise. Thus, the 8-year limit for tax exemption was maintained for activity-based enterprise, while the 13-year extended limit was applied to technology-based enterprise (GO2).

The BOI is perceived by participants from all sectors to be the most influential actor. The processes used by industry to influence the BOI were identified as shaping the problem representations. One government actor in investment reflected on the “public and private platform” created for holding a regular dialogue between public and private sector investment actors to discuss or agree on measures related to investment policy issues. The BOI also holds power of unilateral action and with this power it lobbies for bringing in more resources such as expertise.

[BOI] also look at development of food production technology in agro-industry and hubs like the Food Innopolis [a global food innovation hub at the Thailand Science Park]. […] If there are measures which the BOI can do directly to improve the situation, then the BOI can act unilaterally […] For example, in the past, some have made the case that Thailand lacks experts in certain fields that are critical for the country’s development (e.g., aviation). In that situation, the BOI will consult with the relevant agency/organization and, if it is true, then we will lobby for modifications in the procedures/regulations to make it easier to bring in that expertise in a systematic way (GO2).

This was consistent with the interview given by one commercial actor emphasising “transparent” public and private sector dialogue to help facilitate investment for hi-tech industry.

Talking about investment, we would tell all our counterparts that investment was the purview of the BOI. The BOI did not force an entity to be part of the Federation of Thai Industries or Thai Chamber of Commerce, but they did have stipulations on the nature of the investment. Then, there came a time when the emphasis was on high-end technology, but hi-tech can be interpreted in multiple ways. […] This is the direct responsibility of the BOI. They want to do it neutrally, without political interference (FI1).

By contrast, engagement of health actors in investment policy discussions was described by one technical expert as being mainly “by invitation” only, with attention to health restricted to “healthcare and health services” policy such as Thailand’s medical hub policy and long-term care facilities and nursing homes.

The first time [I was involved] there was an issue related to FDI [Foreign Direct Investment] in the hospital sector. The issue concerned taxation rights of private hospitals. […] At that time, there was discussion about how this should not be a commercially-led initiative. […] My second involvement with the BOI was two or three years ago. That time the issue was investment in health services outside the hospital setting (TE1).

What is left unproblematic in this “problem” representation?

Despite some recognition of the case for aligning investment policies with public health benefits, these policies do not sufficiently take into account the nutrition implications of government investment to enhance future economic and social benefits. Food investment policy tends to be silent on nutrition issues, reinforcing the perception that interventions should focus on economic and technological aspects. Not only does the nutrition of Thai people remain unacknowledged in such policies, these do not take cognisance of the term “nutrition” and its importance to economic growth. Most government actors in investment are not familiar with food and nutrition policy objectives and as such do not prioritise it as a driver of economic wellbeing.

I don’t think they are considering the [food and nutrition] issue from a broad enough perspective. They [policy makers] are not considering the diversity of the context and the dynamic way the challenge is evolving. Instead, they seem to be narrowly considering what is feasible for the economy, or what has the potential for the most cost-benefit advantage for the country. They are not considering the health of the population in these policy decisions (TE1).

Perceptions on approaches to food classification constitute another gap in the representations. Although some government and industry actors and technical experts generally welcomed the idea of classifying foods as “healthy” and “unhealthy” based on level of processing to promote better nutrition, many pointed to unclear definitions within this food classification system, limited information on its health related impact, and challenges in promoting healthy eating through a return to traditional (or less processed) food diet. Thus this can affect prospects for regulating food investment for nutrition.

I don’t think that classifying products as UPF would change the policy climate. That’s because people don’t yet have an intuitive understanding of UPF. But in the academic field or health field, we can see more clearly how over-consumption of UPF could become a health problem (TE1).

there has to be strong scientific data to back up a position. However, if the evidence is ambiguous, then it is hard to find a middle ground. This is especially true for the health impacts of certain products [such as UPF]. Diets of different populations around the world have evolved over a period of thousands of generations, and the human body has adapted to the local diet out of natural selection. Thus, what is nutritious for one tribe may be toxic for another tribe. However, with globalization, diets are merging. People who used to subsist on a diet of, say, cactus root, now eat burgers and fries as a meal. Once a people transitions too far away from their traditional diets, it is hard to go back (FI1).

One commercial actor argued for allowing people to enjoy unhealthy foods on occasion and letting them eat in balance and moderation.

once in a while, it is OK to eat junk food or other food that doesn’t have much nutritional value. We can do that just as a diversion, for fun. But, the average meal needs to be a balanced diet (FI2).

Concern was also raised from one government actor in commerce where it was felt that UPF interests may clash with current investment policy directions.

Insects are made into sausages. They are ultra-processed foods? […] Thailand should sell anything that adds value to it. In order to add value, it requires technology, requires industrial production, and then, and of course ah, that food item has to be processed more or less as you said. It could have gone to Group 4, ultra, or just a little bit of processing, from shrimp to breaded shrimp, teriyaki shrimp, something like this, which is what if you think that it affects [our investment policy] or not, I think it affects (GO8).

Opposition to UPF was particularly prevalent among commercial actors. It was felt that use of this food classification system would “stigmatise” their products as harmful. These actors argued that their business is supporting Thais’ modern lifestyle and food security.

I am concerned about stigmatizing certain foods arbitrarily. The term ‘processed food’ is acquiring a bad reputation. Some Thais are even refusing to eat any processed food. UPF is seen as the worst in this category. […] So, this is a case of an UPF that is indispensable in a modern society where women are expected to work outside the home. If the term ‘UPF’ acquires a negative connotation in the mind of the consumer, that could do damage when certain UPF are essential. […] if we also characterize UPF as using innovative processes to improve food security through, for example, extending shelf life, or making a fixed amount of food more nutritious, or tailoring the food to the age group of the consumer, that would help improve the general public’s understanding of UPF (FI2).

Another limitation for the investment discourse is that the existing mechanisms for consultation do not drive diverse stakeholder engagement. Actors representing nutrition and health interests were generally excluded from broader discussions, and thus ideas about nutrition and health are in effect silenced within the investment policy arena. Despite acknowledgement of government to engage multisectoral actors in policy discussions, existing platforms appear to be appear ro be privileging engagement between government and the commercial sector. Civil society actors felt underrepresented in these processes. They were of the view that existing processes limited their opportunities to be involved or provide input into investment policy. Despite being invited to participate, the government response could be perceived as tokenistic, not taking their input seriously or that their involvement was a government afterthought. However, this could be improved with public pressure.

they [government] probably wouldn’t dare to invite us. If they do, how they listen to what we said is another story. Later they saw that if they didn’t listen to us, the point we were talking about, would be an issue that people echoed up, it’s really a problem (CS1).

The health sector did not appear to be recognised as a key part of the multisectoral coordination platform led by the investment sector:

The Board has representatives from the economic, finance, industrial, and commerce sectors of the government, as well as the President of the Federation of Thai Industries, and the Chairman of the Chamber of Commerce. Therefore, any policy that comes out is considered to be approved by both the public and private sectors (GO2).