Comparative Analysis and Recommendations for Further Improvements by Movendi International
This policy brief provides an updated comparative analysis of how alcohol harm and alcohol policy are addressed in the latest draft (Rev. 3, dated August 4, 2025) of the Political Declaration for the 4th UN High-Level Meeting on Noncommunicable Diseases (NCDs) and Mental Health.
The policy brief examines changes from the Zero Draft through Revision 1 and Revision 2, evaluates alignment with WHO-endorsed evidence-based alcohol policy strategies (Best Buys, SAFER), and identifies gaps and opportunities for restoring ambition and coherence in the final political declaration.
The comparative analysis based on the Rev. 3 draft of the Political specifically focuses on:
- How alcohol harm is addressed as a risk factor for NCDs and mental health,
- How alcohol policy is treated as a solution, particularly in relation to the WHO Best Buys and SAFER blueprint,
- How Rev. 3 compares to the Zero Draft, Rev. 1, and Rev. 2 in light of Movendi’s prior analysis, and
- Recommendations for further improving the language on alcohol harm and alcohol policy.
Movendi Has Launched an Initiative to Restore Ambition to the UN NCDs and Mental Health Declaration
Movendi International has launched a global initiative to ensure the UN Political Declaration on NCDs and Mental Health includes high-impact, evidence-based alcohol policy solutions. Despite alcohol being a major risk factor, proven solutions are being left out due to industry interference.
The initiative for collective action gives people everywhere the chance to make their voices heard and urge their governments to restore ambition, integrity, and impact to the declaration.
1. How Alcohol Harm Is Addressed as an NCD and Mental Health Risk Factor
Rev. 3 references alcohol in five key ways:
- §13 (Global alcohol burden): States that 2.6 million deaths each year are attributable to alcohol consumption.
- §43 (Pro-health taxation): creating health promoting environments through raising or introducing alcohol taxation.
- §44(f) (Alcohol policy response): Calls to “reduce the harmful use of alcohol through accelerating the implementation of the Global Strategy to Reduce the Harmful Use of Alcohol (2010) and the Global Alcohol Action Plan 2022–2030, including by considering marketing and availability measures.”
- §46 (Health literacy section): Lists alcohol alongside tobacco and air pollution for public awareness efforts (still using “harmful use” framing).
- §57 (provision of psychosocial and psychological support): Mentions “harmful use of alcohol” alongside other conditions like psychosis and depression in a list of conditions where treatment and psychosocial support are to be scaled up.
- This sections shows the flaws of the term “harmful use of alcohol” because in the treatment context it means a clinical diagnosis, while in the rest of the document it means WHO’s broad definition of alcohol harm, including social harm. The political declaration should not use terminology that means different things in the same document.
Assessment of how Rev. 3 draft addresses alcohol harm
This is an incremental improvement over Rev. 2, which lacked any reference to concrete alcohol policy measures.
However, alcohol harm remains described in generic, decontextualised terms, with continued use of the flawed, outdated, and confusing concept “harmful use of alcohol” and no mention of second-hand harms, gender-based violence, or mental health burden of alcohol use disorder and addiction.
2. How Alcohol Policy Is Addressed (Best Buys + SAFER Blueprint)
In Rev. 3, alcohol policy is addressed in three relevant sections:
2.1 §43: Pro-health taxation
Rev. 3 retains the importance of considering “introducing or increasing taxes on tobacco and alcohol to support health objectives, in line with national circumstances;”
- This remains the most robust alcohol policy element, preserved from earlier drafts.
- However, the 80% target for raising alcohol taxes has been diluted and now is a general target for all NCDs policy measures:
- “Target: at least 80% of countries have implemented policies and legislative, regulatory and fiscal measures to support health objectives related to prevention and control of noncommunicable diseases and promotion of mental health and well-being, in line with national circumstances, by 2030.“
2.2 §43(f): Alcohol policy response
“Reduce the harmful use of alcohol through accelerating the implementation of the Global Strategy to Reduce the Harmful Use of Alcohol (2010) and the Global Alcohol Action Plan 2022–2030, including by considering marketing and availability measures.”
Comparison to Previous Versions:
| Version | Content |
| Zero Draft | Included 3 of 5 SAFER measures explicitly (marketing, availability, alcohol impaired driving). |
| Rev. 1 | Retained same 3 measures, though demoted in prominence. |
| Rev. 2 | Removed all concrete policy examples, replaced with a meaningless reference to the Global Alcohol Action Plan. |
| Rev. 3 | Partially restores alcohol policy best buys with vague language “considering marketing and availability measures.” But fails to include alcohol impaired driving counter measures or screening and brief interventions. No SAFER or Best Buys mentioned explicitly. |
2.3) §57 Treatment/Screening
Rev. 3 again includes “harmful use of alcohol” in a long list of conditions under the heading of scaling up access to treatment, psychosocial, and pharmacological support.
- Still misses the opportunity to name screening and brief psychosocial interventions for alcohol use disorder and addiction (Quick Buy #4) as a cost-effective, evidence-based action for reducing and preventing escalating mental health harm due to alcohol.
- Reveals the flaws of the term “harmful use of alcohol” because in the treatment context it means a clinical diagnosis, while in the rest of the document it means WHO’s broad definition of alcohol harm, including social harm.
- The political declaration should not use terminology that means different things in the same document.
Assessment of the alcohol policy response
All three alcohol policy best buys are now included: alcohol tax increases in §43 and alcohol marketing and availability limitations in §44.
The lack of reference to the WHO SAFER alcohol policy blue print and the absence of alcohol policy among the fast-track actions also remain a serious flaw of the draft political declaration.
- Improved vs. Rev. 2: At least a partial reinstatement of two Best Buys and SAFER measures.
- Worsened: the 80% target for raising alcohol taxes has been diluted and now is a general target for all NCDs policy measures – losing specificity and ambition.
- Still inadequate: Lacks clarity, strength, and commitment. Uses weak “considering” language. No reference to Best Buys, Quick Buys, or the SAFER package by name.
- Still missing: Clear reference to screening and brief interventions for alcohol use disorder and addiction – both in §44 and in §57.
- Deeply problematic: The draft contains the flawed term of “harmful use of alcohol” but employs two mutually exclusive definitions caused confusion instead of clarity.
3. Comparison to Movendi’s Analysis of Previous Drafts of the Declaration – What Got Better or Worse?
The following table summarises the evolution of alcohol policy elements across the two latest versions of the draft declaration:
| Element | Rev. 2 draft | Rev. 3 draft | Status |
|---|---|---|---|
| Concrete alcohol policy measures | None | Partial re-introduction (marketing, availability “consideration”) | Slight improvement |
| Fast-track Reference to SAFER/ Best Buys/ Quick Buys | – No fast-track action – Zero reference to high-impact measures | – Still no fast-track action – Still none | No improvement No improvement |
| Alcohol taxation target (80% of countries) | Retained | Removed | Worsening |
| Health literacy | Retained but with flawed “harmful use” framing | Same | No improvement |
| Screening and treatment (SAFER intervention) | No mention of screening and brief intervention Conflicting use of flawed term “harmful use of alcohol | No mention of screening and brief intervention Conflicting use of flawed term “harmful use of alcohol | No improvement |
| Commercial determinants of health (CDoH) language Conflict of interest language | Missing from §42 §63 mentions preventing conflict of interest §81 gives the private sector a role – with due regard to conflict of interest prevention – in NCDs prevention and mental health promotion | Still missing from §42 §65 mentions preventing conflict of interest §81 gives the private sector a role – with due regard to conflict of interest prevention – in NCDs prevention and mental health promotion | No improvement and inadequate on CDoH Solid on reference to the need for conflict of interest prevention |
| Alcohol industry interference language | None | None | No improvement |
| Target for population-level alcohol consumption reduction | None | None | No improvement |
| Framing of harm | Inadequate (key harms are omitted), stigmatising and misleading (flawed concept of “harmful use of alcohol”) | Inadequate (key harms are omitted), stigmatising and misleading (flawed concept of “harmful use of alcohol”) | No improvement |
Summary Assessment: Rev. 3
Positive:
- Retaining of alcohol taxation
- But with removal of concrete target from Rev. 2
- Partial return of concrete and high-impact alcohol policy measures (availability and marketing) after complete deletion in Rev. 2.
- But with watered down ‘considering’ language.
- Reference to the need to prevent conflicts of interest, concerning the “private sector”.
Negative:
- No fast-track alcohol policy action and target, despite clear commitment expressed by member states in 2022 when adopting the WHO Global Alcohol Action Plan.
- No targets for reducing alcohol consumption, unlike tobacco (which retains a 150 million user reduction target).
- No mention of the SAFER alcohol policy blue print or Best Buys packages, despite being official WHO guidance endorsed by Member States.
- No mention of alcohol industry interference or commercial determinants of health.
- Stigmatizing, vague, and outdated language persists – “harmful use” persists still throughout the revision 3 document as dominant framing.
- Screening and brief interventions are still missing, despite being one of the five SAFER interventions and one of the four alcohol policy Quick Buys.
Conclusion
Rev. 3 marks a course correction after the major setbacks introduced in Rev. 2. The reintroduction of references to marketing and availability is an acknowledgment of alcohol policy’s role but falls far short of what is needed to reflect the scale of the alcohol burden or to align with previous agreements by Member States, and WHO’s guidance.
Compared to other risk factors, alcohol policy remains the most inadequate, vague, and under-specified intervention area:
- Tobacco: Detailed actions, targets, and protection from industry interference.
- Unhealthy diets and physical inactivity: Multi-layered strategies and investments.
- Alcohol: Stigmatizing, outdated, misleading language, no specificity, no targets, no alcohol industry accountability.
The political declaration still fails to use the tools at hand – alcohol policy Quick Buys and the SAFER blueprint – that could drive a quadruple win for health, equity, economy, and sustainable development and make the political declaration a turning point for alcohol policy.
4. Recommendations for further improving the language on alcohol harm and alcohol policy.
- Replace ‘harmful use of alcohol’ with ‘alcohol harm’ or ‘per capita alcohol consumption’ for clarity and scientific accuracy.
- Retain in §43(f), the two alcohol policy best buys on availability limits and advertising bans, and include the missing SAFER interventions: screening and brief interventions as well as driving under the influence of alcohol counter-measures.
- Include alcohol screening and brief interventions among treatment and prevention commitments (§57).
- Reinsert the 80% taxation target for alcohol and tobacco (§43).
- Introduce language acknowledging and protecting against alcohol industry interference and the commercial determinants of health (§42).
- Align the declaration with the ambition, momentum, and global consensus of the Global Alcohol Action Plan to accelerate alcohol policy action by addressing alcohol harm as public health priority: Include fast-track action for alcohol policy in §41.
Source Website: Movendi International Advocacy Priorities for HLM4 on NCDs and Mental Health