HEALA: 2022 Division of Revenue Proposals

Submission to Standing Committee on Appropriations

1. Background

Introduced in 2018, the Health Promotion Levy (HPL) is a tax designed to precisely target the sugar content added to sugar sweetened beverages (SSBs) beyond acceptable thresholds. This lowers overall sugar consumption via SSBs through incentivising companies towards reformulating their products and affecting a reduction in demand and consumption of such goods by consumers. This levy is essential to enforce industry accountability for public health in the South African context; where excessive and increasing consumption of SSBs, driven by aggressive market behaviour, significantly contributes to our spiralling rates of obesity and diet-related non-communicable-diseases (NCDs) such as type 2 diabetes, cardiovascular diseases, certain cancers and tooth decay.

Despite its relatively short period of existence, and the watered-down rate at which it was introduced, its positive impact on sugar consumption is already evident. By arresting this trend, the longer-term effects will bring a massive saving of lives, as well as billions in healthcare costs and related economic burdens otherwise incurred.

While not the primary goal of the HPL, the additional positive impact is the raising of significant revenue for the state budget. For a struggling healthcare system that is increasingly financially constrained and overburdened, the availability of such funding is invaluable. However, the potential impact of these funds is currently limited by a lack of dedicated and effective oversight as to their use. Within the context of many competing socio-economic needs, policymakers are obligated to prioritise usage of the revenue raised in a manner that can most effectively advance rights to health and wellbeing of the most vulnerable people living in South Africa.

2. Assessment of Current HPL Collections & Usage

Currently, the HPL sets a levy-free threshold of four grams of sugar per 100ml in non-alcoholic SSBs produced or imported for domestic consumption (excluding certain items such as fruit juices and dairy products), levying a fixed rate per gram of sugar that exceeds this. National Treasury commendably raised this rate by 4.5% to 2.31 cents per gram in 2022 – while further consultations may see the welcomed inclusion of fruit juices and reduction of levy-free threshold. In practice, this amounts to a tax of 10% to 11% on the price of 1 litre of the average sugar-sweetened beverage.

From its inception to March 2021, the cumulative revenue raised from both domestically produced and imported SSBs amounts to R7.9 billion. This represents a collection of R3.2 bn, R2.5bn and R2.1bn across financial years 2018/19, 2019/20, and 2020/21 respectively. Declines in revenue collected are potentially expected as producer and consumer behaviour respond positively to the HPL. The impact of COVID-19 on the market also played a significant factor in the decrease over the previous two years. National Treasury estimates annual HPL collections to increase over the coming financial years due to market recovery and growth; increasing up to R2.8bn by 2024/25.

Here, we should note that the compromise with business to reduce the levy rate from the proposed 20% to 11% has meant not only massively restricting its positive impact on public health, but also forfeiting billions in potential revenue.

Nonetheless, even the current rate produces a substantial source of revenue; annually accounting for around 0.2% of the state’s total budget revenue. Yet the ongoing concern is the use thereof.

At present, neither the entirety nor simply a portion of this tax revenue is earmarked for any particular purpose, going instead to the National Revenue Fund for general government expenditure. Treasury’s explanation for this is that “the legislative earmarking of revenue is not supported as it will introduce rigidities in the budgeting process”.5 Rather it can be referred to as being ‘soft ring-fenced’. In this, the government has stated commitment for additional budgetary support for health promotion and chronic disease prevention programmes, as identified by the National Department of Health (NDoH). Presumably supported from this revenue, the 2021 Medium Term Expenditure Framework raised NDoH’s budget allocation for health promotion to around R50 million per annum. By 2021, actual expenditure under health promotion totalled a mere R34 million over 2019/20 and 2020/21.

It is deeply inadequate that from the Health Promotion Levy raising R7.9 billion over 3 years, the very justification for its existence receives such a miniscule budget allocation; which is then underspent at that. Meanwhile, the entire health budget faces cuts of over R50 billion in real terms over the next 3 years. This needs to be changed.

3. A More Comprehensive Approach to Health Promotion

Restructuring how the tax revenue from the HPL is allocated and spent, whether partially or entirely, is a necessary, beneficial and strategic consideration. The presence of unallocated funding in the National Revenue Fund may be seen as desirable for potential rainy days or administrative ease. Yet policymakers are obligated to weigh this choice against tangible alternatives to evaluate which route, or what compromise between them, best protects South Africans’ Constitutional rights while prioritising the most vulnerable.

South Africa struggles with a double burden of malnutrition – especially seen in children. The reality is that 1 in 4 children (27%) are stunted (chronically malnourished) which is coupled with an increasing child and adolescent overweight and obesity – all increasing the growing burden of NCDs. The need to intervene early is vital. The first 1000 days from conception to two years old is a critical time to address immediate undernutrition and consequent overweight or obesity later in life. Although this time is vital for long term results, addressing the current issue of childhood hunger must be prioritized. Positive results of good nutrition during early childhood may be reversed by poor nutrition
during adolescence. The reality is that 30% of South African children live in households living below the food poverty line – where adequate nutrition needed for optimum growth and development is out of their reach.7 The NIDS-CRAM reports, found that during the pandemic child hunger had risen to 14% (1 in 7 people indicated a child in their household had gone hungry in the prior week) and that 400 000 children lived in households that experience perpetual hunger (hunger every day or almost every day) during each of the waves.

The need to invest in food and nutrition security initiatives in South Africa that can protect children from both under and over nutrition is pertinent to creating a thriving population that can reach their physical, mental and economic potential. This can be done through increasing funding of existing interventions such as the National School Nutrition Programme (NSNP) to expand the programme and provide more meals to school learners and expanding existing social protection measures.

These alternatives should be identified by their alignment with the holistic intent of the HPL, and furtherance of its goals. This entails not only support for the NDoH’s health promotion programme, but other high impact areas that can contribute to decreasing the burden of obesity and diet related NCDs. Effectively, by linking the majority expenditure of HPL collections from the goals of the HPL itself, we are creating a far more comprehensive policy that can more directly funnel resources from unhealthy economic and behavioural activities into opposingly healthier ones for much greater overall impact. This strengthens the HPL into a far more impactful policy with greater measurable benefits. An inevitable result of this is the deepening of public trust in and support for the HPL and policy-makers’ intentions behind it; an invaluable resource in the event of widening or raising the HPL.

4. Potential Strategies for Utilisation

Proactive dedication of the levy’s revenue offers many benefits, but how and where. Our key proposals are as follows:

Proposed Strategies:

  • Increasing support for NSNP
  • Supporting nutrition of children in the critical first 1000 days: Maternity Grant
  • Improving nutrition in households: Basic Income Support
4.1 Increasing Support for the National School Nutrition Programme (NSNP)

The National School Nutrition Programme (NSNP) is a lifesaving feeding scheme that benefits over 9 million learners aged four and above every day. The programme’s objectives include providing all learners one nutritious meal to enhance learning, strengthening nutrition education in schools to promote healthy lifestyles with the use of food production initiatives (school gardens). This programme allows learners to realise their constitutional rights to basic nutrition (Section 28(1)(c)) and basic education (Section 29(1)(a)) and aims to improve their ability to learn through reducing hunger, combating malnutrition and improving school attendance. The NSNP is an effective poverty alleviation intervention, reaching some of the most vulnerable children in South Africa by targeting schools in the socio-economic quintiles one, two and three or the “no fee-paying schools”).

The NSNP is guided by a conditional grant framework (CGF) with specific budget allocations according to the following, at least 96% of the budget should be spent on school feeding and purchasing cooking, education including deworming should be a minimum of 0.5%and administration a maximum of 3.5%.

Although the NSNP can improve punctuality, school attendance, mental concentration, and learners’ general well-being – it has fallen short in implementation. In 2017, the Legal Resources Centre compiled an analysis of the NSNP in the Eastern Cape. The daily nutritious meal should provide 30% of the recommended daily allowance (RDA) of energy; however, the report found that the meals served only provided 16% of the RDAs – equivalent to a snack rather than a meal. The Department of Education (DOE) evaluation of the implementation of the NSNP in 2016 found that only half of the schools received balanced meals including three food groups (starch, protein, and vegetables) and 42.4% of schools only served two food groups, often omitting vegetables.

Schools argue that they cannot meet the NSNP’s nutrition requirements without sufficient funding, while most Provincial DBEs have underspent on their budgets for the NSNP implementation. In order to be a more effective program and meet the nutritional needs of many vulnerable children, the NSNP should be expanded to also include breakfast. Evidence shows that breakfast has positive benefits for children’s academic performance and attention in school. Using the funds from the HPL to strengthen and expand this existing national intervention could be an effective way to address child hunger.

Providing nutritious meals to learners contributes to the children’s health in the long term. Effectively decreasing socio-economic impacts of poor childhood nutrition such as non communicable diseases. Thus, decreasing the burden on the state’s public health burden. Consequently, investing in childhood nutrition also provides financial benefit to the state in the long term.

4.2 Supporting nutrition in the critical first 1000 days (Maternity Support Grant)

Intervening in a child’s nutrition in the first 1000 days can have positive lifelong results. Stunting arises from chronic malnutrition in pregnancy and the early years of life and impairs the physical and cognitive development of young children. Stunting from macro and micronutrient deficiencies in pregnancy and the early years of life casts a long shadow on children’s health, education and employment prospects across their life course. Improving the wellbeing and nutritional status of pregnant women during this critical period when the growth of the developing foetus is wholly dependent on the nutritional status of the mother, would go a long way towards shifting the needle on stunting in South Africa. At present however, pregnancy poses significant health, social and economic challenges for women. Many women working in the informal sector (which is where the majority of poor women work) have to give up paid work during pregnancy, while incurring additional costs related to the increased volume and variety of food they need to consume to support pregnancy, travel costs for healthcare and costs of a new child. Local surveys find that as many as forty percent of pregnant women report going to bed hungry, 15% of babies are born with low birth weight and 40% of poor children do not access the child support grant in the first year of life. Extending the Child Support Grant into pregnancy, in the form of a Maternal Support Grant, would help ensure that poor and vulnerable pregnant women have access to much needed income support to enable attendance of antenatal check-ups, healthy nutrition and improved mental health. In addition, enabling uptake of income support during pregnancy would support seamless transition to the Child Support Grant once the baby is born and mitigate against the access barriers to the Child Support Grant many poor and vulnerable women face immediately after their baby is born.

The idea of a Maternal Support Grant is not a new one. Different types of pregnancy support are available in many other countries. Maternity and early childhood support is presently provided in over 30 countries. Such support has also been discussed for at least a decade in South Africa.

An investment case on the MSG estimates that extending the CSG into pregnancy will cost a maximum of R2, 227 million at current CSG levels. This constitutes only 1,2% of the total grant budget. Considering that economic models suggest that stunting places a penalty of 9% of GDP per capita on African and Asian, the return on investing in extending the CSG into pregnancy and reducing SA’s high stunting prevalence, would far outweigh the costs.

4.3 Improving nutrition in households: Basic Income Support

Globally, Social safety net programmes that provide sufficient levels of cash transfers over long periods can be effective in breaking the intergenerational cycle of poverty, improving the living standards of the poor, reducing food insecurity, and can improve undernutrition outcomes. These programs have the potential to reach millions of people that can spend the money given on nutritious food and have better access to health care including nutritional and health education. In turn, social support can help reduce the risk of childhood undernutrition, obesity, and non-communicable diseases (NCDs).

Poverty, inequality and unemployment are not mere challenges, they are the most profound crisis confronting democratic South Africa. These are all drivers for the double burden of malnutrition we see in children. Households struggle to afford nutritious food, leaving their children and members hungry. Social grants are vital in mitigating the effects of poverty for households and children.

The South African government needs to create a society of greater equality by strengthening the social protection system. One that will guarantee sufficient nutrition for all families and provide access to quality healthcare and education. Cash grants reduced hunger and malnutrition and improved food sufficiency. The evaluations of Basic Income Support a Case for South Africa showed that grant recipients were significantly more likely to have enough income for their daily food needs than those in the control group. The grants also led to more varied diets, with greater relative consumption of fruit and vegetables. The number of households that reported that their income was sufficient for their food needs increased from about 50% in the baseline to about 78% and a further 82%. Lastly, income grants were associated with an improvement in children’s weight-for-age, with the most considerable effect being among young girls.

During the pandemic – Although the R350 was not enough to make households and beneficiaries food secure, those who did not receive it, and those who received it late, experienced hunger and food insecurity more frequently (Black Sash Social protection in a time of COVID Lesson for Basic Income Support). The Department of Social Development has acknowledged that the COVID-19 SRD grant was primarily used to buy food.

The implementation of a Basic Income Support (BIS) in South Africa is feasible, affordable, would contribute to economic growth and job creation, and similar to social grants. The BIS would ensure many households in the country have improved food security, health and educational outcomes, resulting in long-term impact on poverty reduction.

The Black Sash and HEALA demand that the government implement a permanent Basic Income Support for those aged 18 to 59 years who have no or little income that meets the upper-bound poverty line (R1335 per month). Unemployed Caregivers who receive the CSG must also qualify. Although the extension of the COVID-19 Social Relief of Distress (SRD) grant is welcomed, it must be increased to at least the Food Poverty Line (R624) until social assistance for the unemployed is made permanent.

5. Way Forward

If we are to improve the health of all South Africans – we need to start with helping our children thrive into their best potential. As there are limited funds it is not a possibility to embrace new programmes however there are existing effective programmes that reach millions of hungry children everyday such as the NSNP and child support grant. In order to address the food and nutrition insecurity that our children experience we must prioritise; including breakfast in the NSNP more children will reach their daily nutritional needs, addressing the intergenerational transfer of malnutrition through the expansion of the child support grant into pregnancy & acknowledging that households that include vulnerable children and women need additional resources through basic income support.

6. Recommendations

By directly confronting excess sugar consumption, the Health Promotion Levy currently serves as one key preventative policy against rampant health conditions such as obesity, type 2 diabetes and other diet related NCDs. Its ability to create effective impact is already evident despite its constraints. Yet without strengthening the levy, along with introducing additional measures, South Africa is unlikely to resist its current trajectory towards increasingly catastrophic loss of life and crippling economic costs.

To do so, requires not only raising the levy and widening its scope, but finding ways to maximise the use of funds it raises to protect and enhance South Africans’ rights to health, nutritious food and a decent quality of life. To this end, we propose that:

  • Usage of HPL tax revenue as general revenue must be reprioritised via earmarking the entirety or majority thereof towards projects in line with the HPL’s vision.
  • Regulate and subsidise daily staple and healthy foods and reduce food prices.
  • Key projects to be considered for this should include:
    • Increasing support for NSNP
    • Supporting nutrition of children in the critical first 1000 days: Maternity Grant
    • Improving nutrition in households: Basic Income Support
7. About HEALA

HEALA is a coalition of civil society organisations that advocate for equitable access to affordable, nutritious food in South Africa by building a more just food system.

For further information contact:

HEALA: Nzama Mbalati
Email: Nzama@heala.org
Cell phone: 082 734 5414

Rural Health Advocacy Project: Nathan Taylor
Email: NTaylor@rhap.org
Cell phone: 082 406 1208

Grow Great: Dr Kopano Matlwa Mabaso
Email: kopano@growgreat.co.za
Cell phone: 071 861 5796

Black Sash: Hoodah Abrahams-Fayker
Email: hoodah@blacksash.org.za
Cell phone: 072 252 0333

Section27: Baone Twala
Email: twala@section27.org.za
Cell phone: 081 464 3033

South African Council of Churches: Reverend Parkson Mohlala
Email: lechipishaparksonm@gmail.com
Cell phone: 082 547 6434

SACSoWACH: Pumla Dlamini
Email: pdlamini@vitaminangels.org
Cell phone: 079 806 5406

TAC: Ngqabutho Mpofu
Email: ngqabutho.mpofu@tac.org.za
Cell phone: 061 807 6443

Equal Education: Nontsikelelo Dlulani
Email: ntsiki@equaleducation.org.za
Cell phone: 073 469 8750

Download the presentation

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Manyema M, Veerman LJ, Tugendhaft A, Labadarios D, Hofman KJ. Modelling the potential impact of a sugar sweetened beverage tax on stroke mortality, costs and health-adjusted life years in South Africa. BMC Public Health 2016;16(1):405

Question to the Minister of Finance Standing Committee – NW1300 | PMG

Budget Review 2021

Final Response Document on the 2017 Rates and Monetary Amounts and Amendment of Revenue Laws Bill – Health Promotion Levy

Kristie L. Watkins, Donald A. P. Bundy, Dean T. Jamison, Günther Fink, and Andreas Georgiadis “Evidence of Impact of Interventions on Health and Development during Middle Childhood and School Age”, pages 99 – 106

South African Child Gauge 2020: Food and nutrition security

NIDs CRAM Wave 5: Synthesis Report

National School Nutrition Programme – SECTION27

Hazell E. Report on the Implementation Evaluation of the National School Nutrition Programme. Pretoria: JET Education Services. 2016

National Treasury, (2015), Frameworks for conditional grants to provinces. Government Gazette, 38869, 12 June 2014: Part 2: 126-127
Bulman A. Realising Every Child’s Right to Nutrition: An analysis of the National School Nutrition Programme in the Eastern Cape. Grahamstown: Legal Resource Centre. 2017.

Hazell E. Report on the Implementation Evaluation of the National School Nutrition Programme. Pretoria: JET Education Services. 2016

Hazell E. Report on the Implementation Evaluation of the National School Nutrition Programme. Pretoria: JET Education Services. 2016

The effects of breakfast on behavior and academic performance in children and adolescents

Basic Income Support. 2020. Black Sash.

Key data from the February 2022 Household Affordability Index

The February 2022 Household Affordability Index, which tracks food price data from 44 supermarkets and 30 butcheries, in Johannesburg (Soweto, Alexandra, Tembisa and Hillbrow), Durban (KwaMashu, Umlazi, Isipingo, Durban CBD and Mtubatuba), Cape Town (Khayelitsha, Gugulethu, Philippi, Langa, Delft and Dunoon), Pietermaritzburg and Springbok (in the Northern Cape), shows that:

  • In February 2022: The average cost of the Household Food Basket is R4 355,70.
  • Month-on-month: The average cost of the Household Food Basket decreased by R45,33 (-1%), from R4 401,02 in January 2022 to R4 355,70 in February 2022.
  • Year-on-year: The average cost of the Household Food Basket increased by R354,52 (8.9%), from R4 001,17 in February 2021 to R4 355,70 in February 2022.

Food prices dropped marginally in all areas tracked. Most foods in the basket came down in February 2022 – and across most staples, meats, and vegetables, with the exception of oils and fats: cooking oil, margarine and cremora.

Statistics South Africa’s latest Consumer Price Index for January 2022 shows that Headline inflation was 5,7%, and for the lowest expenditure quintiles 1-3, it is 6,7%, 6,1% and 5,6% respectively. CPI Food inflation was 6,2%.


The National Minimum Wage for a General Worker in February 2022 is R3 470,40. Transport to work and back will cost a worker an average of R1 280 (36,9% of NMW), and electricity an average of R731,50 (21,1% of NMW). Together transport and electricity, both non-negotiable expenses, take up 58% (R2 011,50) of the NMW, leaving R1 458,90 to secure all other household expenses. Workers families will underspend on food by a minimum of 51,8%, this month, based on PMBEJDs basic nutritional food basket which stands at R3 029,23 for a family of four persons.

Productivity in the workplace and learning quality in classrooms, and whether we have to visit a health centre or not, are all dependent on the food we eat.

Women and children

In February 2022, the average cost to feed a child a basic nutritious diet was R771,95. Year-on-year, the cost to feed a child a basic nutritious diet has increased by R61,20 or 8,6%.

In February 2022, the Child Support Grant of R460 is 26% below the Food Poverty Line of R624, and 40% below the average cost to feed a child a basic nutritious diet of R771,95.

In its annual adjustments, Government chose to increase the Child Support Grant by R20 from April 2022. This is an increase of 4,3%.

The R20 increase will move the Child Support Grant of R480 from 26% below the Food Poverty Line of R624, to 23% below the Food Poverty Line.

by  the PMBJED group

Vacancy: Communications manager

Are you an exceptional communicator with at least five years’ experience in journalism or communications? Are you committed to social justice and health equality?

We are looking for a communications manager to implementation of HEALA’s communication strategy and to develop, implement, monitor and evaluate communications to support HEALA’s primary policy advocacy campaigns.

This person must have the ability to think strategically, handle ambiguity, and problem solve in a fast-paced, limited-structure, multicultural environment.

HEALA is a coalition of civil society organisations advocating for equitable access to affordable, nutritious food in South Africa by building a more just food system.
HEALA’s mission is to create a platform for communities to organise and mobilise around policy and the realisation of the right to affordable, nutritious food.
Find out more on our website.

Role specifics

  • Fixed term position – 1 year contract.
  • Location – Rural Health Advocacy Project – Rosebank Johannesburg.
  • Closing date 25 April 2022.

What we’re looking for

This work is all about conveying information to various audiences, including a range of cultures and international partners, donors and NGOs. The skills we’re looking for include:

  • Fluent written and spoken English as well as one other South Africa language.
  • Sound knowledge of the South African media sector, including news production cycles and outlets.
  • Basic knowledge of social media and website metrics, including Twitter and Facebook.
  • Experience with web content management systems and newsletter delivery systems such as Mailchimp is a plus.
  • Proven ability to translate health and/or scientific research jargon into easy-to-understand language; experience in helping researchers and experts do the same is an added advantage.
  • Excellent oral and written communications skills, including the ability to communicate about complex issues in sensitive and compelling ways.
  • Willingness to travel nationally or internationally as required.

What the role looks like

Key performance areas include:

  • Designing, writing and editing advocacy communications materials for the HEALA coalition and specific policy advocacy campaigns
  • Managing the content and co-ordination the reporting for all of HEALA’s digital platforms including the WordPress website, MailChimp and social media channels (Facebook, Twitter and LinkedIn)
  • Facilitating effective communication within the HEALA coalition and with external stakeholders
  • Building and maintain relationships with the media
  • Overseeing event management
  • Effective self-management and performance ownership

Find out more

You can find further information at the full job spec.

How to apply

Accepted applications will comprise of two parts:

  1. Your CV detailing all relevant experience and education
  2. A cover letter answering these three questions:
    • Please describe a piece of communications work that you are proud of and provide links where possible. What was your role in creating this work?
    • What are three important values you would embody as the communications manager for HEALA, and can you give examples of how you embody them already?
    • What are two concrete learnings from your experience working in communications sector that you would bring to HEALA?

Please email your CV and cover letter to nboomgaard@witshealth.co.za with the subject line: RHAP-Comms Manager before 15 March 2022.