# How are frames generated? Insights from the industry lobby against the sugar tax in Ireland

Norah Campbell, Mélissa Mialon, Kathryn Reilly, Sarah Browne, Francis M Finucane

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Norah Campbell, Mélissa Mialon, Kathryn Reilly, Sarah Browne, Francis M Finucane. How are frames generated? Insights from the industry lobby against the sugar tax in Ireland. Social Science & Medicine, 2020, 264, 10.1016/j.socscimed.2020.113215. hal-05038676

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# How are frames generated? Insights from the industry lobby against the sugar tax in Ireland

<figure><img src="image_3.png" /></figure>

Norah Campbell<sup>a,*</sup>, Melissa Mialon<sup>b</sup>, Kathryn Reilly<sup>c</sup>, Sarah Browne<sup>a</sup>, Francis M. Finucane<sup>d,e</sup>

## ARTICLE INFO

### Keywords:

Framing

Health related food tax

Sugar sweetened beverages

Corporate political activity

## ABSTRACT

There is a causal link between the consumption of ultra-processed foods and a range of non-communicable diseases (NCDs) such as obesity, type 2 diabetes and cancers. Despite this, no country in the world has reduced its obesity levels because the factors that drive obesity continue unchanged (Swinburn et al., 2019). One systemic driver is corporate influence on the public policy process. The world's largest food and beverage manufacturers engage public relations firms to create a narrative which speaks of corporate cooperation with public health policy, while simultaneously influencing policy making in ways that are favorable to industry.

We sought to examine framing as a key strategy in the corporate political activity of food industry actors attempting to resist the introduction of a public health policy. Specifically, we analyzed industry submissions for an Irish government consultation for the proposed introduction of a sugar sweetened beverage (SSB) tax in 2018. We describe how a food product like sugar is framed positively by corporate actors who rely on it as their principal ingredient. Sugar is a good focus from a framing perspective because it is currently undergoing re-calibration in the public's imagination - from a benign, nourishing treat in its heyday to a dangerous 'substance' that can contribute to premature mortality.

Framing is already well established as a corporate political activity (CPA) to influence public policy (Shelton et al., 2017; Nixon et al., 2015; Darmon et al., 2008). Our research expands this understanding by uncovering four underlying *mechanisms* used to generate frames – dichotomizing, contesting, equating and cropping. Recognizing these mechanisms could help policy makers, public health professionals and business ethicists to deconstruct any given frame that becomes dominant in corporate discourse, such as ‘personal responsibility’, ‘inadequate exercise’, ‘freedom’ and so on. These mechanisms may also apply to other industries such as alcohol, fossil fuels and tobacco, where hazards from interference in public health strategies are a concern.

## 1. Introduction: framing as a corporate political activity of the food industry

Evidence is now overwhelming that SSB consumption causes weight gain (Mozaffarian et al., 2011) and increases the risk of stroke, vascular disease, and diabetes (Gardener et al., 2018; Imamura et al., 2015; Malik et al., 2013; de Koning et al., 2012; Bernstein et al., 2012). With the rising global prevalence of obesity and its complications (Abramowitz et al., 2018; Kyrgiou et al., 2017; Ng et al., 2014; Laaksonen et al., 2010), population-wide public health strategies to improve food environments are being developed (Mozaffarian, 2016). These include the recent introduction of health-related food taxes on

sugar sweetened beverages (SSBs) (Saxena et al., 2019; Alvarado et al., 2019; Briggs et al., 2013) – an intervention prioritized by the World Health Organization for the prevention of NCDs.

Opposition to taxation by actors in the food industry, particularly large manufacturers, has been reported but empirical research into the nature of this resistance remains sparse. As with the tobacco (Ulucanlar et al., 2016) and alcohol (Martino et al., 2017) industries, the food industry seeks to mitigate public health strategies that might adversely affect their commercial sustainability and shareholder return through what is known as corporate political activities (CPAs) (Mialon and Mialon, 2018). CPAs encompass any intervention in “electoral, legislative or regulatory processes so that the outcomes of those processes

<footnote><sup>a</sup> Trinity Business School, Trinity College, Dublin, 2, Ireland</footnote>

<footnote><sup>b</sup> Faculty of Public Health, University of São Paulo, São Paulo, Brazil</footnote>

<footnote><sup>c</sup> Irish Heart Foundation, Dublin, 2, Ireland</footnote>

<footnote><sup>d</sup> Bariatric Medicine Service, Centre of Diabetes, Endocrinology and Metabolism, Galway University Hospitals and HRB Clinical Research Facility, Galway, Ireland</footnote>

<footnote><sup>e</sup> Department of Medicine, National University of Ireland Galway, Ireland</footnote>

<footnote>* Corresponding author. Trinity Business School, Trinity College, Dublin, Ireland. E-mail address: norah.campbell@tcd.ie (N. Campbell).</footnote>
better reflect the internal goals of the organization (primarily economic)” (Baysinger, 1984).

A review of CPA scholarly work within the management, political science, economics and sociology literature shows the focus has predominantly been on establishing the *antecedents* to CPA, *types* of CPA, *outcomes* of CPA and *implementation* of CPA, spanning instrumental and discursive strategies (Ulucanlar et al., 2016; Hillman et al., 2004). Instrumental strategies include coalition management, information management, direct involvement and influence in policy and legal issues. In coalition management, the industry actor builds alliances with health organizations, communities and the media, among others (Mialon and Mialon, 2018; Nestle, 2013; Freedhoff and Hebert, 2011; Simon, 2006; Jacobson, 2005). Information management involves industry distortion of scientific research either by funding studies, cherry picking, or disseminating information that would protect its interests or promote its products (Bes-Rastrollo et al., 2013; Lesser et al., 2007). Legal strategies consist of challenging, or threatening to challenge, industry opponents or specific public policies in court (Bodker et al., 2015).

As well as instrumental strategies, industry actors employ discursive strategies, where, for example, they emphasize their economic importance, where obesity is seen as a personal responsibility issue rather than a societal issue, and where industry is presented as part of the solution rather than part of the problem (Livonen, 2018). These discursive, proactive strategies are also known as framing, and work as a type of “political buffering” or “discursive politics” (Hillman et al., 2004; Fischer, 2003) that creates and shapes public and political understanding about the meaning of sugar, its regulation and its governance (Nestle, 2013; Livonen, 2018; Clapp and Scrinis, 2017; Freudenberg, 2014; Norum, 2005). Broadly, frames have cognitive, material-performative and ideological dimensions that enact realities which are in turn recognized by persons and collectives and, to varying extents, condition or determine their attitudes and actions (Snow et al., 1986; Goffman, 1974; Bateson, 1972). Frames do this by *guiding* the interpretive work necessary to understanding a reality (Snow et al., 1986). Frames do a number of important things: they garner support and acceptance (Cornelissen and Werner, 2014), they diagnose causes and prognose solutions (Nisbet et al., 2013; Le Ber and Branzei, 2010; Kaplan, 2008), which in turn creates path dependencies for what constitutes credible courses of action (Hawkins and Holden, 2014). Frames create hierarchies of values, such that unethical behaviour can be legitimized (MacLean, 2008). They can be inspirational, galvanizing collective action and securing allies, often through their argumentative strength rather than their recourse to external realities (Borah, 2011; Nisbet, 2009; Tarrow, 1989).

Extant work in obesity framing tends to analyze it from an 'issues' perspective. In other words, it has focused more on the evolution of frame issues than on framing actions which are used to shape the dialogue and policy around obesity, as 'sloth and gluttony' (Prentice and Jebb, 1995), 'education and exercise' (Koplan and Brownell, 2010), 'industry fight against obesity' (Nixon et al., 2015), 'business in the community' (Shelton et al., 2017) and 'nutrients' (Clapp and Scrinis, 2017; Scrinis and Monteiro, 2018). Recent research in social theory has sought to move away from categorizing frame 'issues', examining instead the organizational mechanics of framing that have the potential to give insight across issues (Le Ber and Branzei, 2010; Sharma and Jaiswal, 2018; Klitsie et al., 2018; Voltolini and Eising, 2017). For example, Kaplan (2008) describes framing as a process of contestation, whereby organizational actors engage in "highly political framing practices" – establishing legitimacy for one's own frame, undermining the legitimacy of other's frame and, realigning others to a dominant frame – to make their frames resonate and to mobilize action in their favor (2008, pp. 729). This is timely and relevant as public health research suggests that other industries as diverse as fossil fuel, tobacco, alcohol and pharmaceuticals adopt similar logics, arguments and symbols to gain frame dominance or maintain the status quo. Thus, we

sought to foreground the process of framing, rather than categorize different frames or frame contests used within the sugar tax debate.

## 1.1. *Sugar in Ireland*

Sugar consumption has long been a politically-charged issue in Ireland. As far back as the early 1990s there was mounting evidence that obesity rates were rising sharply in Ireland in both children and adults (O'Neill et al., 2007; McCarthy et al., 2002). The Irish Department of Health first began to discuss the feasibility of a tax on sugar-sweetened drinks (SSBs) in 2011. From the initial discussions, it was evident that Ireland's food and beverage industry was strongly opposed to a such a tax, making high-profile and public recommendations, including the need for more industry engagement in policy design (All Cost and No Benefit, 2017) and the negative impact a sugar tax would have on employment (Sharing the Harvest, 2012).

In 2016, the Irish Government undertook a public consultation on a proposal to introduce a tax on SSBs to help tackle growing levels of obesity. The objective of the public consultation was to determine how the tax would operate in practice, how to impose and collect the tax so that it achieved public health objectives in an efficient and fair way, and to seek input on how the tax was designed so that it is both EU compliant and not overly onerous on producers of SSBs (Sugar Sweetened Drinks Tax, 2016). Submissions from various stakeholders, including representatives of the food industry, were invited. In this study, we focused our analysis on the food industry actors' response to the proposal to introduce a SSB tax. Specifically, our aim was to explore the use of framing in the industry submissions in this consultation.

## 2. Methods

We adopted a social-constructivist model that recognises the performative role of language (Tuchman, 1978). In reporting our findings, we adhere to the guidelines outlined in the Standards in Reporting Qualitative Research (O'Brien et al., 2014).

### 2.1. *Data sources*

Our data comprised all the submissions from corporate actors in response to the Irish government's consultation process on the increase of taxes on SSBs in 2016. We submitted a freedom of information request to the Irish Department of Finance which returned details of all submissions received, from which we identified and included for analysis those from the food industry or its representatives.

### 2.2. *Data analysis*

We took a conventional thematic content analysis approach (Hsieh and Shannon, 2005) to analysing the data while the subsequent organization and charting of data according to coding variables was conducted according to the Framework method (Gale et al., 2013). This was a three-step process to determine frame data as first order, second order, and aggregate frames, which progressed from (i) thematic description to (ii) distillation of processes to (iii) general abstraction (Klitsie et al., 2018; Hervieux and Voltan, 2018). In the first order, we sought to categorize the data into 'issues' frames uncovering frame types, rather than focusing on the framing mechanism *per se*. One author inductively coded the consultations (Bowen, 2009; Miles and Huberman, 1994) and meetings with the co-authors discussed the conceptual coherence and clarity of the emergent frame issues, namely how well (i) the content corresponded to the theme and (ii) spanned across the consultations.

We then progressed to a second order analysis, moving across the issues' data to discern the dynamic process for how each frame was set in motion, to determine how "meaning is contained in and conveyed by the relationships *among the elements*" (Benford, 1997). Hence, we
sought to shift the unit of analysis from the issue to the framing actions, the specific 'doings' of framing. We sought to determine *how* the content within any given frame is generated to create compelling meanings and assert control of the obesity narrative. This inductive approach did not seek out an established concept from the framing literature (Kaplan, 2008; Hervieux and Voltan, 2018; Himick and Audousset-Coulier, 2016), but rather began with the data and drew up the mechanisms therein. The third wave of analysis sought to aggregate these 'actions' into a smaller number of underlying framing 'mechanisms' that clustered around certain characteristics, and which ultimately helped enact the corporate political strategy. Finally, in line with a tradition of early structuralist work on discourse and meaning-making (Greimas and Rastier, 1968; Levi-Strauss, 1955), we produced a visual model that depicts this dynamic framing process, with potential to be applied in other domains and contexts (see Fig. 1).

## 3. Results

14 industry actors made submissions for the sugar tax consultation in 2016, totalling 102 pages of documents, as outlined in Table 1. During the process of thematic content analysis of the SSB consultations, we first set out to locate and code all the frame issues that emerged. We located and discussed 13 distinct frame issues in total (see Table 2 for overview). As our aim was to move beyond the identification of frame issues and to understand the ‘doings’ of framing, our second phase of analysis therefore sought to locate the specific framing action which had enabled the food industry to shape and reinforce these issues. We identified 9 specific actions, which we named attributing, boomeranging, co-opting, exiting, demanding parity, conflating, jockeying, siloing and blame-shifting, as outlined below. We discussed these actions for conceptual coherence and clarity (Table 3). Finally, we recognized that the framing actions shared similar features, and so we clustered them into 4 over-arching mechanisms – Dichotomizing, Contesting, Equating and Cropping. (Fig. 1)

### 3.1. Dichotomizing

Dichotomizing is the division of the frame into binary blocs. It happens when the corporate actor ascribes its agencies and objects with positive characteristics, which by default casts the other actor (in this case government) into an assumptive opposition. This is similar to the bifurcation fallacy in rhetoric, where the rhetor attempts to collapse complex arguments into two opposing blocs and force a choice between the two (Gunderman and Sistrom, 2006). Dichotomizing is strategically important because it allows the corporate actor to avoid directly demonizing their antagonist. Rather, dichotomizing breaks the frame into

<figure><img src="image_4.png" /><figcaption>Fig. 1. The framing actions of the lobby against the Irish Sugar Tax, 2016</figcaption></figure>

one of two positions, and affords the actor ownership of the positively-valanced logics of position one, casting the antagonist in the shadow of position two. There are two actions to achieve this:

**1a: Attributing:** Attribution describes the processes where actors tie objects to effects in order to simplify their environments, and understand, predict and control the behaviour of other actors (Schwarz, 2006; Crittenden, 1983; Heider, 1958). Whether obesity is attributed to internal or external factors has a big impact on its framing. Attribution not only allows specific actors to align with desirable actions and objects; corporate actors use it to binarize the frame, and occupy the self-created positive space. Blaming a single actor has negative consequences in the politics of obesity, so implication is key. In the submissions to the sugar tax, 'choice' emerges as a moral, positively-valanced logic that allows industry actors to attribute its products with adult-characteristics. Thus, according to Coca-Cola, "Our approach is based on giving people choice and information about our products, enabling them to make the decisions that are right for themselves and their families." Corporate actors assume the role of the choice giver, while the dichotomized alternative is government, which is forced to occupy the opposing domain in the frame as the infantilizing remover of choice.

Similarly, taxation itself is endowed with exclusively negative characteristics. All industry actors in their submissions oppose the increase in the SSB taxes, attributing negative connotations to bolster their opposition, by calling taxation 'discriminatory' (Sunway), 'blunt' (Irish Beverage Council), 'ineffective' (Irish Vintners Association), 'punitive' (Lucozade Ribena Suntory Ireland), and 'unfair' (Food Drink Ireland). The framing action of attributing thus succeeds in dichotomizing taxation as a solution to obesity, and the inference is that there is no taxation route that could be fair, innovative or effective.

**1B: Boomeranging:** Boomeranging is the weaponizing of the logic of the opponent's side, undermining it by either adopting its premises in a literal manner or exposing where it fails to live up to its own arguments. An especially consistent action is setting the evidence base for a sugar tax by pointing to the lack of *causal* evidence for its efficacy. Causality is a deadly mechanism – the use of a statistical measure that is almost impossible to apply outside of closed, linear systems. 'Proving a causal relationship' between the environment and eating patterns is a challenge for government and public health. Ignoring the methodological realities of population health (see Rose, 1985), every industry actor in the data set uses 'lack of causality' as the reason that increases in SSB taxes are bad. Soft Drinks Europe's response is representative, stating "This proposal neglects that current research is inconclusive with regard to the alleged cause-effect relationship between the consumption of sugar-sweetened beverages and weight gain". The sine qua non of public health and medical authority, causality is boomeranged as the sole evidential criterion for action that is acceptable to the industry actor.

At the same time, the industry submissions refer to a small number of marketing and consultancy reports that are circulated as counter-evidence – a tendency that has been observed in other studies where in-house market research and industry-funded research are preferred to peer-reviewed published papers (Mialon and Mialon, 2018; Nestle, 2018; Kearns et al., 2015). A McKinsey Global report of 2014 is referenced by more than half of the actors – Irish Beverage Council, Coke, Lucozade, Food Drink Ireland, and Soft Drinks Europe. The report is noted as identifying taxation far down the hierarchy of effective policy interventions (16th out of 20 effective actions to tackle obesity). This allows industry actors to propose alternative (rather than additional) measures within the McKinsey Report such as (i) portion control, (ii) reformulation, (iii) education and (iv) food labelling. However, the actors disregard the more inconvenient measures that are higher than all of the above, including, at number three, to radically curb 'high calorie food availability'. While there is unanimous medical agreement that reducing the convenience, salience and availability of ultra-processed food would be a critically important strategy to improve public
health, the industry submissions do not authentically reflect the fullness of the base from which they derive evidence. The framing action of boomeranging by industry allows for the dichotomizing of research into two types – research that supports taxation as a solution to the obesity problem, and research which denounces it. Through boomeranging, industry uses public health's own research quality criteria for causality against it while deflecting attention from the major shortcomings of research which industry itself relies on for its counter-argument.

## 3.2. Contesting

Contesting is the shaking of the frame, rendering it permeable so that logics and arguments by different stakeholders can *exit* and new ones can *enter*. Essentially, contesting is a mechanism by which industry actors take in new logics, symbols and arguments, co-opt those already deployed by public health, or disassociate with previously positive ones. We identify two specific framing actions through which this is achieved: Co-opting and Exiting.

**2A: Co-opting:** Industry actors work to co-opt a single set of symbolically-important arguments that are in the field of public health, in order to derive opposing conclusions about them. “Co-opting” is a widely-used term in critical theory to describe any process where a system or social movement assimilates its opposite (Coy and Hedeen, 2005). Most of the submissions begin with the industry actor expounding how serious the problem is. Obesity is principally defined by the industry actors as (i) ‘complex’, (ii) ‘multi-factorial’ and (iii) requiring a ‘whole-of-society’ approach. With this mimicry of the language of public health, industry actors conclude that single measures such as taxation are inherently reductionist and undermine the nature of the problem. Britvic states “We don’t believe that a single measure, taxing some soft drinks products with added sugar, which account for circa 3% of total population calorific intake, will be effective”. While government and public health professionals use the exact same terminology to describe obesity, it is a means of emphasizing the need for a ‘suite’, ‘menu’, or ‘portfolio’ of measures (Mozaffarian, 2016).

Co-optation is facilitated through the use of emotionally powerful, vague phrases which attempt to position industry actors themselves as concerned role models within the community, with adjectives like ‘(fully) committed’. This *unquantified quality*, is pervasive in industry submissions to SSB consultations, where no measurement exists, yet still carries a performative value. While ‘committed’ and ‘responsible’ are frequently used self-descriptors for industry actors, the most common unquantified qualities concerning consumption are ‘moderation’ and ‘balanced’, which are galvanizing, optimistic and attitudinal rather than action-based and measurable targets. ‘Moderation’ and ‘balance’ are incrementalist and individualizing terms, which enable industry to co-opt public health’s logic that change *is* needed, yet allowing this commitment to change to be non-specific and unmeasurable in nature. Co-optation facilitates an *enforced sharing* of logics and arguments from public health, it rationalizes the need to listen to the industry actor because of shared concerns, and it tilts the frame to commercial actors’ strategies.

**2B: Exiting:** Exiting is the disassociation of the corporate actor with a previously positive frame. As the general public and government policy makers become more literate in the frames of obesity, industry actors must exit certain logics that become widely suspect. Corporate actors are moving away from the logics of personal responsibility as a means of addressing the obesity epidemic. In 2011, in a previous submission to the Irish Government during an obesity policy consultation process, Retail Ireland, a lobby group for retailers, states: “Retailers are not the main driver of consumer demand - rather, retailers respond to that demand ... Everyone understands that fruit and vegetables are a healthier choice than confectionery, yet many people continue to choose chocolate as a snack rather than an apple. Retailers are realistic and understand that consumers are not always going to go for the healthiest option.” This frame is not evident in the 2016 submissions,

likely because of increasing public scepticism about free choice. Exiting accounts for the dynamic nature of frames, and allows for contesting (and disassociating from) a previously positive logic or argument, as publics become frame-literate.

## 3.3. Equating

Equating is the *equalizing* of logics in the face of two or more incommensurable frames. If contesting work is the (forcible) sharing of a frame, equation work is most effective when a parity between incommensurable frames is sought. “Stakeholder theory”, used in business to turn attention to the responsibilities of business in society, is eerily similar to “strategic stakeholder communication”, a political activity where the firm maipulates issues in the nonmarket domain (Darmon et al., 2008; Bach and Blake, 2016; Freeman, 2010). Because profit maximisation is the ultimate and exclusive of a private organization, business organizations are missing a ‘unity of object’ with public health, a fundamental prerequisite for co-operation (Donovan et al., 2015). The goal of equating is to level all audiences, as exemplified in Danone's opening statement: “Through its mission and dual commitment to business success and social progress, the company aims to build a healthier future, thanks to better health, better lives and a better world, for all its stakeholders—its 100,000 employees, consumers, customers, suppliers, shareholders and all the communities with which it engages”. We noted two distinct domains of equating in these submissions.

**3A: Demanding parity:** There is consistent assertion that corporate actors should be on the same footing as any other stakeholders by emphasizing the progress they have made such as highlighting in-house voluntary codes of responsible marketing and positioning themselves as “industry leaders”. “We have led the way” is a consistent sentence opener, in everything from product innovation to advertising control. The Licensed Vintners' Association, for example, “understands and have [sic] acted on concerns about exerting influence over children. This is why we created our unique code of responsible marketing. This shapes our company behaviours and goes beyond the industry norm.” Such voluntariness immediately precedes a demand to a seat at the policy table. Coca-Cola “firmly believe that Government should work in partnership with the food and drink industry, as well as other sectors to support the introduction of a multi-stranded suite of meaningful solutions, focussed around portion control, reformulation, education and food labelling. We would have welcomed further consultation with industry. We are eager to engage further with the Department and Revenue Commissioners.” Industry actors use adjectives such as ‘confused’ and ‘disappointed’ to characterise how they feel about the impending tax. This is despite the lengthy build-up between 2011 policy recommendations for a sugar tax and its ultimate implementation in 2018. As PepsiCo states, “We urge the Government to reconsider the proposal for an SSB tax and instead build on the voluntary approach which the industry has demonstrated to date”, while IBEC argue that “a pre-consultation to define ‘added sugar’ and other terms used in the consultation document, as happened in the UK, would have been helpful and allowed submissions to be fuller”. Expressing discontent with the perceived lack of parity shown to industry in the SSB consultation process enables industry to suggest that a unified solution *could* have been established, had the opportunity been afforded them, despite the evidence of the two incommensurable frames of both stakeholder groups.

**3B Conflating:** The other type of equating work is conflating – the *blending* together of elements from one frame with elements of another. A blended frame can be relatively unstable, but it can function to create confusion about corporate action. In the submissions, there is a consistent conflation of the local and the global, usually by blending the corporate structure and the brand as frame sponsor. As most suppliers of SSBs in Ireland are major international food conglomerates with shareholders based in other territories and profits repatriated to
headquartered countries, it is important for the industry actor to em-
phasize localised engagement with Ireland to ward off estrangement in
the eyes of the public. This is evidenced in the ways in which the actor
aligns itself with Ireland by (i) appealing to historical roots, as in the
case of Britvic: “The business that we call Britvic Ireland today dates
back to 1773 and the invention of Soda Water by Augustine Thwaites
Junior in the medical laboratory in Trinity College Dublin”, (ii) pro-
duction investment, such as with Coca-Cola stating that “97% of ev-
erything that we sell across the island of Ireland is manufactured here”,
or (iii) emphasizing the familiarity of an individual brand that may be
mistaken as homey and familiar. The Japanese conglomerate Suntory
states that “our much-loved brands - Lucozade, Ribena and Orangina
account for 11.6% of the Irish market,” but has global holdings of
mostly alcohol brands such as Connemara, Laphraoig and Ardmore.
Thus, the conflation of corporate and brand structure makes it difficult
to discern the global infrastructure and agency of these industry actors.

3.4. *Cropping*

Cropping is the cutting of the frame so that it focuses on a smaller part of the overall picture. Deployed in a literal sense in visual studies, the work of cropping has been demonstrated to draw attention to what is inside the frame, rather than outside it (Berger, 1981). Cropping ensures that the viewer of the frame does not experience what they are perceiving as part of a bigger picture. Cropping affects “how we see, how we are able, allowed, or made to see” (Fischer, 2003). In these submissions, three distinct forms of cropping were apparent.

**4A: Jockeying for special position:** Jockeying for special position is apparent in the submissions, where the actor makes a case for either its own brand or industry as a exceptional case. Lucozade argues that “Uniquely the food and drink industry is dispersed throughout all regions of Ireland and is at the heart of the social fabric of rural Ireland”, while PepsiCo state that it “recommend[s] the exemption of sports drinks as they are designed for elite performance and not for general refreshment and are formulated specifically to meet the performance requirements of sports persons ...” The Licensed Vintners' Association asserts “that SSBs sold via the licensed trade make a negligible contribution to obesity among children and young people generally and accordingly, such a levy on product sold by the licensed trade will prove completely ineffective in terms of achieving the policy objective set.” This jockeying in the submissions process could be regarded as scattered and non-strategic, with lots of ‘unique cases’ put forward, perhaps in order to observe which ones can gain traction for subsequent larger strategic communication investment. The very act of jockeying for a special position, results in cropping the frame, because it presents cases distinct from others and which demand separate considerations.

**4B: Blame-shifting:** Blame-shifting is the singling out of another actor or object to carry the burden of negativity within a frame, so that attention is focused on the most blame-worthy and the industry actor may reap the “lesser of two evils” effect. In the SSB submissions, three exemplars of blame shifting emerge. Firstly, the dairy industry is admonished by Coca-Cola which states that “There are several examples of drinks sold on the Irish market that are high in milk content and high in added sugar. These drinks can contain more sugar and more calories per serving than a serving of Coca-Cola Classic and are direct competitor products of the set of drinks that will be subject to the levy.” In this way, highly sugared milk-drinks are framed as worse than SSBs. The second blame is Brexit, used by every industry actor to variously (i) to increase levels of confusion as to the future regulatory environment, (ii) to prognose instability, and (iii) to inaugurate delay as the best possible interim option. According to IBEC, the government should ‘support’ rather than ‘tax’ ‘Irish industry’ because of the economic upheaval posed by Brexit. Britvic Ireland states that “[The proposed tax] is particularly concerning given the uncertainty caused by the Brexit vote in the UK, and the volatility in euro/Sterling rate ... Without the detail of the UK’s future trading relationship with Ireland and the EU generally

in the context of Brexit, it is virtually impossible to envisage all the
issues that will exist”. Brexit is depicted to cause exchange rate vola-
tility, food labelling changes and illegally altered product composition.
The third blame locus is the ‘black market’ – a cipher also observed in
the tobacco industry (Michaels, 2008). Almost all industry actors refer
to the threat of a black market for illegal soft drinks. Coca-Cola ex-
presses concern about “the potential for black-market or counterfeit
products entering the marketplace which may be mistaken for legit-
imate soft drink products and not in compliance with food and drink
safety standards”. Despite the fact that the Irish Department of Finance’s
invitation for consultation explicitly and repeatedly states that the
sugar tax would be harmonised with the UK’s sugar tax, all industry
actions re-vivify fears of a non-taxed SSB environment in the North of
Ireland, painting a scenario of smuggling and cross-border shopping
which pose dangers according to the Irish Beverage Council, of “black-
market counterfeit/recipe fraud products entering the legitimate
market [which] could pose a significant health threat to Type 1 dia-
betics who use SSB products for their health needs”. Blame-shifting is a
key framing action of industry which has the effect of creating a
‘hierarchy of goodness’, thus cropping the frame to only focus on those
“most guilty” within the hierarchy.

**4C: Siloing:** Siloing is the funnelling of logics and arguments that are positive but contradictory for the corporate actor into distinct conceptual realms. This allows actors to occupy opposing logics within a frame without the feeling of contradiction. Two distinctive examples from the sugar tax submissions are observed. The first can be termed the contradiction of might and modesty. The consultations show that corporate actors must walk a tightrope in this rhetoric: they must boast their economic might while at the same time point to how low the impact of SSBs are likely to be on the populations' diets. For example, Coca-Cola is a "major employer and contributor to the national and local economies", while then emphasizing how the SSB sector comprises only 3% of the Irish diet. A second siloing is seen in the logic of reformulation, which allows the actor to occupy the important position of problem maker *and* problem solver. Reformulation is a heavily emphasised silver bullet in the submissions – a frame that has been successfully keyed to Irish public health, media and government. In these data, it allows the brand to quantify some impressive initiatives. PepsiCo for example reduced sugar in regular Pepsi by 4% between 2008 and 2011 followed by a 30% reduction of sugar in its Lipton brand of ice tea in 2015. However, siloing de-lists the question of how the sugar got there in the first place, and it limits the alternative to full-sugar products to reformulated ones, instead of free or non-packaged options like water.

**4. Discussion**

These findings contribute to research in corporate political activity
by offering a conceptual framework to analyze framing *mechanisms*. We
have found that corporate actors engage in the policy process through
the mechanisms of dichotomizing, contesting, equating and cropping
the frame. In *dichotomizing* the corporate actor's goal is to break the
frame into binary blocs, enabling it to take up positive characteristics
while inferring negative ones to public health or government without
direct articulation. This is achieved through *attributing* (aligning the
brand or firm with positive logics) and *boomeranging* (weaponizing the
logics of public health). *Contesting* is the shaking of the frame, rendering
it permeable so that logics, and arguments, can exit and new ones can
enter. *Co-opting* and *exiting* are two contesting dynamics in the sub-
missions. The former uses ‘unquantified quality’ – emotionally pow-
erful, vague rhetoric to mimic public health discourse and to showcase
commitment to the problem. *Exiting* is the disassociation of the corpo-
rate actor from a previous frame. *Equating* is the equalizing of logics in
the face of two or more incommensurable frames. This is achieved
through *demanding parity* as an equal partner in the multi-faceted set of
roles actors have in society, and *conflating* the frame's logics, with
elements of another to achieve modular blends that are strategically useful. Finally, *cropping* is the cutting of the frame so that it focuses on a smaller part of the overall picture. Within this, corporate actors *jockey for special position* by framing their brand, firm, category or context as deserving of special dispensation, *shift blame* by singling out another actor or object to carry the burden of negativity within the frame, and *silo*, by funnelling logics that are positive but contradictory for the corporate actor into singular conceptual realms.

It is essential to appreciate the inherently political nature of public health if one is to engage well in debates on public health ethics (Coggon, 2018). A Lancet Commission recently proposed that “the single largest contribution that corporations could make to addressing ‘The Global Syndemic’ is to stop investing enormous efforts and resources into opposing the enactment of regulations and fiscal policies for the public good” (Swinburn et al., 2019). Developing frame-literacy empowers politicians and policy makers to better counter-act industry actions, claims and motivations. Such mechanisms can provide public health advocates with frame-innovations that counter industry dominance, for example counter-framing guideline daily amount labels as explicit warnings on the front of food and beverage packs (Arrua et al., 2017). As we have presented earlier, studies have identified obesity frames that corporate actors use – from parental responsibility to exercise, to moderation and portion control, to reformulation. However, *how* these frames are created requires consideration of the mechanisms of discursive politics, a move from frames to framing. This is especially important because a frame is only effective if it cannot be seen and if its construction is invisibilized. Conversely, visibilizing framing work offers policy makers, public health professionals and researchers insight into the *modus operandi* of discursive politics before it solidifies as an issue frame. To the extent that the tobacco industry developed a ‘playbook’ in the 1950s – a masterplan and script to decouple cigarette smoking from cancer (Proctor, 2011) – our findings may similarly be applicable to any industry that is seeking to decouple its core offering from its public health negative externalities.

This research has limitations. Firstly, we have examined a single consultation process, with just 14 corporate actors trying to influence one domain of fiscal policy in Ireland and as such the analysis lacks systematic empirical studies across cases, corporations and time. This is a single case and it does not determine the effects of industry framing over time. Rather, our objective was to present a model of framing mechanisms from a process-perspective that has sufficient abstraction to be applied across other industries and time periods. In general, data on CPAs are limited. Unlike the recent work by the Institute for Policy Studies at UC San Francisco, where a great many internal documents relating to the food industry have been digitized and made publicly available no European institution is currently archiving and making available such documents.

Secondly, while we suggest that the model might elucidate some of the general principles of framing across industries, we cannot infer that these actions are monolithic and further studies are required to determine whether the framing strategies outlined above are generalizable or relevant in other domains of industry lobbying to governments. Thirdly, we adopted a hypothesis-free “ground up” approach in our analyses rather than adhering to established taxonomic methods in the field of frame theory. This may then miss other framing actions, such as prognostic and diagnostic framing, bridging and amplification. Finally, in our third wave of analysis, where we aggregate the processes according to shared mechanisms and characteristics, there is a danger that we literalize the frame metaphor, reifying the phenomena that we

observe in the data and visualized in Fig. 1. It has been noted elsewhere that imagining an actual frame can unintentionally create its own straitjacket that subsumes the agency of individuals to the overwhelming forces of abstract frames. However, frames allow us to glean general structures that strongly influence meaning-making, while at the same time giving analytical room to individuals, single events and cultures to disrupt determining forces – the first step of which is a better understanding of those structures.

## 4.1. Implications for policy

The major interpretation and deployment of frames in social theory emerged from the research on social movements by Benford and Snow in the 1980s and 1990s (Snow et al., 1986; Benford, 1997). This collectivist, pro-social activist context tended to view the world from the position of a David seeking justice against a Goliath. Hence, early framing work overwhelmingly adopted injustice-grievance framing as the prompt to framing actions, and the modality was one to enfranchise (through means such as alignment and bridging) disenfranchised issues or communities. While this strong contextual influence has enabled analytical insight, it may constrain that insight when the context is not a social justice movement, but rather a dominant economic force seeking domain maintenance or dominance.

The extension of the social movement context to public health can thus sometimes be inadvertently normative, with notions like rigid versus flexible frames, partners versus adversaries, successful versus unsuccessful alignments and collaboration instead of division. Our findings suggest that the *metaphor* of the frame can inadvertently enshrine a progressivist teleology of fusion, partnership, the over-coming of differences and the sharing of frames. The striving towards frame sharing between commercial and public health actors is the dominant vision in national and supranational public health governance. In contrast, key recent debates in obesity policy have circled on ‘partnership’ itself, and the extent to which corporate actors seek to enforce co-framing (Scott et al., 2017; Marks, 2019). In a lesstheorized way, framing has itself been regarded as the “psychological editing of information” (Singer et al., 1991), a tool in the repertoire of corporate communications actively encouraging customers to hold false beliefs or make inappropriate inferences when making purchasing decisions. Framing thus occupies a strange axiology: being a simple description of cognitive habits on one level, a model with predictive power on the other, and an ideology that pre-favours partnership as a solution to multi-stakeholder challenges on another. Framing should thus be understood as a multi-valent concept.

## Author Statement

**Norah Campbell:** Conceptualization, Methodology, Analysis, Writing, Reviewing and Editing. **Kathryn Walsh:** Data curation, Writing, Reviewing and Editing. **Melissa Mialon:** Writing, Reviewing and Editing. **Sarah Browne:** Methodology, Analysis, Writing, Reviewing and Editing. **Francis Finucane:** Conceptualization, Methodology, Analysis, Writing, Reviewing and Editing.

## Acknowledgements

Norah Campbell received funding from the Trinity Benefactions Fund in Arts, Humanities and Social Sciences to complete this research.

# Appendix A

Table 1
Summary of empirical data.

<table><caption>Table 2
Frame typology, with illustrative examples.</caption><thead><tr><th>Corporate actor</th><th>Background</th><th>Public Relations Agency</th><th>Size of document</th><th>Shorthand</th></tr></thead><tbody><tr><td>Britvic Ireland</td><td>In 2007 Britvic UK acquired the soft drinks arm of C&C to create Britvic Ireland. It owns soft drinks companies in France and Brazil. Brands include Robinson's, Tango, J20, Drench, MiWadi, Ballygowan, Teisseire, Fruité, Maguary and DaFruta.</td><td>Murray, Dublin</td><td>15 pages</td><td>Britvic</td></tr><tr><td>Coca-Cola Ireland</td><td>Coca-Cola Ireland is a subsidiary of the Coco-Cola Company and is responsible for marketing 20 brands across the island of Ireland. First franchise established in 1939. Coca Cola is rated as Ireland's most popular brand. Coca-Cola has 500 brands and more than 4100 products globally. In Ireland, it distributes Fanta, Sprite, Powerade and Schweppes. Turnover end of 2016 was €162.3 million</td><td>In-house public affairs, Dublin</td><td>12 pages</td><td>Coke</td></tr><tr><td>Danone</td><td>Danone Ireland supplies 80% of the company's base powder for Europe's infant formula market. It has over 190 production plants and around 104,000 employees globally. In 2013, the company generated sales of over €21 billion, with more than 60% in emerging countries.</td><td>Fuzion PR, Dublin</td><td>7 pages</td><td>Danone</td></tr><tr><td>Food Drink Ireland (FDI)</td><td>Food Drink Ireland is the main trade association for the food and drink industry in Ireland. It represents the interests of over 150 food, drink and non-food grocery manufacturers and suppliers. It is a member of IBEC.</td><td>Paul Kelly</td><td>12 pages</td><td>Food Drink Ireland</td></tr><tr><td>Irish Business and Employer's Confederation (IB-EC)</td><td>IBEC is Ireland's largest lobby group representing Irish business both domestically and internationally. Spent €1.3million lobbying EU in 2017 (Third largest lobby group in Europe).</td><td>CEO Danny McCoy</td><td>2 pages</td><td>IBEC</td></tr><tr><td>Irish Beverage Council</td><td>Represents companies that produce, distribute and market soft drinks, fruit juices, bottled waters, and sports and energy drinks throughout the island of Ireland. Member of IBEC.</td><td>Colm Jordan</td><td>56 pages</td><td>Irish Beverage</td></tr><tr><td>Licensed Vintners Association (LVA)</td><td>The trade association and representative body for the publicans (pub owners) of Dublin</td><td>N/A</td><td>3 pages</td><td>Vintners</td></tr><tr><td>Lucozade-Ribena-Suntory Ireland (LRSI)</td><td>Lucozade-Ribena-Suntory Ireland (LRSI) Limited was set up in 2013. Circa €110 million in sales of the three brands in Ireland.</td><td>Catherine Brent(Corporate Affairs Office of LRSI)</td><td>32 pages</td><td>Lucozade</td></tr><tr><td>PepsiCo</td><td>Based in Country Cork, Ireland since 1974, with R&D and manufacturing specialities. Brands include Pepsi, Walkers, Doritos and Lays crisps.</td><td>Murray, Dublin</td><td>7 pages</td><td>Pepsi</td></tr><tr><td>Retail Ireland</td><td>Retail Ireland represents the retail industry in Ireland. €30 billion in sales annually in Ireland. Member of IBEC.</td><td>Crotty Communications, Dublin</td><td>3 pages</td><td>Retail Ireland</td></tr><tr><td>Subway</td><td>American fast-food franchise with 321 stores in Ireland</td><td>McKenna Townsend, Hampshire, UK</td><td>3 pages</td><td>Subway</td></tr><tr><td>Union of European Beverages Association (UNESDA)</td><td>Based in Brussels, UNESDA represents the European soft drinks industry with €185 billion market size.</td><td>In-house lobbyists</td><td>2 pages</td><td>Soft Drinks Europe</td></tr></tbody></table>

<table><thead><tr><th>Issue</th><th>Choice</th><th>A portfolio of measures</th><th>Voluntary actions - industry leadership</th><th>Partnership</th><th>Special case for product/industry</th><th>Employment</th><th>Brexit</th></tr></thead><tbody><tr><td>Framing of issue</td><td>(i) present choice as democratic, (ii) present brand as a simple choice-giver, (ii) construct a rational consumer</td><td>(i) emphasise multi-causal nature of obesity, (ii) conclude that industry change cannot be a single solution (iii) move to lots of measures</td><td>(i) present brand as deeply concerned and open to change, (ii) showcase internal codes of responsibility, (iii) emphasise charity and community work, (iv) provide evidence that self-regulation works</td><td>(i) we are all stakeholders, (ii) convey unilateralism on part of government, (iii) ask for more engagement</td><td>Make a case for that the firm/brand is a special case by (i) asking for exemptions, (ii) defending brand's portfolio, (iii) directing the tax</td><td>(i) quantify the numbers of employees to emphasise the share of voice, (ii) threaten loss of employment, (iii) frame industry/brand as a support/contributor</td><td>(i) present Brexit as a reason for an imminent period of uncertainty, (ii) Brexit will bring huge legislative changes, (iii) Brexit requires that government give business extra support</td></tr></tbody></table>

(continued on next page)
<table><caption>Table 2 (continued)</caption><thead><tr><th>Issue</th><th>Choice</th><th>A portfolio of measures</th><th>Voluntary actions - industry leadership</th><th>Partnership</th><th>Special case for product/industry</th><th>Employment</th><th>Brexit</th></tr></thead><tbody><tr><td>Examples from data</td><td>(i) The greatest amount of information and product range to make informed choices ... Our approach is based on giving people choice and information about our products, enabling them to make the decisions that are right for themselves and their families (Coke)</td><td>(i) Obesity has many causes and requires a whole-of-society approach (Britvic)</td><td>(i) We welcome the growing focus on this area, and at Coca-Cola we are committed to playing our part - whether that's using our sponsorship of sport on the world stage to inspire people to be more active, or through our direct support of grass roots programmes in local communities ... The Coca-Cola Thank You Fund has donated €750,000 since 2011 to support community based projects on the island of Ireland that get more people more active, more often (Coke)</td><td>(i) FDI We firmly believe that Government should work in partnership with the food and drink industry, as well as other sectors to support the introduction of a multi-stranded suite of meaningful solutions, focussed around portion control, reformulation, education and food labelling. Working together with industry to make these programmes happen will ultimately support far greater positive and sustainable health outcomes for Irish consumers (Food Drink Ireland)</td><td>(i) We recommend the exemption of sports drinks as they are designed for elite performance and not for general refreshment and are formulated specifically to meet the performance requirements of sports persons which in some cases includes particular levels of sugar above 5g per 100 ml.limited adult target market (Pepsi)</td><td>(i) In the UK and Ireland Danone employees more than 1700 people, and serves an estimated 17 million consumers (Danone)</td><td>(i) The Department of Finance's own "Getting Ireland Ready for Brexit" shows that post-Brexit trade arrangements are not known. Implementing any sort of punitive taxation regime on business at this time is unhelpful when so much uncertainty exists. (Beverage Council)</td></tr><tr><td></td><td>(ii) the administration activities and compliance associated with this tax should not threaten or disrupt the supply of sugar-sweetened drinks for consumers and traders (Retail Ireland)</td><td>(ii) Discriminatory taxes, however, are not the right solution to a complex, multifactorial societal issue such as obesity and other non-communicable diseases, which can only be effectively addressed by a "whole-of-society", holistic approach (Food Drink Ireland)</td><td>(ii) The brand has led the QSR sector in its commitment to the Government's call for voluntary calorie postings and through its voluntary reformulation of SUBWAY* product (Subway)</td><td>(ii) This is why we are disappointed that the Government chose to announce a soft drinks tax given the many proactive steps taken by LSRI and others ... Change will only come when we all work together: government, industry and retailers. We need a holistic approach to affect consumer behavioural change, not regressive tax measures (Lucozade)</td><td>(ii) We agree with the proposal that fruit and dairy drinks should be excluded from the proposed sugar levy on the basis of their contribution to the national diet (Danone)</td><td>(ii) In addition to being an extra and unwarranted additional cost to Irish consumers, a SSD tax will threaten Irish businesses and the jobs they support (Food Drink Ireland)</td><td>(ii) With the potential of Brexit to also trigger the UK's departure from the jurisdiction of the ECJ, there is a significant chance for differing food standards, labelling requirements and other testing. This has the potential to create further cost and administrative burdens on our business (Coke)</td></tr><tr><td></td><td>(iii) There is a strong degree of academic consensus that by the age of 12, children are fully capable of understanding the persuasive intent of advertising and have the necessary cognitive tools to critically assess it (Lucozade)</td><td>(iii) The causes of obesity are complex and there is no silver bullet to solve the problem (Lucozade)</td><td>(iii) LSRI understands and have acted on concerns about exerting influence over children. This is why we created our unique code of responsible marketing. This shapes our company behaviours and goes beyond the industry norm (Lucozade)</td><td>(iii) We welcome the public consultation process and call on the government to engage further with industry (Food Drink Ireland)</td><td>(iii) The SUBWAY* brand wishes to underline that producers of sugar sweetened drinks should be liable to pay this proposed tax and it should not be passed onto the retailer. It is important that Government should consider a mechanism to ensure that the tax remains with producers, as is its intent. (Subway)</td><td>(iii) We note a recent Oxford Economics Study in the UK which estimated that such a tax would reduce the soft drinks sector's contribution to GDP by £132 million and cost 4030 jobs (Vintners)</td><td>(iii) The challenge of Brexit, including the immediate exchange rate exposure to sterling and the longer term trading relationship challenges with the UK, faced by the food and drink sector point to the need to support, rather than tax, Irish industry (IBEC)</td></tr><tr><td>Issue</td><td>Sunset clause</td><td>Nationalism/localism</td><td>Activity and exercise</td><td>Tax is backward</td><td>The black market</td><td>Lack of evidence</td><td>Lack of government planning</td></tr><tr><td>Framing of issue</td><td>Canvas for an end to the tax by (i) implying that the government is cynically profiting from obesity, (ii) demanding a sunset clause</td><td>Emphasise the localism of the brand/industry by (i) demonstrating it is made in Ireland, (ii) endowing it with Irish history/roots</td><td>(i) Foreground activity and exercise as the most important actions in the fight against obesity</td><td>(i) create a link between other precedent taxations and lack of causal (ii) imply that taxation will disincivivise industry from further collaboration, (iii) taxation discriminates either the poor consumer, the non-consumer, or the industry, (iv) taxation is illegal, (v) taxation is primitive/blunt</td><td>Describe the threat of black markets appearing through (i) cross border smuggling, (ii) bootleg manufacturing, (iii) unintended consequences of taxation, e.g. substitutability</td><td>Emphasise research that shows inconclusively or non-causality, (ii) showcase failures, (iii) minimise the target population, (iv) reference studies that disfavour or demote taxation, (v) preface such studies with scientific credence, (v) cite work that has been sponsored by the company</td><td>Resurrect failures of government to adequately plan for every eventuality, (ii) misconstrue government intention to align with UK taxation system</td></tr></tbody></table>

(continued on next page)
<table><caption>Table 2 (continued)</caption><thead><tr><th>Issue</th><th>Sunset clause</th><th>Nationalism/localism</th><th>Activity and exercise</th><th>Tax is backward</th><th>The black market</th><th>Lack of evidence</th><th>Lack of government planning</th></tr></thead><tbody><tr><td>Examples from data</td><td>(i) In short, the levy would be nothing other than an unfair measure to raise additional funds for the state's coffers, creating huge administrative burden and red tape, hitting low-income consumers, hurting local businesses, while not providing any tangible solution to the problem of obesity. (Subway)<br/><br/>(ii) We also agree with the Irish Beverage Council's view that in the spirit of good governance, any legislative proposal must include a review and sunset clause where aims are not met.</td><td>(i) 97% of everything that we sell across the island of Ireland is manufactured here (Coke)<br/><br/>(ii) We are the second largest branded soft drinks supplier in Ireland, our much loved brands - Lucozade, Ribena and Organina - account for 11.6% of the Irish market (Lucozade)</td><td>(i) Through a wide variety of CSR programmes and sponsorship activities, our member companies are promoting a greater emphasis on physical activity and healthy choices amongst customers and employees (PepsiCo)<br/><br/>(ii) We are the second largest branded soft drinks supplier in Ireland, our much loved brands - Lucozade, Ribena and Organina - account for 11.6% of the Irish market (Lucozade)</td><td>(i) scientific evidence proving that taxation represents an effective means of changing consumer behaviour and of successfully tackling obesity and other lifestyle related non-communicable diseases is inconclusive ... The experience of countries with discriminatory food taxation, such as Denmark, provides real-world evidence that such taxes are regressive and ineffective in changing diet and lifestyle-related issues (Food Drink Ireland)<br/><br/>(ii) Potential taxation on these products would discourage reformation and innovation ... The risk is that incremental reformation is not incentivised thus reducing the potential impact this most effective measure can have on public health (Coke)<br/><br/>(ii) SSDs are recommended to balance blood sugar content in diabetics. The potential for black-market counterfeit/recipe fraud products entering the legitimate market could pose a significant health threat to Type 1 diabetics who use SSD products for their health needs; there is no guarantee that counterfeit products will be produced to the same recipe standards (IBEC)<br/><br/>(iii) The proposal would hurt low-income consumers most because of its regressive nature, and could even have undesirable counter-productive substitution effects, e.g. by stimulating alcohol consumption. (Soft Drinks Europe)</td><td>(i) We would have a further concern around the potential for black-market or counterfeit products entering the marketplace which may be mistaken for legitimate soft drink products and not in compliance with food and drink safety standards ... This presents a real risk of cross-border smuggling and the entry of non-controlled, potentially unsafe, black market product entering the market (Coke)<br/><br/>(ii) SSDs are recommended to balance blood sugar content in diabetics. The potential for black-market counterfeit/recipe fraud products entering the legitimate market could pose a significant health threat to Type 1 diabetics who use SSD products for their health needs; there is no guarantee that counterfeit products will be produced to the same recipe standards (IBEC)<br/><br/>(iii) The proposal would hurt low-income consumers most because of its regressive nature, and could even have undesirable counter-productive substitution effects, e.g. by stimulating alcohol consumption. (Soft Drinks Europe)</td><td>(i) Indeed, the independent Health Impact Assessment of a SSD tax in Ireland failed to find a single real-world evidence based study proving the efficacy of taxation in decreasing national obesity figures (Pepsi)<br/><br/>(ii) The experience of countries with discriminatory food taxation, such as Denmark, provides real-world evidence that such taxes are regressive and ineffective in changing diet and lifestyle-related issues (Food Drink Ireland)<br/><br/>(ii) Furthermore, the likely increase in cross-border trade and black/grey market trade in these products which would inevitably result from price hikes caused by additional tax – despite a similar UK proposal</td><td>(i) In order to help ensure legal certainty, product manufacturers/importers would need clarity as to whether current legal and industry requirements in Ireland for packaging and labelling of their products would be regarded as sufficient for the purposes of calculating and implementing a SSD tax (Irish Beverage)<br/><br/>(ii) Furthermore, the likely increase in cross-border trade and black/grey market trade in these products which would inevitably result from price hikes caused by additional tax – despite a similar UK proposal</td></tr></tbody></table>

<table><caption>Table 3
Categorising different framing actions</caption><thead><tr><th>Framing actions across issues</th><th>Categorisation of action</th></tr></thead><tbody><tr><td>Choice-giver = brand; choice taker = government; taxation = unfair = government; self-regulation = progressive = brand<br>Logics of causality; logics of public health<br>"Whole-of-society"; 'No single solution"; ""Fully committed"; "activity"; "Voluntary"<br>Stakeholder = we have the same rights; Good deeds = we care about the disadvantaged Loss of employment = we can only cope with so much regulation before something bad happens;<br>We are local; we are embedded in Irish history; we give value to Irish economy; we are loved<br>We are critical to the economy; our product is a special case; our actions are a special case<br><br>It is the dairy industry! It is Brexit! It is the black market!<br>Be both powerful and fragile, Be problem causer and solver</td><td>Attributing<br>Boomeranging<br>Co-opting<br>Demanding parity<br><br>Conflating<br>Jockeying for special position<br>Blame-shifting<br>Siloing</td></tr></tbody></table>
## Appendix B. Supplementary data

Supplementary data to this article can be found online at https://doi.org/10.1016/j.socscimed.2020.113215.

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