Most recently, the World Health Organization published all submissions to their web-based consultation late last year about the development of a global alcohol action plan.
Shehara analyzed 16 submissions of major alcohol industry front groups from around the world. This rapid analysis brought to light a number of surprising and a few shocking elements.
There are clear commonalities and even through-lines across the Big Alcohol submissions. Identifying those is revealing of Big Alcohol’s sincerity and commitment to accelerate action on alcohol harm as public health priority.
In this joint blog post, Maik with input from Shehara examines the major claims the alcohol industry makes to undermine the development of the global alcohol action plan. Shehara and Maik identify the contradictions, shortcomings and the PR-spin the alcohol industry applies even to a technical consultation on a specific issue.

This analysis is written by Maik Dünnbier with critical input from Shehara Cooray who analyzed the alcohol industry submissions.

In November and December 2020 the World Health Organization conducted a web-based consultation on a to begin developing a global action plan to better implement the WHO Global Alcohol Strategy. When the submissions were released recently, we began the counting and analyzing: In total 253 submissions were made, including more than 70 Big Alcohol submissions. Alcohol industry submissions come from producers, retailers, marketers of alcohol as well as lobby front groups and think tanks.

We’ve already released a rapid analysis of think tank submissions. As it turns out, they are all connected to a strategic ally of Big Tobacco and are interfering in the WHO process on behalf of the alcohol and tobacco industries.

This is the second part of our analysis. Here we focus on examining the submissions of Big Alcohol front groups (and one producer):

  • Alcohol Beverages Australia,
  • Beer Canada,
  • British Beer and Pub Association,
  • Bundesverband der Deutschen Spirituosen-Industrie und -Importeure e. V.,
  • CEEV, Comité Européen des Entreprises Vins,
  • Distilled Spirits Council of the U.S.,
  • Drinkaware,
  • Drinks Ireland,
  • Educ’alcool,
  • International Alliance for Responsible Drinking,
  • Pernod Ricard,
  • spiritsEurope,
  • The Brewers of Europe,
  • The Scotch Whisky Association,
  • World Spirits Alliance, and
  • Worldwide Brewing Alliance.

Big Alcohol strategies in submissions to WHO alcohol policy consultation 

The front groups we analyzed are operating (primarily) in Australia (1), Canada (2), the United Kingdom (3), Germany (1), the European Union (3), the United States (1), Ireland (1), and globally (4). They represent the beer, wine and liquor sectors. And they are funded by and directly representing major alcohol producers. We also included Pernod Ricard as the only alcohol production giant that submitted a response to the consultation.

In total, we identified 12 common strategies but for this article we focus on the four most prevalent ones. You can read the entire analysis here (PDF) and find the overview below.

The strategies we’ve identified are: use of specific language to reframe the key problem; demand to work in partnership with WHO; exclude WHO from World Trade Organization deliberations; and attack SAFER and specific alcohol policy best buys.

Strategy #1: Use of specific language to reframe the key problem

Big Alcohol systematically uses the terms “harmful use of alcohol”, “abuse”, “misuse”, “excessive use” across the 16 submissions we analyzed. Their submissions are aggressive attempts to reframe what alcohol harm is, who is responsible for the alcohol burden and which solutions work best to solve the identified problems.

Remarkably, the alcohol industry rejects and undermines the foundational element of the WHO Global Alcohol Strategy – the definition of what “harmful use of alcohol” means.

WHO definition “harmful use of alcohol”

On page five in paragraph one of the WHO Global Alcohol Strategy the term is defined:

Example: Bundesverband der Deutschen Spiritiosen- Industrie und – Importeure e. V. (BSI)

“Responsible drinking is not the problem, but abuse of alcohol is, so policies should orient towards causes of alcohol abuse.”

“The harmful use of alcohol has a serious effect on public health and is considered to be one of the main risk factors for poor health globally. In the context of this draft strategy, the concept of the harmful use of alcohol is broad and encompasses the drinking that causes detrimental health and social consequences for the drinker, the people around the drinker and society at large, as well as the patterns of drinking that are associated with increased risk of adverse health outcomes. The harmful use of alcohol compromises both individual and social development. It can ruin the lives of individuals, devastate families, and damage the fabric of communities.”

Flaws of the WHO term

The concept of “harmful use of alcohol” enshrined in the WHO Global Alcohol Strategy is not a purely evidence-based term but a political compromise to ensure the adoption of the strategy itself. It obviously comes with a host of problems the alcohol industry tries to exploit:

  1. The term does not immediately convey that there is no safe or healthy alcohol use; only the definition does;
  2. The term does not illustrate that the main cause of the global alcohol burden is the products and practices of the alcohol industry but instead intuitively seems to focus on the user who consumes alcohol in a harmful way;
  3. The term – if its definition is removed – focusses on individual responsibility to not use alcohol in “harmful ways”;
  4. On first glance the term communicates that there is harmful and “normal” use of alcohol; and
  5. The term “harmful use of alcohol” was a lobby victory of Big Alcohol in the adoption of the WHO Global Alcohol Strategy.

The term is thus a key strategy in itself to promote ambiguity about alcohol harm and related solutions.

Purpose of undermining and reframing a key WHO concept

In their consultation submissions, Big Alcohol is attempting to blur its meaning, reframe the concept and thus promote strategic ambiguity and cognitive dissonance.

The purpose of reframing the meaning of “harmful use of alcohol” is to exploit this strategic ambiguity and disguise the full extent and real cause of alcohol harm.

With the attempt to reframe what the key problem is that the WHO Global Alcohol Strategy addresses, the alcohol industry is casting doubt on the importance of population level alcohol consumption to understand and address the extent and magnitude of alcohol harm in a given society. Big Alcohol attempts to delay and derail comprehensive understanding of alcohol harm (health, social, economic, development) and in doing so to call into question the effectiveness of the alcohol policy best buys that are also key elements of the strategy.

The alcohol industry is undermining the recognition of total alcohol consumption as the most important indicator for population-level alcohol harm and whether countries are on track to reduce per capita alcohol use by at least 10% by 2030. This is serious.

This strategy places Big Alcohol at odds with unimpeachable scientific evidence, with the UN Statistical Commission and with the core objective of the WHO Global Alcohol Strategy.

The reframing and blurring of the meaning of “harmful use of alcohol” also serves to shift the blame for alcohol harm to consumer behaviour and thus to a focus of alcohol policy on “safer drinking patterns” – in contrast to the focus on the products and practices of the alcohol industry as cause of harm. The objective is to distract from scientifically proven, cost-effective, high-impact alcohol policy solutions which aim to regulate the alcohol industry and Big Alcohol’s profits.

In a sweeping rebuke of this Big Alcohol strategy, Rehm, Crépault, Wettlaufer, Manthey, and Shield found in their study of the usefulness of “alcohol per capita consumption”:

  1. Alcohol per capita consumption (APC) is greatly associated with harm and is available for almost all countries on a yearly basis as it is largely derived from routinely collected statistics.
  2. In a regression analysis of 182 countries, APC was better at predicting alcohol‐attributable harm than heavy episodic alcohol use. APC was also correlated with changes in the alcohol‐attributable burden of disease (from 2010 to 2016), while heavy episodic alcohol use was not.

Strategy #2: Demand to work in partnership with WHO

Big Alcohol demanded in almost all of their consultation submissions to be part of the policy formulation process concerning the global alcohol action plan as “full partners”.

This might appear to be their “normal” talking point to be partners and that all stakeholders should work together. But in our analysis, this second strategy to demand partnership with WHO has a new quality.

Big Alcohol is making three main claims to push for “partnership”:

  1. The 2018 UN Political Declaration on Non-Communicable Diseases requires partnership,
  2. The Sustainable Development Goal 17 requires partnership with Big Alcohol for development, and
  3. The denial of an inherent, fundamental conflict of interest between alcohol industry interests versus the well-being of people, communities and society at large.

Example: Brewers of Europe

“There is no inherent conflict of interest between the brewers’ interests and those of public health, and no justification to de facto exclude brewers from all public policy discussions.”

Example: Beer Canada

Using the term “industry interference” in the working document of the consultation would marginalize the industry and would also contradict the 2018 UN Political Declaration.

Big Alcohol is offended by the use of the term “alcohol industry interference” in the working document. This term amounted to marginalization and exclusion of the alcohol industry, according to the submissions of numerous front groups.
The alcohol industry also feels they are being framed as part of the problem and barrier to real progress. But of course, they would love to be viewed as part of the solution.
The alcohol industry rejects the fact that there is a fundamental, direct conflict of interest.
The alcohol industry is also not satisfied with the role the working document assigns them in specific areas, limited to their role as economic operators.

World map of Big Alcohol interference

Alcohol harm has been discussed as a global public health priority at the WHO governing bodies and the UN General Assembly in the last three years. And government representatives have on numerous occasions expressed concern about and frustration over alcohol industry interference against the implementation of the WHO Global Alcohol Strategy. In addition, alcohol industry interference to delay, derail and destroy alcohol policy development has been well documented and studied around the world.

@Movendi International, 2021, World Map of Alcohol Industry Interference

 1.Alaska, USA: Lobbying against local alcohol tax
2. Yukon, Canada: Political pressure to upend cancer warning label study
3. United States: Lobbying campaign against road safety improvements
4. Mexico: Lobbying to lower alcohol taxation
5. Brazil: Derailing of alcohol marketing regulation
Vietnam: Lobbying to derail country’s first ever comprehensive alcohol law
6. Argentina: Opposition to DUI counter-measures
7. Peru: Lobbying to derail warning labels
8. Sweden & Iceland: Lobbying to upend successful alcohol policy models (government retail monopolies)
9. Norway: Lobbying against local opening hour limits
10. Germany: Destroying alcohol law modernisation
11. Lithuania: Fierce attacks against life-saving alcohol laws
12. Scotland: Opposition to minimum unit pricing

13. Africa: Derailing of evidence-based alcohol laws
14. Hong Kong: Lobbying to abolish wine tax
15. India, South Korea, Thailand, Kenya: Bribery, corruption as business practices
16. Australia & New Zealand: Opposition to health warning labelling to protect unborn children
17. Sub-saharan Africa: widespread tax avoidance
18. Kenya: Alcohol industry interferes in election campaign for MP Mututho who sponsored comprehensive alcohol act to lose his seat
Uganda: Alcohol industry fails to comply with alcohol sachets
19. Lesotho, Malawi, Uganda and Botswana: draft national alcohol industry as tailor-made respectively, but failing to include WHO-recommneded alcohol policy measures to tackle population-level harm
20. Rwanda and Myanmar: Collaboration with military/ rebel forces while they committed genocide
21. South-East Asia, Africa: Use of beer promotion girls (“beer girls”) to sell beer in exploitative settings and conditions

Our growing world map of Big Alcohol interference shows a snapshot of how aggressive alcohol industry giants interfere around the world – even on local levels – to delay, derail and destroy alcohol policy development. The map also illustrates other unethical strategies of political interference against the formulation and implementation of WHO-recommended alcohol policy best buy solutions.

I think it is revealing that Big Alcohol plays the victim considering the reality of one person dying every ten seconds due to their own products and practices, while the same industry obstructs any meaningful action to save lives.

Big Alcohol’s fundamental conflict of interest

Relentless political interference is closely linked to Big Alcohol’s fundamental conflict of interest.

Increased alcohol consumption leads to increased negative health and development outcomes, but also to increased sales for the alcohol industry, placing public health and development interests in an inherent and direct conflict with corporate profit interests. Expressed in a different way: alcohol harm is an industrial epidemic – a fact the coronavirus crisis has brought into sharp focus even more.

The conflict of interest is fundamental. For example, a key element of alcohol harm prevention is to protect children and youth from exposure to alcohol marketing and from early alcohol initiation. But under-age alcohol users make up a substantial part of Big Alcohol’s profits in the United States. That’s why there is still so much alcohol advertising exposing children and youth.

The alcohol industry is one of the most profitable industries in the world. Revenues of the nine largest companies by volume totaled $141.2 billion. If these companies together were a country, they would be larger than the gross domestic product of all but 54 of the world’s nations, according to David Jernigan and colleagues.

  • The alcohol industry was the eighth most profitable sector of 94 global industries – less profitable than tobacco (number 3) but much more more profitable than sugar-sweetened beverages (number 40).
  • Net earnings before income taxes in 2018 at AB InBev, the world’s largest alcohol company by volume, were $17.8 billion, or 31% of total revenues – slightly less than tobacco giant Altria, at 37% but more than Coca-Cola at 26%.
$1.5 Trillion
Total Alcohol Sales in 2017
Alcohol sales totaled more than $1.5 trillion in 2017. Control of alcohol production and marketing is extremely concentrated globally. This oligopoly structure helps generate high profits per dollar invested relative to other industries.

Profit maximization through selling and promoting addictive, psychoactive substances is Big Alcohol’s core objective. And the numbers tell that story: major profits come from “heavy” alcohol users – the very same customers the alcohol industry is falsely blaming for alcohol harm. But if all alcohol users in the UK for instance reduced their consumption to the recommended low-risk limit, Big Alcohol profits would tumble: they would lose £13 billion annually, 38% of their sales revenues.

Middle-income countries: Big Alcohol relies on heavy users for their profits

Analysis of data from five different countries shows the alcohol industry’s reliance on the heavy use of alcohol.

  • In higher income countries heavier alcohol consumption occasions make up approximately 50% of sales.
  • 76% of sales in middle-income countries are resulting from heavy alcohol use.

England: Alcohol industry dependent on heavy alcohol use

Those using alcohol above guideline levels are estimated to account for 68% of total alcohol sales revenue in 2013/14.

  • The heaviest alcohol using 4% of the population account for 30% of all consumption and 23% of all industry revenue.
  • If all consumers reduced their alcohol use to within guideline levels, alcohol sales revenue could decline by 38% (£13 billion).

USA: Big Alcohol addiction to minors and heavy alcohol consumers

Already in 2003, a comprehensive study showed that underage alcohol users and adult heavy alcohol users in the United States were responsible for 50.1% of alcohol consumption and 48.9% of consumer expenditure.

Interference and corporate capture of alcohol policy formulation processes is a fact. The fundamental conflict of interest is a reality.

Nevertheless, alcohol industry front groups are relentlessly pushing their demand to partner with WHO and to participate in the discussions about alcohol policy development.

What the WHO Global Alcohol Strategy actually says about Big Alcohol’s role

In addition to the attempt to undermine the meaning of “harmful use of alcohol”, the alcohol industry is attempting to reframe another key element of the WHO Global Alcohol Strategy: their role – and what their role is not – with regard to the Strategy.

Economic operators in alcohol production and trade are important players in their role as developers, producers, distributors, marketers and sellers of alcoholic beverages. They are especially encouraged to consider effective ways to prevent and reduce harmful use of alcohol within their core roles mentioned above, including self-regulatory actions and initiatives. They could also contribute by making available data on sales and consumption of alcohol beverages.”

WHO Global Alcohol Strategy, 2010, p. 20, §45d

The WHO Global Alcohol Strategy is specifying which role the alcohol industry should play. And their role is limited to their core areas as developers, producers, distributors, marketers and retailers of alcohol products.

In addition to the concept of “harmful use of alcohol” this paragraph of giving the alcohol industry any role in tackling alcohol harm is the second big flaw of the Global Alcohol Strategy. The alcohol industry, exactly like the tobacco industry, should be kept at bay from any engagement with WHO and from any role whatsoever in implementing the WHO Global Alcohol Strategy.

But the alcohol industry has not even lived up to delivering on this limited role. Big Alcohol has not only interfered against alcohol policy development but is also systematically violating their own self-regulation promises.

Landmark UN decision and the role of Big Alcohol

The alcohol industry is abusing the alcohol policy formulation process at the WHO to push for more “partnership”. We have debunked their claims that Big Alcohol had no conflict of interest. We’ve also busted their rejection of the concept of alcohol industry interference. And we want to expose the truth about their third claim: that the SDGs and the recent NCDs declaration compel WHO and governments to partnerships with the alcohol industry.

In 2015 the 2030 Agenda was adopted and SDG 17 is seeking to “Strengthen the means of implementation and revitalize the global partnership for sustainable development”. But importantly the 2030 Agenda is universal. And its 17 Sustainable Development Goals and 169 targets are integrated and indivisible and balance the three dimensions of sustainable development: the economic, social and environmental.

Therefore, policy coherence is an essential part of the work to achieve the SDGs. That means that conflict of interest considerations matter in the context of implementing the 2030 Agenda.

The alcohol industry actually has a massive conflict of interest not just with regards to health goals but concerning 14 of the 17 SDGs, including poverty eradication, reaching gender equality, water and food security, safe and healthy cities, sustainable consumption, biodiversity and violence eradication.

Even SDG 17 itself is being undermined by Big Alcohol: alcohol taxation is an important tool to finance development but the alcohol industry is opposing this solution. Alcohol taxation would cut into Big Alcohol profits, but it would raise much needed domestic revenue, reduce alcohol consumption and harm and it would help promote health and development for all.

The alcohol industry is a serious vector of poverty, disease, and social, environmental and economic harm. The products and practices of Big Alcohol are eroding human capital, hurting economic development, and threatening environmental development. They fuel deprivation, inequality, exploitation: massive social harm.

The Political declaration of the 3rd High-Level Meeting of the General Assembly on the Prevention and Control of Non-Communicable Diseases was adopted by the UN General Assembly in the fall of 2018.

The significant part of the declaration is that governments commit themselves to scale up the implementation of the previous commitments to reduce tobacco and alcohol use, as well as unhealthy diets and physical inactivity, based on WHO-recommended interventions – the so-called best buys.

The way to step up efforts for NCDs prevention and control is to “Promote and implement policy, legislative and regulatory measures, including fiscal measures [to reduce] the impact of the main risk factors for NCDs,” as it says in paragraph 21.

In paragraph 44 the declaration invites “the private sector to strengthen its commitment and contribution to the implementation of national responses to prevent, control and treat non-communicable diseases to reach health and development objectives…”

For the alcohol industry, there are two a specific sub-paragraphs 44b and 44c. Firstly, it reaffirms the basic premise of the WHO Global Alcohol Strategy that the alcohol industry only can play a role in their specific core areas – and only if appropriate – to contribute to reducing alcohol harm, taking into account national, religious and cultural contexts. Secondly, the declaration challenges Big Alcohol to eliminate the marketing, advertising and sale of alcoholic products to minor.

It is very clear that neither the SDGs nor the 2018 NCDs declaration envision any other type of collaboration with, or engagement of the alcohol industry than did the WHO Global Alcohol Strategy.

The alcohol industry is not living up to the challenges of the 2030 Agenda or of the 2018 NCDs declaration:

  1. In 2019, The Lancet published a landmark Global Burden of Disease study that projected rising alcohol consumption over the next decade, indicating that the goals (included in the SDGs and NCDs agendas) for preventing and reducing alcohol harm will remain out of reach.
  2. In 2020, the latest Global Burden of Disease study illustrated a decades-long alcohol policy failure as exposure to several highly preventable health risks, including alcohol use, keeps increasing.
  3. Evidence shows that children are increasingly exposed to alcohol marketing – even during the pandemic.
  4. Very recently analysis of the political process leading to the 2018 NCDs declaration showed:

Many cost-effective policy options to address NCDs, such as taxation of health-harming products, were opposed by high-income countries and the private sector and not well-represented in the Declaration. To ensure robust political commitments and action on NCDs, multi-stakeholder governance for NCDs must consider imbalances in power and influence amongst constituents as well as biases and conflicts in positioning.”

Mao Suzuki, Douglas Webb and Roy Small, 2021, in: International Journal of Health Policy and Management

A partnership with Big Alcohol would only be a dysfunctional relationship, geared towards private profits interest instead of community well-being and societal development.

Strategy #3: Exclude the World Health Organization from World Trade Organization deliberations

For all the talk about partnership and the alcohol industry’s request to be included in public health policy making, the strategy to use this specific consultation process to lobby against the WHO being involved in WTO deliberations is surprising and revealing.

Both Australian and European alcohol industry front groups pushed in their respective consultations that international trade of alcohol was the responsibility of member states and the World Trade Organization, claiming that the future action plan should not make proposals on that issue.

I think the alcohol industry is afraid of any international action to regulate their products and practices in a more evidence-based way – labelling, alcohol marketing (especially its cross-border dimension), alcohol taxation, and the global binding treaty are all examples that communities and member states are discussing as solutions to the current alcohol problem.

Example: CEEV

“International trade is at WTO competence level; the action plan should not make any proposals to expand the role for WHO related to world trade”

This is of course about the WHO assisting member states at the WTO to navigate international labelling standards to better warn consumers “about the content of the products and the health risks associated with their consumption”. 

Actually, this is not outside WHO competence. The World Health Organization has observer status at the WTO’s Technical Barriers to Trade Committee. And WHO engagement in other areas of policy making outside of public health, such as trade, should be encouraged – especially in this era of cross-sectorial work to achieve the SDGs.

Leading scientists have argued this case:

WHO has a responsibility to refute false claims, especially those that challenge the adequacy of evidence supporting particular policies, such as alcohol beverage labelling regulations, marketing and labelling requirements for energy drinks and regulations for front-of-pack nutrition labelling for food products.”

Pepita Barlow, Ronald Labonte, Martin McKeec & David Stuckler, 2019, in: WHO Bulletin

The number of trade challenges filed by WTO member states against another country’s tobacco, alcohol or nutrition policy has increased in the last 20 years. Notably, while WHO was present when tobacco trade conflicted with public health objectives, WHO was absent from WTO discussions concerning nutrition (including alcohol) policy.

Scientific analysis showed that between 1995 and 2016 there were 82 challenges to regulations affecting food and beverage products at the Technical Barriers to Trade Committee. Some public health measures that were challenged were best buys from WHO’s list of cost–effective interventions for preventing NCDs. The researchers did not find any evidence of WHO participation in nutrition-related trade challenges, such as those related to unhealthy food high in salt, fat and sugar, alcohol, sugar-sweetened beverages and infant milk formulae.

This absence of WHO, the global normative leader in health policy, leaves the WTO as Big Alcohol’s playing field to attack public health measures.

Strategy #4: Attack SAFER and specific alcohol policy best buys

It is not new that the alcohol industry is opposing and obstructing high-impact alcohol policy solutions. It’s therefore no surprise that these talking points are recycled for the WHO consultation about a new global alcohol action plan. Now Big Alcohol’s attacks are aimed at SAFER – a new initiative and technical package outlining an alcohol policy blue print to help governments with their efforts to prevent and reduce alcohol harm.

  • Strengthening restrictions on alcohol availability;
  • Advancing and enforcing driving under the influence counter measures;
  • Facilitating access to screening, brief interventions and treatment;
  • Enforcing bans on alcohol advertising, sponsorship and promotion; and
  • Raising prices on alcohol through excise taxes and pricing policies.

Alcohol Beverages Australia, Beer Canada, CEEV, DISCUS, Educ’alcool, IARD, spiritsEurope, and the World Spirits Alliance are all attacking SAFER, and they are all using the same talking points to do so. We see a concerted effort to undermine an implementation tool developed to support member states in achieving the SDGs and NCDs targets, including 10% per capita alcohol consumption reduction.

Example: spiritsEurope

“Policy approaches which aim to best inform and educate the consumer about this choice – how to drink responsibly, the importance of moderation, the strong discouragement of risky behaviour – may prove ultimately to be a more effective and sustainable strategy than SAFER for certain regions.”

WHO’s position is that any alcohol use is associated with some amount of risk – such as the risk of alcohol dependence, breast cancer or injury. Although the risk at the level of the individual may be low, from a public health perspective and at the population level there are no levels of consumption at which no risks are involved.

The technical package for the SAFER initiative focuses on five key alcohol policy interventions that are based on accumulated evidence of their impact on population health and their cost-effectiveness.

An alcohol policy best buy is an intervention that is not only highly cost-effective but also cheap, feasible and culturally acceptable to implement. A highly cost-effective intervention is one that, on average, provides an extra year of healthy life (equivalent to averting one DALY) for less than the average annual income per person. 

Cost-effective measures for reducing … alcohol use include increasing alcoholic beverage taxes, regulating the availability of alcoholic beverages, restricting marketing of alcoholic beverages and drink-driving countermeasures.” (WHO)

Big Alcohol attack on SAFER

“SAFER was produced without member state involvement/endorsement”

“SAFER  invalidates the global alcohol strategy’s flexible menu of policy options appropriate to national, cultural, regulatory and local contexts; should not promote “one-size fits all“ policy approach”

“SAFER is lacking evidence or scientific data to support its effectiveness; in several countries there is lack of evidence for effectiveness of SAFER best buys”

The facts about SAFER

SAFER packages the 10 action areas of the WHO Global Alcohol Strategy and consists of the three best buys of the NCDs Global Action Plan, meaning all SAFER measures are actually endorsed by member states.

The definition of cost-effectiveness and the specific, country-focused approach of the SAFER initiative ensure that local adaptation of the menu of policy options is at the core of the support provided to countries.

SAFER is a blue print, not a one-sizefits all, meaning that it depends on local contexts and data analysis which mix of alcohol policy solutions will work and which calibration the specific measures will have.

The alcohol policy best buys are in fact best buys because they are scientifically proven to be cost-effective, high-impact, and tested in different countries around the world.

Conclusion: What I think this all means

Alcohol availability, marketing and affordability create alcohol-centric environments that are strongly associated with adverse health and development outcomes. These alcogenic environments are crucial for shaping patterns and volume of alcohol consumption. Therefore, Big Alcohol exerts massive power and influence over the alcohol consumption environment and norm. The products and practices of the alcohol industry shape and foment health harmful values, norms and behaviors. The products and practices of the alcohol industry – not isolated individual choices – fuel death, disease and destruction.

In addition, this analysis has revealed an unprecedented campaign of alcohol industry interference in alcohol policy formulation – a concerted effort to push a set of identical talking points, to reject and cast doubt over essential scientific consensus on alcohol harms and solutions and to undermine the foundational elements of the WHO Global Alcohol Strategy.

All this, the alcohol industry does in close collaboration with the tobacco industry. As a matter of fact, Big Alcohol is copying Big Tobacco’s playbook.

This mobilization of Big Tobacco’s network and strategies to undermine alcohol policy development at the WHO calls into question even more why the alcohol industry is allowed to participate in the first place.

Our examination of the submissions of 16 of the biggest front groups also reveals how irresponsible and flawed Big Alcohol’s approach to science is. The alcohol industry is manipulating science, misrepresenting science, using its own, purchased scientific results and they also simply ignore science and evidence to make outrageous claims:

“Growing evidence shows that regulatory environments should be designed to favour products with lower alcohol concentration,“ claimed Beer Canada. But they did not offer any evidence or any source for that type of data.

The Worldwide Brewing Alliance claimed: “Insights from the evidence do not imply that consuming higher ABV drinks is always dangerous to health…” Again, sources and references are missing to examine the “evidence” of the brewers’ front group.

In March 2020, Gemma Mitchell, Matthew Lesch, and Jim McCambridge published an analysis of the scandal where the U.S. National Institutes of Health had to stop the worldwide “Moderate Alcohol and Cardiovascular Health (MACH)” trial in 2018 because of institutional failings that led to the biased design of this major study. This case illustrates that the alcohol industry seeks to buy scientific results favorable to their profits.

Alcohol companies agreed to fund the MACH trial to advance their commercial interests rather than to help answer a major scientific question. Alcohol industry executives seized opportunities presented by discussions of the MACH trial to try to influence this study and wider public health, research, and policy decision-making.
The process of soliciting research funding from corporations, which included convincing alcohol companies that the study design supported their commercial interests, was intrinsically biased. Thus, the three parties – research funding officials, researchers, and industry executives – coproduced the biased trial design.”

Gemma Mitchell, Matthew Lesch, and Jim McCambridge, 2020: Alcohol Industry Involvement in the Moderate Alcohol and Cardiovascular Health Trial American Journal of Public Health 110, 485_488,

Understanding this case highlights the importance and urgency of better protecting public health research from biases associated with corporate donations. Who would be better suited than the World Health Organization to champion this cause?

And who else would be better placed than the WHO to help and support governments protect their alcohol policy development processes from alcohol industry interference?

In April 2019, an internal note to WHO staff was leaked, relaying the message that partnering, collaborating, taking funding, and even talking with the alcohol industry on some subjects was not acceptable. However, the internal guidance did not preclude other types of restricted interactions, as is the case with Big Tobacco. WHO stopped short of recommending that other organisations and governments should follow its policy. According to the guidance: Interaction between the WHO secretariat and the alcohol industry should be limited to a dialogue and exchange of information for achieving positive outcomes for public health. Interactions should not lead to or imply ‘partnership,’ ‘collaboration,’ or any other similar type of engagement that could give the impression of a formal joint relationship. It was critical to preempt jeopardizing the integrity, credibility, and independence of WHO’s work.

The internal guidance gives a sense of the Big Alcohol pressure that all levels of WHO are subjected to.

I think it is clear that the WHO dialogues with the alcohol industry need to be reevaluated. They are causing damage to WHO’s integrity and credibility – especially if dialogue is about self-regulation.

I also think that the global action plan should better reflect what we know about alcohol industry lobbying, interference, undermining of science and other unethical business practices – even more so because of the tight link to the tobacco industry.

The four alcohol industry strategies we examine in this blog post and the one we exposed in my previous article are exact replications of Big Tobacco strategies.

Big Alcohol strategies to interfere in WHO alcohol action plan development

  1. Think tanks and front groups in concerted action to interfere in the development of the WHO global alcohol action plan.
  2. Use of specific language to reframe the key problem;
  3. Demand to work in partnership with WHO, rejecting any conflict of interest and decrying the label “industry interference”;
  4. Exclude WHO from World Trade Organization deliberations; and
  5. Attack SAFER and specific alcohol policy best buys.

Big Tobacco strategies to undermine public health policies

These five strategies are a selection of the analysis provided by STOP – the tobacco industry watchdog. “Crooked Nine: Nine Ways the Tobacco Industry Undermines Health Policy” and “Targeting the European Commission: The 7 Lobbying Techniques of Big Tobacco”.

  1. Building alliances and front groups: Tobacco companies mislead the public by orchestrating support from diverse groups. For example in 2017, Philip Morris International established the front group “Foundation for a Smoke-Free World” – a very similar vehicle to the “International Alliance for Responsible Drinking”.
  2. Promoting untruths and disputing public health facts: Commissioning their own studies and publicizing (often non-peer-reviewed) research that casts doubt on the scientific consensus around tobacco.
  3. Playing the victim: Portraying themselves as the victims of misrepresentations of their motives and excessive regulation.
  4. Playing the WHO off against member states: Arguing that public health legislation in a particular member state could distort free trade rules, or that international trade of alcohol is WTO and member states responsibility and that international alcohol labelling rules would destroy free trade.
  5. Postponing regulations: Delaying or discouraging the introduction of new tobacco control legislation and the revision of existing legislation

These reflections call into question the role ascribed to Big Alcohol in the WHO Global Alcohol Strategy. It should be reassessed and updated in the strategy. It is certainly important to better protect the ongoing process of developing a global alcohol action plan from alcohol and tobacco industry interference. One thing is clear: the current level of protection against undue alcohol industry influence is not enough to safeguard alcohol policy development and in the face of the lobbying onslaught better tools and approaches are necessary – such as a global binding treaty on alcohol.

For further reading

“The Alcohol Marketing Landscape: Alcohol Industry Size, Structure, Strategies, and Public Health Responses”

Targeting the European Commission: The 7 Lobbying Techniques of Big Tobacco

Big Tobacco has been influencing policy to its advantage for decades—postponing, protesting, promoting untruths, playing the victim and pushing new technologies—in order to disrupt tobacco control policies. The World Health Organization’s (WHO) Framework Convention on Tobacco Control (FCTC) is the best global tool to combat tobacco industry interference, providing clear guidelines to protect public health policies and reduce tobacco-related deaths.

A new report analyzes key contacts between the European Commission (EC) and the tobacco industry to better understand why the EC has struggled to implement a consistent policy around industry meetings. Download the report or brief to read about the seven identified tactics Big Tobacco uses to lobby the EC.

Crooked Nine: Nine Ways the Tobacco Industry Undermines Health Policy

Exposing the tobacco industry’s strategies is the first step towards countering them.

Crooked Nine outlines the nine ways the tobacco industry undermines the policies that reduce smoking and ultimately save lives. STOP researchers documented examples in nearly 30 countries and at the United Nations.

This report will enable readers to:

  • Predict what the industry will do and prepare accordingly
  • Draw on lessons learned from around the world and suggested actions to counteract the industry

Despite what they say, tobacco companies are not trying to create a healthier world. An industry that is serious about saving lives would stop production and stop fighting against effective tobacco control policies.