Policy context
In 2009, the Pacific Obesity Prevention in Communities (OPIC) project worked with local stakeholders in the Kingdom to identify 40 policy options that were potentially feasible and evaluating them, based on local data and global and regional evidence, for effectiveness and cost-effectiveness strategies if implemented in the country.14 A summary of the recommendations is presented in table 1 along with implementation status and tax rates as of 2016. While most recommendations were not implemented, legislation was enacted to increase fish consumption and reduce consumption of soft drinks and animal fats.
Policymakers
Key informant interviews were conducted with 15 participants from the Ministries of Revenue, Health, Finance and Labour & Commerce. One key informant passed away. From these interviews, five themes were identified as barriers to and/or facilitators of food-related policy in Tonga: leadership and management; cross-sector collaboration; awareness and advocacy; the nature and intent of the policy; and the use of evidence. These are expanded on below and illustrated with quotes from policymakers.
Leadership and management
Key informants were of the view that the absence of identified leaders for implementing the recommendations hindered progress. All the recommendations were advocated for and well received by the Ministry of Health as evidenced by the NCD strategy recommending government action. However, it was unclear who was responsible for implementation.
“The policy proposal was actually advocated for by the Public Health [CMO PH] for a long time. Unfortunately for some reason, the enthusiasm by [CMO PH] was not followed through.”
“…we did not also look at the body that will implement the policies and to make specific timelines and key responsibilities so they can tie down the key stakeholders to clearly state this is the deadline we’re working towards and do 1, 2, all the way through to 40…”
“It was important that we identified the needs but moving on to processing policies, we are not sure of who was supposed to do it, whether it was Health or us or any other...”
One informant suggested that more of the recommendations may have been taken up if responsibility for their passage to and through parliament was assigned to particular institutions and individuals. Another informant implied that the lack of clear lines of responsibility contributed to a gap in the pathway from translating evidence into policy action.
“…even when it’s already published [OPIC recommendations]. It should be included in our routine advocacy materials…there is a big gap from evidence and research to policy intervention…”
Secondly, informants noted a ‘lack of enthusiasm by senior health officials’ as another leadership-themed barrier to implementation that was attributed to the novelty of food-related fiscal policies in Tonga and an associated fear of taking action,
“…I think people don’t have the courage to move outside of their comfort zone. Most of us like to be followers, we wait for others to do it first…”
a lack of knowledge about trade in the health ministry
“…there was not enough trade expertise within health and there was not much discussion about trade. But I think there was a perception that it will be very difficult. So, no one really ventured into these kind of things…”
and memories of an unsuccessful attempt to place an import quota on mutton flaps that compromised World Trade Organisation accession plans.28
On the flip side, incisive individual leadership was identified as the reason for the 2013 fiscal policy changes being implemented so quickly. The determination of the then Chief Medical Officer, Public Health resulted, not only in a face-to-face meeting with the Prime Minister of Tonga, but a directive to the Minister of Revenue to fast track the policy development process.
“…it didn’t go through the [normal] process. He used his own line of communication to achieve political intervention and we see how strong that political intervention [was]…”
Good organisation leadership from the Minister of Revenue, was given as the explanation for the smooth and fast-tracked implementation of the 2016 food taxes. The Minister instructed staff in the Revenue and Customs Ministry to analyse import revenue data, model the proposed food- related taxes scenarios, discuss them with senior staff and adjust taxes and/or select other food products based on the scenarios. The legal section within the same Ministry then drafted the amendment for submission to Cabinet. In Tonga, once a tax policy is endorsed, it becomes effective immediately. There was some push-back from business, particularly to the sugar-sweetened beverage excise duties, that led to the Ministry of Revenue demonstrating leadership and enforcing the law.
“This is a government decision, there are times when we need to consult with [businesses] but there are times when we [government] need to make our own decision”.
“In relation to the SSB tax, the industry said ‘we have already put our orders through’ but the response from [government] was ‘that is actually not our responsibility, you still have to pay what the rate is now’”
Cross-sector collaboration
The Prime Minister’s directive to form a task force committee in 2013, led by the Ministry of Revenue and attended by high level representatives from Commerce, Health, Revenue and Finance, expedited endorsement of the 2013 NCD-related taxes. According to the informants, this cross-sector collaboration ensured relevant Ministries had input on the policies, that decisions were debated and made, and that feedback was provided to Ministers.
“It has been teamwork, a coordinated effort between the different ministries – health, finance, revenue and customs, and labour. No one can do it without the support of the other. We need to remember the partnership, the people and the politicians, to work together, and the champions who willingly did it without recognition or need for acknowledgement. We know it is for the best of the country.”
Decisions on which of the proposed tariff rates to change made at these meetings were informed by research provided by the World Health Organization and data provided by the Ministries of Revenue and Commerce. To minimise potential opposition to the proposed tariffs, the task force also made a strategic decision to “start small” with a plan to expand the range of food products that incurred excise taxes and progressively increase taxes on certain products. This was the reason behind the two-tiered introduction of taxes in 2013 and 2016.
“We decided that, in order to be successful with this policy, we had to start small, and that is why only 3 items were initially selected.”
While the need for collaboration was diminished in 2016 as higher taxes had already been flagged in the progression plan, participants noticed a lack of cross-sectoral collaboration the second time around. In particular, there was a pause in collaboration between the Ministries of Revenue and Health.
“We hoped to be working together with Health – I approached them [Health] but we got sick of waiting... But now it’s good …It’s an ongoing process.”
“We still need the support of the Ministry of Health and their attendance at the committee.”
The Ministry of Health were of the view that the Ministry of Revenue should initiate action because tax was the focus of the policies being implemented. It saw the Ministry of Revenue’s role in the policy implementation process as supporting the health argument underpinning the policy.
“We have raised that concept of health in all policies. For us, we are quite aware 70% of determinants of health happens outside of health …for food we put it out to Ministry of Agriculture. When it comes to taxation, we send it to Revenue to be involved in the development of policies. Most of the excise tax initiative was by Customs and Revenue. When they go public, we provide the support to make sure it’s not a money-making thing but a health gain process.”
Awareness and advocacy
Growing global and national awareness of the health and economic burden of NCDs in the leadup to the introduction of the 2013 food-related taxes was identified by participants as important to them being passed. In 2011, the High Level Meeting in New York on NCDs set a platform for NCD work to move forward. Soon after, Tonga conducted its second NCD Risk Factor STEP Survey in 2011/2012 with NCD screening being conducted with a representative sample of Tongans across the nation. Both activities raised awareness of Tonga’s NCD burden among civil society and policymakers and created a favourable environment for endorsement of the proposed taxes. Furthermore, national documents articulated the need for NCD action. The Tonga National Strategic Framework 2011 – 2014 included a specific objective to address the rise in NCD burden within the country. This was further supported by a National NCD Strategic Plan that looked at strategies to overcome some of Tonga’s worst NCD indicators. Collectively raised awareness and clear strategic directions ensured the proposal to tax unhealthy foods and make heathy food affordable was seen as a “win-win”, good for health and able to generate revenue.
“There was great support for this to be implemented. But I must say, there is still a lot of work to be done in terms of continuing this fight against NCD.”
The Chief Medical Officer for Public Health was recognised by informants as the advocate for the ‘fight against NCDs’ and the taxes and one informant noted that this continued following the introduction of the 2013 laws. The Chief Medical Officer went on national television to encourage compliance with the laws and to publicly acknowledge the contribution of policymakers.
“That was good that he did that because we would not have gone public ourselves.”
Informants indicated that there was much less awareness raising or advocacy in the lead up to the introduction of the 2016 taxes. Also, in keeping with the lack of consultation mentioned previously, there was no implementation task force. The taskforce committee was bypassed, and the taxes were simply implemented by the Ministry of Revenue. While this didn’t hinder implementation, informants noted that there were a number of complaints about the 2016 taxes and this ‘push-back’ appeared in the media.
Nature and intent of the policy
The 2013 and 2016 policy changes were in keeping with Tonga’s existing tax schedule and tariff bands. Informants noted that this made policy endorsement easier. Brand new policy would have required extensive consultation, more drafting responsibilities and greater buy-in from policymakers. Informants also noted that the policies targeted food products (like lard or dripping) that were unlikely to invoke strong public opposition. If the tax had been applied to chicken, they did not think the policy would have been endorsed.
“Meat is more expensive in Tonga than Fiji (e.g. chicken is $10 per kilo but in Fiji it is $4 per kilo), but fruit and vegetables are cheaper. The committee was told not to touch chicken [change the excise duty on it] because people will not be happy.”
With this in mind, there was some concern that the sugar-sweetened beverage tax may not have been endorsed due to public and industry opposition.
“[Sugar-sweetened beverages] could have been a huge issue, but at the end of the day it was approved.”
“At least we succeeded with the sugar sweetened drinks because, as you know, in our culture we use a lot of them eh. We not only love it, but we use the drinks at funerals”
The fact that they were fiscal policies with the capacity to generate revenue also made their endorsement easier. Policymakers noted that in the context of slow economic growth for Tonga, plans to host the South Pacific Games (which were subsequently cancelled), and decreased foreign allocation from developing partners, it was the revenue generating nature of the policy that most likely clinched the endorsement of cabinet members and the Prime Minister.
Finally, timing in the political cycle and the number of policies under consideration at any one time were also noted as factors influencing policy endorsement.
“You wouldn’t want to do it [introduce new taxes] 1 year before the election. Most of the people won’t support it because they don’t want to pay more tax.”
“You have to be sensitive to the political climate and know when to implement the change.”
“He was scared that they were all there.” [that there were too many policy recommendations for cabinet to consider all at once]
It was noted that a champion of the policies became sick at a critical time in the policy endorsement process and that other policy recommendations may have been endorsed had that not happened.
Use of evidence
Information gathering for 2013 policies was performed by a research team within the Ministry of Revenue and Customs. They sourced health data from WHO, employment and economic data from the Ministry of Labour and Commerce and import data from the Ministry of Revenue. Informants considered this data, and its subsequent collation and presentation to the committee, as critical for determining what products were to be taxed and by how much.
“He did a lot of work and sourced data from labour. The process was hard and took a long time. We needed the support of people writing the papers and getting the research done.”
According to informants, the taxes were designed to be progressive with a ‘soft’ introduction and increases over time. It was noted that this was dependent on successive governments being in agreement.
“We wanted the tax to be progressive but, in the end, we left any subsequent increases to other governments.”
Illustrating the importance of government conducting their own research, one policymaker made the following observation about the proposed tobacco tax, which was being considered at the same time as the food taxes.
“They were proactive about the tobacco tax and even asked for an increase of 5%. We said ‘no, no, no we can’t do what you say, we have to do our own analysis’. The tobacco industry has a contact in Tonga who is always ringing me to have a meeting, it is always like that. At the end of it, we have to do our own work to ensure that we actually don’t do what they want.”
Informants did not identify evidence-use barriers to implementation.