COMPARATIVE POLICY ANALYSIS OF THE ADOPTION OF SUGAR-SWEETENED

BEVERAGE TAXATION TO REDUCE SUGAR INTAKE IN ASEAN MEMBER

STATES : LESSON LEARNED FOR INDONESIA

Thesis Proposal

By
Fitri Apriliyani
22100243
 CHAPTER I
INTRODUCTION

A. Background

Excessive sugar consumption is considered to be a major factor in the weight gain and obesity.
Obesity is one of major risks connected with the non-communicable disease (Ferretti & Mariani,
2019) which accountable for 74% of all deaths globally (WHO, 2022). World Obesity
Federation, projected that between 2010 – 2030 the obesity prevalence will be doubled in the
region of South and South East Asia (Tham, et al., 2022). Non-communicable disease has been
the burden on economies and development globally as it affected the health system and human
capital productivity. (Mulcahy, et al., 2022)

Sugar-sweetened beverages are considered to be a major source of excessive sugar intake which
resulted in obesity than any other processed food (Onagan, Ho, & Chua, 2019). The World
Health Organization (WHO) recommended the sugar intake of maximum 25 grams or 100
calories per person to have a healthy lifestyle. In comparison, the typical sugar-sweetened
beverages like coke, contains 35-37grams or 140gr calories in its single 355ml can, which
already exceed the maximum recommended intake. It is reported that in general, 54% of
adolescent reported consuming this carbonated drink at least once per day. (Yang et all, 2017).

The rapid consumption of sugar sweetened beverages is seen from the affordability rate of
consumers. The rapid growth of sugar-sweetened beverages affordability was recorded by
around 8,76% per year in the lower middle income countries. (Blecher, et all, 2017). This gives
an increasing risk of the sugar intake globally which contribute to prevalence of non-
communicable disease. Given the evidence, reducing the sugar intake coming from sugar
sweetened beverage calls for intervention to improve overall diet quality and reduce the burden
in the health system.

Currently the economic burden in addressing diabetes is quite high across ASEAN member of
countries. Data showed that $830/year in Thailand (Phrommintikul, et al., 2022) is spent to
address diabets. A range of $727 to $2507 was recorded as cost to address diabetes and its
complication in Philippines (Jimeno, et al., 2021) and up to 16.8% of total health expenditure in
Malaysia was spent to treat the non-communicable diseases, including diabetes. (Zainuddin &
Su-Lyn, 2022). In Indonesia itself, the data showed that spending for diabetes was US$567/year
in Indonesia which is 10% of overall spending from public health insurance (Hidayat, et al.,
2022).

At the global level, WHO recently just launched global sugar tax manual to provide documented
evidence and promote sugar-sweetened beverage taxation for the Ministries of Finance around
the world who explores this policy option. Since 2016 only quarter of the WHO member states
are implementing the sugar sweetened beverage tax (Mulcahy, et al., 2022). Meanwhile there is
potential value to tap in to reduce the burden of healthcare funding. Globally, the revenue in soft
drink segment is up to US17.28 million with expected growth up to 5.42% (statista.com, 2022).
The sugar-sweetened beverage tax could be the extensive resource option for the government for
financing health sector or other social objectives, especially during the recovery period after the
global pandemic of COVID-19. Therefore, the implementation of the tax in sugar sweetened
beverages will provide state with budget for public health and promote the behaviour change for
the community to select healthier options.

In ASEAN countries the trend of using fiscal reform to reduce sugar intake for its community
began since 2017. The pioneer of sugar taxation adopters in ASEAN are Brunei and Thailand
which introduced the regulation back in 2017. The step is then then followed by other members
of nations, Philippines in 2018 and Malaysia in 2019. Singapore and Vietnam have been
discussing and proposing to apply SSBs taxation but no implementation just yet.

Indonesia is also proposing the bills since 2016, but due to argument of lack empirical study the
tax has not been implemented. (Sartika, et al., 2022). In 2023, Ministry of Health has sent a letter
to Ministry of Finance to encourage the implementation of sugar sweetened beverage tax as
soon. The urgency comes from the prevalence of children diabetes that increasing by 70 times
just within 13 years from 2010. (K, 2023). Ministry of Finance has already discussed about sugar
sweetened beverages and will continue the discussion with parliament in May 2023. The
implementation of this tax regulation is considering the momentum of economic recovery and
the Harmonisation of Tax Regulation (K, 2023).

ASEAN Economic Community was inaugurated in 2015 with agenda to have regional integrated
economic which covers 2,3 trillion market size and 600 millions of people. The major agenda for
the integrated economic are including a highly integrated and cohesive economy, a competitive,
innovative and dynamic ASEAN, enhanced connectivity and sectoral cooperation, a resilient,
inclusive, people oriented and people cantered ASEAN and global ASEAN. Those characteristic
support the vision of the ASEAN integrated economy in 2025. The program across the region
has been in place, especially with the free flow and levied tax among member of states.

The economic integration and free flow of goods between states in ASEAN could potentially
hinder the effort of reducing sugar intake in each ASEAN member country, especially since the
sugar-sweetened beverage taxation was not implemented in all ASEAN member countries.
ASEAN member states need to do a coordinated effort so the risk of goods entering the market
with price below desired by state can be managed. The coordination effort here does not mean
that each and every member needs to implement the same amount of tax or same mechanism
(Preece, 2019) in sugar taxation, but this is to counter measure the risk of free flow of goods
among the countries in ASEAN.

Currently 7 out of 11 ASEAN member countries have applied sugar-sweetened beverage

taxation policies. Sugar sweetened beverage taxation has been accepted as an effective policy
option to reduce sugar intake and source of tax revenue for the government to re-allocate the
resource for the finance health (Mulcahy, et al., 2022).The adoption of policy attract significant
interest from stakeholders and media attention (Kruge, et all.,2021) which affect the level of
implementation across countries. Several studies around sugar sweetened beverage taxation has
been undertaken globally for the earlier adopter and success story of the policy such as Mexico,
UK, Pacific and African region but there is limited discussion focusing on the policy across
ASEAN countries. There is also concern about the sustainability of the sugar-sweetened
beverages across nation if it is not supported through coalition. (Roache & Gostin, 2018). By
learning the common issue that leads to the adoption and implementation of the regulation, this
could be a recommendation for the Indonesian government to consider and to accelerate the
implementation of the sugar sweetened beverage tax.

Therefore, this study is proposed to analyse the policy adoption process of sugar sweetened
beverage tax using the framework of qualitative comparative policy analysis among the ASEAN
countries, focusing on the early adopter Thailand, Brunei, Philippines and Malaysia. We use the
policy diffusion approach in this study as we learn that the state actors often mentioning about
learning process from the neighbourhood countries within ASEAN in the agenda setting and
framing. A stronger advocation of this policy could be linked on ASEAN Economic Community
agenda, with Indonesia is currently holding the chairmanship.

B. Research Question
1. How do the sugar-sweetened beverages tax being adopted or proposed by the ASEAN
member of states?
2. What strategy applied by the countries in ASEAN who applied sugar sweetened
beverages taxation in addressing the concern related to economic and investment?
3. What are the similarities in policy adoption across early adopters in ASEAN member
of states that could be used as lesson learned, especially to Indonesia?

C. Research Objectives
1. This study aim to describe the agenda setting and framing of the sugar-sweetened
beverages tax that is already implemented by early adopter in the ASEAN member of
states.
2. The study will describe the strategy used by the government in addressing the
economic and investment issue caused by implementation of sugar sweetened
beverages in ASEAN countries.
3. This study would like to understand the characteristic across policy adoption that can
be used as lesson learned by future adopter across ASEAN member of states.
D. Significance of the research
This research will provide contributions to :
- To government of Indonesia and stakeholders to provide more evidences and lesson
learned in the adoption of sugar sweetened beverage tax. These evidences and lesson
learned could contribute to the study in the regulation adoption thus will accelerate
the implementation process in Indonesia.
- Fellow policy researchers, this study will give understanding on the similarities of the
earlier adopters of the sugar sweetened beverage taxation across ASEAN countries.
The research can give more knowledge on the process of policy learning from state to
state interaction and transnational bodies to tackle issue in their setting. Additionally,
this could contribute to the development of knowledge of the comparative study
related to sugar sweetened beverage policy adoption across countries in ASEAN
region.
- To public, this study could show more evidences to the public on the effectiveness of
the sugar sweetened beverage taxation to reduce the consumption of sugar as
happened in the early adopter countries. This could promote a healthier community
and reduce the risk of non-communicable diseases by utilizing fiscal measures.

E. Scope of Research
The study will focus on looking at the similarities of policy adoption of sugar-sweetened
beverage taxation across ASEAN member of states. The samples will be limited to the
earlier adopters which are Brunei, Thailand, Philippines and Malaysia, to draw the lesson
learned from the other country as a lesson learned for the Indonesia setting. The
discussion for other ASEAN member of states are not comprehensive due to limitation in
availability of information in English.
 CHAPTER II
LITERATURE REVIEW

A. Sugar Sweetened Beverages and Associated Risks

Sugar sweetened beverages are the non-alcohol pre-packed beverage with sugar in it.
(WHO manual, 2022). There are several variations of these beverages such as carbonated
drinks, milk base product, juices, sweetened plant-based product, energy drink, vitamin
drink, flavoured coffee and tea etc. Those typical beverages contain 5,5 to 10 teaspoon of
sugar content per 330ml (WHO manual, 2022). The American Heart Association (AHA)
recommend for children to have maximum 6 teaspoon of sugar a day and 9 teaspoon
sugar for adults. Therefore, a single can or bottle or sugar sweetened beverage is already
risky in reaching the maximum recommended sugar intake for both children and adults.
With the fact, no wonder that the sugar sweetened beverages are regarded to be one of the
most significant factors that leads to the excessive energy intake in comparison to other
kind of processed food. (Ferretti & Mariani, 2019)

Additionally, the consumption of this type of beverages could potentially reduce the
consumption of food which has better nutrition, for example plain water. There several
types of ready to drink beverages such as fruit flavoured beverages, canned coffee and
teas which usually contain lots of refined sugars. Consumers are provided with selections
of beverages which have no or less quality in the nutrition. (Malik & Hu, 2022). With the
branding of juice or tea, community is led to think that their choice of beverage
consumption can substitute the nutrition from the real fruits or tea. While in fact, no or
less nutrition intake that can be consumed from the above mentioned beverages, and still
added with disease risk from the refined sugar content.
 The issue with sugar sweetened beverages also lies on how these beverages are widely
accessible and affordable. When it is affordable and can be found anywhere, it is easy to
have high consumption among communities in all age and economic background. The
high consumption of sugar from sugar sweetened beverages increase the risk of the
obesity prevalence. A study revealed that in every 10% increase on the affordability in
the community, it positively impacts the obesity rate by 0.4 point for every 100 people.
(Ferretti & Mariani, 2019).

Obesity has been a problem in the public health and is now considered to be global
epidemic (Boutari & Mantzoros, 2022). Currently, more than 1 billion people worldwide
are obese with 39 million are children (WHO, 2022). Obesity is highly linked to the diet-
related non-communicable diseases (NCDs). NCDs are accountable for the 71% death
globally and around 40% out of them are coming from diet-related NCDs. Therefore, the
issue is very urgent and call for a measure to reduce NDCs by addressing the factors that
increase the prevalence of the obesity, especially from the sugar consumption.

From the public policy perspectives, there are several measures options that have been
implemented in reducing the sugar intake across communities. These measures are
mostly to drive the public behaviour in consuming sugar. Taxing sugar sweetened
beverages, limiting the access of the sugar-sweetened beverages at schools, reducing the
marketing of unhealthy beverages such as limitation of commercial advertisement and
package labelling system are the measures that have been introduced so far as
intervention for the issue. More studies needed to evaluate the implementation and to
understand effectiveness of these policy options. In this study particularly, the research
will focus on the state fiscal policy in promoting healthy diet by implementing sugar
sweetened beverage taxation.

B. Fiscal Policy for Health – Sugar-Sweetened Beverages Taxation

One of the measures to reduce the sugar intake to the community is by the introduction of
sugar-sweetened beverages taxation. This regulation has been implemented in more than
45 countries, in national levels and at sub-national level. (Andreyeva, et al., 2022).
 Taxation is evidently effective to reduce the intake as well as to generate state revenue
for public health funding. It was reported in UK, the sugar tax has prevented 5,234 cases
of obesity in every year or around 8% among year 6 girls obesity rate. (Guardian, 2023).
The success story on the implementation of sugar sweetened beverages also comes from
Mexico which prevented more than 200,000 people from developing obesity. The effort
in reducing the sugar consumption in Mexico saved up to $980 million from public health
funding between 2013-2022. (Sanchez, et all.,2016 in Malik & Hu, 2022).

There are two rationales in implementing the sugar-sweetened beverages which are the
health rationale and economic rationale. The health rationale of implementing sugar-
sweetened beverages is to reduce the prevalence of non-communicable disease (NDCs)
by promoting healthy diet. Increasing price of the sugar-sweetened beverages is expected
to drive the customers to be more selective in their choice of consumption towards a
cheaper and healthier option such as plain water. The risk of having chronic disease is
clear, especially with the pandemic COVID-19, patient with chronic disease such as
diabetes have positive association with increasing risk of hospitalized or in hospital
mortality. (Semenzato, et al., 2021). Therefore, promoting healthy diet by reducing the
sugar intake to reduce the prevalence of diabetes is crucial.

The economic rationale for the implementation of sugar-sweetened beverages is to

diversify the excise taxation resource. Pandemic COVID-19 has attacked the economic
stability of many countries in the world. Government can tap in to the opportunity in
having the excise tax measure to generate more revenue which can be used to support the
economy recovery after pandemic. Additionally, the revenue could potentially help the
state to build better health facilitates across the countries. The sugar sweetened beverages
then could serve as a solution to the health issue on chronic disease by driving customers
to be selective in consuming sugar and to reduce the burden of public health finance.

C. ASEAN Economic Community and its integrated plan

The Association of Southeast Asian Nations or well known as ASEAN is an interstate

union that was established on 8 August 1967 under the ASEAN Declaration by the
founding fathers which are: Indonesia, Malaysia, Philippines, Singapore and Thailand.
Currently there are 11 countries member of ASEAN, comprises of Indonesia, Malaysia,
Philippines, Singapore, Thailand, Brunei, Laos DPR, Myanmar, Cambodia, Vietnam and
Timor Leste. The purpose of the union is to promote economic and cultural exchange
among the member of states, maintain the regional stability and to establish relationship
with the other powers in similar goals. The headquarter of ASEAN is located in Jakarta,
Indonesia and Indonesia is now taking the chairmanship of ASEAN in 2023, with theme
ASEAN Matters: Epicentrum of Growth.

Supporting the growth of the member of ASEAN countries, one of the prominent agenda
across the ASEAN member of states is the ASEAN Economic Community (AEC).
Officially launched on 31 December 2015, the AEC focus is to strengthening the
economic together across ASEAN member of states with main goals :
- to have integrated economic, with a vision to make ASEAN as a single production
base and market,
- to be highly competitive region with significant economic development, and
- to be fully integrated to global economy.

As a realization of the agenda above, several agreements are set to facilitate the
movement of goods, service, capital, skills and investment, increase trade, promote and
expand regional production network, and promote better transparency and predictability
among the member of states. Free movement of goods and service across member of
state, however, did not followed by the integration of policy underlining just yet. In this
case with focus on the excise tax, there should be a coordination effort across state on
taxation as to facilitate trade across border.

Among the excise taxes, the focus is on the sugar sweetened beverages. The free flow of
sugar sweetened beverages across countries could potentially harmed the national effort
when implementing the excise tax to limit the consumption. The market mechanism
might not work as desired by the states because there is no coordinated effort in limiting
 the sugar consumption across the borders. There is a potential of goods coming to the
national market with price under state desired price. (Preece, 2019).

The ASEAN member of states apply different measures to reduce the consumption of
sugar in national level. Some of the states have already implementing the sugar
sweetened beverages taxation or in this case is the early adopters and some of the states
are still discussing and proposing the tax to be implemented. Other measures are being
implemented such as package labelling and food grading, are being implemented in
Singapore currently. A table below describe the details of adoption and implementation
of sugar sweetened taxation by member state of ASEAN.

Tax per litre or ad

Country in ASEAN Year Adoption Sugar Content
valorem rate
6 gram per 100
$0.30
mililitres
> 7 gram per 100
mililitres (soy based $0.30
Brunei 2017 milk)
> 8 gr per 100
$0.30
mililitres
Milk based and fruit
$0.00
juice
Cambodia   based on value 10%
Indonesia proposed   $0.22 or 10-20%
Laos DPR   based on value 5%
5 gram per 100
$0.10
mililitres
Malaysia 2019 >12 grams per 100
mililitres $0.10
(fruit/vegetable juice)
Myanmar   based on value 5%
natural sugar or
$0.12
artificial sweeteners
use high fructise corn
Phillipines 2018 $0.24
syrup
coconut sap sugar or
$0.00
non-caloric sweetener
 Review and public
consultation,
The preferred
action now is to
have non-fiscal
approach,
Singapore mandatory    
labelling grade
from A-D with D
most non-healthy
food/drinks.
Implemented by
end of 2023
6-8 gr per 100
2017 $0.003 +14%
mililitres
8-10 gr pr 100
$0.009 + 14%
mililitres
Thailand
10-14 gr per 100
in 2023 $0.0015 +14%
mililitres
>14 gr per 100
$0.031 + 14%
mililitres
Vietnam Proposed   10%
Timor Leste NA NA  NA 

Table.1 Sugar Sweetened Taxation across ASEAN (Preece, 2019 and WCRF data)

D. Indonesia Context on the Implementation of Sugar Sweetened Beverages

Over the past decades, the number of obese adults is increasing from 10.3 to 21.8 %
according to the national basic health survey in 2018 (Segalita, 2023). This serious case is
added with the data that diabetes ranked as third leading cause of death in Indonesia
increasing by 49,9% between 2009-2019 (healthdata.org/Indonesia). Diabetes is heavily
linked to the overconsumption of sugar in pre-prepared beverages. The national statistical
agency (BPS) reported the increasing consumption of pre-prepared food and beverages
both in rural and urban area with average doubled from 2011-2019. The sugar sweetened
beverages consumption in Indonesia is the third biggest among ASEAN countries with
20,23 litre/person/year. (Faculty of Medicine and Public Health UGM, 2020)
Indonesia has a regulatory framework that functions to control the consumption or usage
by the community if there is negative effect on the consumption via excise tax such as
with alcohol and tobacco. The UU no. 37 year 2007 regulates goods that:
1. the consumption should be limited,
2. the goods that need surveillance in the distribution,
3. the goods that the consumption will affect the environment and
4. to fulfil the justice among society.
The sugar sweetened beverages fits well with the regulation above especially the point
one as the limitation of sugar consumption from sugar sweetened beverages needs to be
implemented. This will significantly reduce the burden of the public health budget to
address diabetes.

As reported in the media, the budget from Indonesian National Health Insurance (BPJS)
to address diabetes keep increasing from 2018 at 6.5T rupiah to 7.1T rupiah in 2019 and
in 2022 reached 7.5T rupiah (CNN Indonesia , 2023). This burden of public health
budget will keep increasing if there is no intervention to reduce the sugar consumption
among the communities in Indonesia. One of the intervention that can be adopted is
through the implementation of sugar sweetened tax.

The Indonesian Ministry of Finance has advocated the extension of excise tax to sugar
sweetened beverage in 2012 and 2016 but had not get the desired outcome. This year
especially the government included the sugar sweetened beverage tax in the draft national
budgeting for 2023 alongside with the plastic tax, with potential revenue 245,4T rupiah.
(Putri, 2022). Parliament also has approved this move, however no implementation is
placed yet with the reasoning that the government is still considering the economic
recovery.

This regulation is not just easily accepted by all the stakeholders. Representative from the
industry stated that the regulation will potentially harm the industry and the society as
consumers. The pressure is especially that the industry is just waking up from the
pandemic, added with the increase price from energy, logistic, wages and the increasing
 competition with non-manufactured beverages (KumparanBisnis, 2022). For the sugar
sweetened beverages especially, the industry voiced their concern as both subjects tax are
two major materials used for the industry. The increasing of price due to tax subjects
could reduce the competitive advantages for the industry.

Those objection from the industry sectors should be addressed by the government when
the government implement the excise tax. Learning from the case study of the
neighbourhood countries could be a way to formulate best practice of the policy adoption
that could reduce the over consumption of sugar sweetened beverages while also address
the concern from the industry, one of them could be by giving incentives to the industry
who can innovate the product to provide a healthier option to the society.

E. Previous Studies

The research on sugar sweetened beverages taxation are mostly related to the empirical
studies around the implementation in the national or subnational level. Meanwhile the
research on the comparative analysis on the implementation of sugar sweetened
beverages taxation are remain limited, especially when it is discussing the in regional
trend of adoption of policy. The studies that are conducted are the result from the earlier
adopter of the policy. Given the variety of determinant in policy adoption, this is a call
from academician to engage in more policy analysis in the taxation of sugar sweetened
beverages to foster experience sharing. (Roache & Gostin, 2018) (Kruger, et all., 2021).

The adoption and implementation of sugar sweetened beverages in other countries is a

potential policy learning for other countries (Mulcahy, et al., 2022). The recent study is
analysing the policy adoption and implementation by policy learning and diffusion from
global organization and regional entity. The research was assessing sugar-sweetened
beverage taxes implementation and adoption in 16 countries representing the early and
latter adopter of the policy from 2016 to 2019. This study revealed that a consistent
public frames across countries were identified to reduce the prevalence of non-
communicable disease and to reduce the burden of public health system. The study also
 identified that opposing policy came from industry that sugar sweetened beverage
taxation will cause economic regression in food industry. Additionally, there was
evident on how the 16 countries are adopting the policy through policy diffusion
network such as international organization (WHO) and other regional economic bodies.
(Mulcahy, et al., 2022).

Another study was conducted in a similar approach of drawing the adoption of sugar
sweetened beverages across the region of Europe based on diffusion of innovation from
WHO. Policy document, media and qualitative interview data are collected to analyse
the adoption of taxes in 10 countries across Europe. The study revealed that ongoing
policy learning to improve tax design, collaborative partnership between policy decision
maker in health and finance sectors are crucial in the success of adoption of tax policy.
The tax design should also involve the consideration for revenue generation especially
for the during the recovery time just like now. Interestingly, the study suggested that
regional body could play greater role in supporting the taxation of sugar sweetened
beverages (Thow, et al., 2022).

In the ASEAN region itself, a study suggested that regional coordination around
taxation, especially in excise tax should be implemented. The study points out how the
trend of fiscal transformation happening in the ASEAN region especially the excise tax
that focus on promoting healthy diet. One of them is the sugar sweetened beverages
(Preece, 2019). The study points out that countries in ASEAN region should be able to
better aligning excise policy priorities and proposing the way how to better coordinate
excise tax policy leading to the integration agenda of ASEAN Economic Community.

F. Theoretical Framework on Comparative Policy Analysis: Diffusion Policy Theory

Comparative policy analysis can be defined as a systematic study and comparison of

policies across different jurisdictions, states, provinces or countries referencing the policy
in the study. (Ritter, et al.,2016). Basically, this approach examine policies in two or
more setting and/or between certain period of time. (Peters, 2020). Comparative policy
analysis can generate useful insights (Ritter, et al., 2016). This study would like to draw
the lesson learned among the previous implementer of the sugar sweetened beverages
across ASEAN countries, thus the researcher will do comparable case studies across the
selected states.

The advantage of the comparative policy analysis is to understand the notion of necesities
or the condition where the policy leads to outome or vice versa, what sort of condition
that do not lead to the outcome (Thomman, 2020). In relation to drawing the lesson
learned for Indonesia, the researchers would like to gather the case studies in the policy
formulation and adoption of sugar sweetened beverage tax from the countries who are in
the same economic and geographic proximity, namely ASEAN countries. From the case
studies, the study aimed to formulate the common issue or common conditions that leads
to the outcome of the policy adoption. One of the prominent theory and framework in the
policy adoption is through policy diffusion.

Policy diffusion is defined as the process of adoption of policy that is interdependent, that
the decision maker is influenced by the choice selected by other decision maker. The
policy diffusion has four interdependencies mechanism which are learning, competition,
coercion and emulation(Braun, et al., 2007). In the context of public health, the evidence
and effectiveness from other countries are used as a benchmarking in adopting the
regulation. Diffusion itself is defined to be a social process that responds to learning for
example a new evidence-based to be implemented to improve the health care. (Dearing
& Cox, 2018). With the world become global and much more connected along with how
each countries are interdependent especially with those who have regional proximity, it is
easy for the decision maker to learn the regulation from each other.

The policy diffusion is generally linked to policy learning across countries. Policy
diffusion researchers have found that national policy, media attention would be able to
influence the consideration of policy at state level. Intermediaries also play important
factors in diffusing policy by working on the political window of opportunity and frame
 solution to the issue in a political favourable ways (Dearing & Cox, 2018). These
paradigm in policy diffusion is then build up the theoretical framework that is being used
in this study.

Element of Theoretical Indicator Data source

Diffusion Theory characteristic
Policy agenda : Setting of policy Tax name, taxed Policy document
sugar sweetened instrument, goods, Government website
beverage taxes, feasibility,
sugary tax, soda tax. compatibility

Diffusion networks Non-state actors and The manual from Report

international World Bank and
organization, WHO as
membership of policy multinational
communities institutions who
provide manual on
sugar sweetened
beverage tax

Influential actors/ Non-state actors, Name and type of News report

change of agents decision makers, actor and advocacy
access to political coalition
stakeholders
Mechanism for policy
process engagement
Earlier adopters Value, health context, Prevalence of NDCs Policy documents and
political will and consumption of news report
sugar

Government public
health cost

Framing on health
using fiscal
transformation

Policy formulation

Table 2. Theoretical Framework of Analysis (Mulcahy, et al., 2022); (Thow, et all., 2022)
 CHAPTER III
RESEARCH METHODOLOGY

A. Research Approach

The research will employ the qualitative study as it focuses on why and how the policy
adoption happens across nation in the ASEAN region. Qualitative research is defined as
the study of phenomena in nature, including the manifestation and context in which it
appears but not the frequency and range or place in an determined chain or cause and
effect. (Busetto et all, 2020).

In the perspective of the public policy, this research will use the approach of qualitative
comparative analysis. This method is selected because it offers the ability to capture the
potential influence in the decision making process (Rihoux et all, 2011 in Thomann
2020) to gather a lesson learn in the pattern and factors influencing the decision making
activities. To be able to compare the data across nation, case study is selected as
methodology in gathering documentary, narratives and other data from the ASEAN
member countries. The selected samples are then divided into early adopter and latter or
potential adopter of sugar-sweetened beverage taxation policy. The adoption of the policy
is highly contextual therefore, case study is being selected as enables the researchers to
have exploration of phenomena within specific context. (Rashid et all, 2019).

B. Data Collection

Data collection techniques that are used for this study comprises of :
1. Literature study, this is a method in collecting date from several literatures such
journal and report. In providing the data to be compared across the framework of
policy diffusion, case study literature from ASEAN member of countries is being
collected. Case studies are often selected in analyse the health policy where the
researchers do not have control in the outcome of the phenomenon (Kruge, et all.,
2021). This case study literature is obtained from the journal published between 2017
to date, noting that the first adoption of the policy began in 2017. The literature study
is also includes some policy document that is obtained from the official website of the
respective countries who adopted sugar-sweetened beverages.
2. National Statistic : Researchers also collected national statistic from various sources
to provide data in each context. The data collected includes but not limited to the
sugar-sweetened beverage consumption, prevalence of diabetes across ASEAN
member states and the statistic of tax implemented. The source of this data mainly
comes from the online report provided by World Bank, Global Health Observatory,
International Diabetes Federation official website and newspaper data.
3. Online media data : Public positions and media coverages on the adoption and or
implementation of sugar-sweetened beverage taxation in the region are identified
from the online reports. The researcher uses the google search engine to provide
information on media report especially for the countries who are latter adopters or
still in the discussion of adopting the sugar-sweetened beverage taxation policy.
4. Interview Data : A semi structured interviews is prepared based on the framework of
study which includes the policy process, actors who support and oppose the policy,
any learning from other states or organization body and any other diffusions (Thow,
et al., 2022) to interviewee identified through WHO in country contact. WHO is
currently works across 11 countries in South-East Asia in which only 2 member of
ASEAN, Indonesia and Thailand have representative offices. Currently there is no
specific body within ASEAN organization that addressed specifically on public health
taxation. Interviews at national level will be conducted by identify the relevant
officials from Ministry of Finance and Ministry of Health, such as Directorate
Technic and Facilitation of Taxation and Directorate Prevention and Control of Non-
Communicable Disease.
 C. Data Analysis

The research data will be analysed using qualitative method which includes but not
limited to reviewing the data, selecting the relevant information to the study and
categorizing the data. To enhance the validity of data, triangulation data will be used to
cross-check evidence across the data obtained from the documentary to the interview
results that is being conducted. Based on the integrated case study analysis, the data from
ASEAN member countries are being synthesized and categorized based on the custom
table in excel format based on framework selected for the study. (Yin,2003 in Mulcahy
2022).

D. Gantt Chart Planning for Writing and Research Process

Activities Feb Feb Mar Mar Apr Apr May May
Proposal writing
Research Planning
Data collection
Data analysis
Draft consultation
Final draft submission
Revision of draft
Annex: Research Instrument

Identified interviewee
1. Head of Tax Potential, Directorate of Taxation Technic and Facilitation, Mr. Ali Winoto
a. Recently there has been a discussion on the excise tax for sugar sweetened beverages,
do you think Indonesia will implement soon in this year as mentioned in news?
b. What is the rational behind, is it because the recommendation from Ministry of
Health or as extensive source of income due to pandemic?
c. With the implementation of excise tax, do the government see and learn the
implementation from other neighbourhood countries for example in ASEAN or other
multinational organization like WHO or World Bank?
d. What kind of guidance that is used by the government to formulate the excise tax? Is
it by amount or is it by sugar content for example?
e. What would be the strategy from Government in addressing the rejection from
industry especially with their concern that it could hinder the economic recovery?
f. Do you think a regional organization like ASEAN could accelerate the
implementation of sugar sweetened beverage tax?
g. What do you think would be the best practice of the implementation of sugar
sweetened beverage in Indonesia to reduce the sugar consumption and support the
national development?

2. Directorate for Prevention and Control of Non-Communicable Disease, Ministry of

Health
 a. Recently there has been a discussion on the excise tax for sugar sweetened beverages,
What do you think about it, do you think the tax can reduce the consumption of sugar
in community and reduce the prevalence of diabetes?
b. How urgent do you think is the implementation of the sugar sweetened tax?
c. Do Ministry of Health learn from other countries or from the multinational
organization like WHO or World Bank in formulating the recommendation to the
Ministry of Finance to implement the sugar sweetened beverages? Which part of the
regulation that is learnt from the other country?
d. Do you think a regional organization like ASEAN could accelerate the
implementation of sugar sweetened beverage tax?
e. What do you think to be the best practice of the policy to reduce the sugar
consumption to the society so it can support the national development?

3. WHO representative Indonesia, Dr. N. Paranietharan

a. WHO has just recently launched the WHO Manual on sugar sweetened beverage tax
to support the countries to implement this type of tax, do you think Indonesia should
also adopt this regulation and why?
b. What do you think the urgency for Indonesia to implement this tax, noting that the
discussion is actually since 2012 and now more than 10 years passed but no
implementation just yet.
c. What do you think the set of conditions that should be there for Indonesia to adopt
and implement the sugar sweetened beverages tax to reduce the sugar consumption?
d. Do you think the multinational organizations such as WHO and probably ASEAN has
role in accelerating the implementation of the regulation?
e. What would be the best practice of the adoption and implementation of the sugar
sweetened beverages in ASEAN countries and Indonesia?

4. CISDI Researchers working on sugar sweetened beverage Tax : Gita Kusnadi

a. CISDI has been tirelessly advocating the sugar sweetened beverage tax
implementation in Indonesia, what do you think the urgency of this matter?
 b. What do you think the factors that hinder the adoption and implementation of sugar
sweetened beverage tax in Indonesia?
c. What do you think the set of conditions that should be existed in Indonesia to be able
to adopt and implement the sugar sweetened tax? Do you think that Indonesia should
also learn the adoption from neighbouring countries who adopted the regulation
before?
d. Do you think that the coalition such as ASEAN or WHO or World Bank could be one
of the strong supporters of the sustainability of the regulation?
e. What do you think would be the best practice of the sugar sweetened beverage tax in
Indonesia?

5. KADIN representative
a. Recently there has been discussion on the implementation of sugar and plastic tax that
will be directly affect the beverage industry, how do think about this?
b. What will be the effect of the implementation of the sugar sweetened beverages to the
industry?
c. As reported by media, the sugar sweetened beverages are not healthy for kids, so
there is a reasonable cause of the implementation, if you don’t support the policy,
what do you think could be the alternative?
d. I noted that you are not supporting this regulation, learning from other countries, if
there is program that support the innovation of industry to have a less sugar products
or no sugar product, will this help?
e. What do you think the ideal situation for this? As you noted that tobacco and alcohol
also have this kind of excise tax but still thriving.
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