Background The United Kingdom (UK) Chancellor of the exchequer announced a tax on sugar sweetened beverages in his March 2016 budget to help reduce sugar consumption and prevent obesity and its associated poor health outcomes. A public consultation on the Soft Drinks Industry Levy (SDIL) was conducted before the levy’s implementation in 2018. We aimed to identify arguments that industry stakeholders made during the public consultation to influence the development of this policy, and to inform future policy processes.

Methods Thematic framework analysis was used with a novel complex systems lens. Industry stakeholders’ (manufacturers, retailers, or representative trade associations) submissions to the UK government’s 2016 SDIL public consultation were obtained via a Freedom of Information request to Her Majesty’s Revenue & Customs and Her Majesty’s Treasury. The five steps of framework analysis were conducted sequentially. After familiarisation with the data, codes were indexed and charted according to the thematic framework. Final analysis was conducted by comparing complex system terms with the codes in a framework matrix in a novel approach to incorporate a complex system lens to the analysis.

Results Forty-two submissions were obtained (27 from businesses, 11 from trade associations, and 4 undocumented). Industry stakeholders were overall opposed to the SDIL. Key themes included unintended consequences of the levy, denying the impact of the levy, the responsibility of government to industry over health, and proposals of alternative policies. Industry stakeholders showed awareness of complexity from a business perspective, but employed simplistic, linear arguments to contest the intended impacts of the policy. Multiple, previously documented industry tactics were referred to, including promoting voluntary agreements, use of industry commissioned research, and questioning the effectiveness of the policy.

Conclusion Industry stakeholders’ submissions to the SDIL consultation opposed an evidence- based policy and did not consistently acknowledge the complexity of predicted effects of the levy. The use of documented industry tactics emphasised the need for a transparent consultation process, with pro-actively managed stakeholder representation. A complex systems approach, alongside robust evidence, could help pre-empt and mitigate unwarranted push-back on public health policies from industry.