Schools are recognised as key arenas for health promotion (HP). The development of health literacy (HL) is one of the cornerstones of HP. HP is closely linked to democratic principles and social values. School-based HP may best be understood within the context of the socio-political spectrum in which it is embedded. This study explores how school-based HP is articulated in Swedish education policies, particularly in relation to democratic and social values, and whether that articulation acknowledges and fosters HL as a core element of HP work. Four education policies were analysed. The analysis was informed by Fairclough's model of critical discourse analysis. The findings indicate that policy articulations exhibit an awareness of the democratic and social dimensions of HP. However, these dimensions may have been undermined by an occasional biomedical hegemony, coupled with a subtle deployment of governance discourse. The policies acknowledged HL in spirit rather than semantics and did not fully exploit teachers' capacities as active agents in HP. Several interdiscursive tensions were observed that may have short as well as long-term social and democratic implications, particularly in terms of fostering student autonomy, empowerment and inclusion.