The web-based consultation ran late November to early December 2020 and asked one question only: What are your comments and suggestions for consideration in reaction to the working document presented? Stakeholder contributions were open to civil society, academia and – controversially – also to the alcohol industry, despite their fundamental conflict of interest.
Now, WHO has released all submissions in two volumes on a dedicated website. In total 253 submissions were made, including even from some governments.
Communities’ contributions outperform Big Alcohol lobby
Out of 253 total submissions, civil society and community groups are responsible for more than 130 submissions. Movendi International alone has supported ca. 40 consultation contributions – meaning approximately one-third of civil society submissions, as Movendi members also contributed to the development of submissions by partners and alcohol policy alliances.
Big Alcohol – including producers, advertisers, lobby front groups, trade associations and industry-funded think tanks – stands for only ca. 75 submissions.
This clearly shows the commitment of community groups and civil society organizations around the world to support the WHO in their effort to better implement the WHO Global Alcohol Strategy.
Other submissions come from academia, such as universities and independent institutes. Some government agencies, such as public health agencies and governmental health centers and foundations, as well as public health directorates and ministries have also made consultation contributions. But WHO has begun this week to consult with Member States specifically.
WHO Member States requested accelerated action, express dissatisfaction with lack of progress
A decision unanimously adopted at the World Health Organization’s 146th Executive Board meeting in early 2020 called the global alcohol burden a “public health priority”. In the decision, countries requested “accelerated action” on alcohol harm.
Concretely, the Executive Board, in its decision, requested the WHO Director-General to:
- Develop an action plan (2022-2030) to effectively implement the WHO Global Alcohol Strategy as a public health priority, in consultation with Member States and relevant stakeholders, for consideration by the 75th World Health Assembly through the 150th session of the WHO Executive Board in 2022.
- Develop a technical report on cross-border alcohol marketing, advertising and promotion issues, including targeting of youth and adolescents, before the 150th session of the WHO Executive Board, which could contribute to the development of the action plan.
- Adequately resource the work on alcohol harm.
Movendi International had already conducted a thorough analysis of the implementation of the WHO Global Alcohol Strategy in the decade since its adoption, as part of its contribution to the review process in 2019. Analysis showed that the WHO Global Alcohol Strategy – despite having facilitated some success – is ineffective, inadequate and in parts outdated to protect people from the harm caused by the products and practices of the alcohol industry.
Lack of progress and failure to implement high-impact alcohol policy solutions
Evidence shows that alcohol policy development has been ineffective over the past decade of the WHO Global Alcohol Strategy (WHO GAS). Technical support to governments has been inadequate, for example concrete technical tools have still not been developed and the WHO Secretariat has not allocated adequate resources to the work on alcohol. The role of the alcohol industry in the WHO GAS is outdated and flawed. The ten year track record is that the alcohol industry itself is a major barrier to the implementation of the WHO GAS.
Overall, trends in alcohol consumption, alcohol’s contribution to the global burden of disease and progress towards global targets are all pointing the wrong direction.
- Progress in the formulation and implementation of national and local alcohol policy solutions has been uneven.
- Most countries, esp. low- and middle-income countries (LMICs), have NOT implemented a comprehensive set of alcohol policies.
- No low-income country has reported increasing resources for implementing alcohol policy since the WHO GAS was adopted.
- Many countries are failing to implement the alcohol policy best buy solutions, with LMICs more likely to have fewer evidence-based and cost-effective policies.
- Modelling forecasts global targets to reduce alcohol use and harm will not be met.
- Without action, Africa could see an increase in both the absolute number and proportion of people consuming alcohol, the amount consumed per capita and heavy episodic alcohol use.
- South East Asia has seen a 29% increase in per capita alcohol use since 2010.
Alcohol affordability policy solutions
95% of reporting countries implement alcohol excise taxes.
Few use such taxes as a public health policy to reduce consumption.
Less than half use price strategies such as adjusting taxes to keep up with inflation and income levels, imposing minimum pricing policies, or banning selling below cost or volume discounts.
Alcohol availability policy solutions
Less than one-third of countries have regulations on outlet density and days of alcohol sale.
Some countries, mainly LMICs in Africa, still have no legal minimum purchase age.
Alcohol marketing policy solutions
Most countries have some policies on alcohol advertising.
Alcohol marketing regulation continues to lag behind technological innovations and e-commerce, including rapidly developing new delivery systems.
Most of the countries that reported no restrictions across all media types were located in the African or Americas regions.
Alcohol remains one of the leading risk factors contributing to the global burden of disease.
- Alcohol is the eighth leading preventable risk factor for disease.
- The contribution of alcohol to the global disease burden has been increasing year by year from 2.6% of DALYs* in 1990 to 3.7% of DALYs in 2019.
- In high income countries, alcohol use is the second fastest growing risk factor and in LMICs it is the fourth fastest rising risk factor.
- Alcohol is the second largest risk factor for disease burden in the age group 10-24 years.
- Alcohol is the largest risk factor for disease burden in the group 25-49 years.
Movendi advocates for bold, ambitious action plan
Movendi International, together with our member organizations, made a comprehensive submission to the WHO consultation. It consisted of three parts:
- General feedback about what Movendi International support and what Movendi wants to improve in the working document;
- Specific comments on what Movendi International disagrees with; and
- Detailed proposals for the elements and structure of the future action plan.
The submission has been developed in a comprehensive process by communities affected by alcohol and engaged in preventing and reducing the consequences of Big Alcohol products and practices.
Summary of action points and recommendations
A summary of the key proposals consists of seven points.
1. Ensure bold targets and ambition
Movendi International proposes a bold and ambitious overall target of a 30% reduction of per capita alcohol consumption until 2030, and a bold and ambitious target to maintain the global percentage of past-year alcohol abstainers among the global adult population at 2016 levels.
2. Strengthen the analysis of challenges and opportunities and better link to other parts of the action plan, especially the global actions.
There are 15 challenges listed in the working document. There are 7 opportunities listed in total.
Movendi proposes the addition of five more opportunities, and suggests the removal of 3 challenges. In general, Movendi recommends that the analysis of the challenges and opportunities better reflects in other parts of the action plan all key lessons learned in the last ten years of WHO GAS implementation.
3. Streamline the global actions by avoiding repetition, reducing overlap and adding prioritization.
Movendi welcomes and supports the set of specific actions and measures to be implemented at global level, building on the WHO GAS provisions. Some of them might be repetitive; some of them might rather be located in a different place of the action plan; some might be removed and some of them might be merged; some of them might be summarized more effectively. They might be streamlined and prioritized.
Where possible, actions and key indicators should be time-bound.
It is important that the action plan makes it clear who has primary responsibility and obligation to implement the WHO GAS and achieve global targets – the Member States and WHO.
Movendi asks for the action plan to illustrate that the operational objectives and principles have a clear bearing on the global actions for WHO and Member States. Comparing the elements of the WHO GAS objectives with the new proposed operational objectives, some elements have gone missing and should be brought back. The following elements should also be included in the action plan’s operational objectives:
- NEW 7. Increased technical support to, and enhanced capacity of, Member States for developing and implementing the most cost-effective alcohol policy solutions, and for protecting those against alcohol industry interference; and
- NEW 8. Improve and strengthen the global and regional infrastructure for alcohol policy development in order to build momentum, exchange best practices, and facilitate partnerships and international collaboration.
4. Ensure greater focus on the SAFER strategies.
Movendi supports the focus on the most cost-effective alcohol policy solutions and suggests expanding their place in the action plan.
This should be clear in the global action areas but should also be a through line in the entire action plan, beginning with the analysis of the decade of WHO GAS implementation, where a focus on the implementation of the alcohol policy best buys – that has largely fallen short of necessity – is currently missing.
5. Update nomenclature in line with state-of-the-art evidence.
Movendi supports revising the nomenclature employed for discussing the global alcohol burden and alcohol policy solutions.
Consistent, clear, unambiguous and evidence- based language and messages from WHO set the standards and shape both norms and discourse. Therefore, a review of problematic concepts, terms and words is crucial – both considering scientific developments over the last ten years as well as alcohol industry attempts to exploit and hijack key concepts and terms.
6. Ensure greater focus on governance and infrastructure improvements.
Compared to other areas of global health, the governance and infrastructure for supporting alcohol policy development and implementation worldwide is under-developed and remains inadequate.
Regarding the level of global action:
- There is no global day/ week to raise awareness about alcohol harm and policy solutions – like there is for tobacco and many other health issues.
- There is no global ministerial conference on alcohol under the guidance of WHO – like there is for mental health, for ending tuberculosis or for road safety for example.
- There is no Global Fund for Alcohol Prevention – like there is for HIV/ AIDS, TB and Malaria.
- There is no global initiative to advance alcohol taxation (or alcohol marketing) – like there is for tobacco taxation.
- There is no Interagency Coordination Group on alcohol harm – like there is for antimicrobial resistance (AMR).
- There is no One Health Global Leaders Group on Alcohol Harm – like it was recently launched for AMR.
- There is no functioning international network of alcohol focal points, largely due to lack of funding and capacity to coordinate and arrange meetings – like there is for NCDs government focal points.
- There is no mechanism for alcohol policy to be on the agenda of WHO governing body meetings in regular, meaningful intervals – like there is for other public health priority issues and despite the fact that alcohol harm extends far beyond NCDs.
- There is no civil society participation in WHO’s expert groups/ committees on alcohol – like there is for other health issues and despite the fact that civil society participation has often been the driver for action and accountability.
- For tobacco, WHO has the Tobacco Free Initiative and the MPOWER package. But there is no specific WHO program on alcohol – despite the existence of SDG 3.5 – to act us custodian for all challenges listed above and to ensure a response to the alcohol burden commensurate with the magnitude of harm.
- There is still insufficiently developed methodology for understanding the real burden of alcohol and the real potential of alcohol policy implementation.
Regarding the level of national action:
- There are few/ no countries with an institutionalized permanent coordinatingentity for alcohol policy development and implementation consisting of senior representatives from all relevant departments of government as well as representatives from civil society and professional associations,
- There are few/ no countries that conduct regular (annual) alcohol policy roundtables/ meetings with national leaders and civil society to discuss latest alcohol policy issues, and
- There are few/ no countries with distinct mechanisms to safeguard alcohol policy development and implementation against alcohol industry interference.
Until 2030, there should be significant progress in terms of these infrastructure and governance elements and therefore Movendi proposes they be included in the section of the action plan called “Infrastructure”.
7. Improve resourcing as well as reporting and review of implementation.
Movendi International recommends annual WHO publications about alcohol harm and/ or policy development issues – as done in tobacco control, where annual reports with different topics are produced to generate momentum for policy discussions and action.
Regarding resourcing, already in the process of developing the action plan, governments should make stronger commitments to support WHO’s work on alcohol and the Secretariat and regional offices in turn should allocate resources commensurate with the alcohol burden.
Movendi calls for more frequent reporting to the WHO governing bodies, preferably through a regular stand-alone agenda item.
Movendi is concerned about the lack of specific time intervals for review and reporting of the implementation of the Action Plan. Given the importance of intergovernmental collaboration to prevent and reduce alcohol harm, we recommend that the Director-General be requested to report to the World Health Assembly biennially on the progress of implementing the Global Action Plan. This should include any challenges faced by Member States and the nature and extent of collaboration between UN agencies.
