Influencing the global governance of alcohol: Alcohol industry views in submissions to the WHO consultation for the Alcohol Action Plan 2022-2030
- Alcohol industry actors make similar arguments in global and domestic policy forums.
- The industry says it has no conflict of interest and is vital to policy-making.
- The industry argues against global governance and for local approaches.
- The industry supports self-regulation and rejects effective measures.
- The industry can be expected to advocate against an alcohol treaty in the future.
In 2020, the Secretariat of the World Health Organization (WHO) conducted an open consultation for the purpose of developing an Alcohol Action Plan to “strengthen implementation” of the WHO’s 2010 Global Strategy to Reduce the Harmful Use of Alcohol. In this paper, researchers used the consultation process and public submissions to critically examine alcohol industry perspectives and arguments in relation to the global governance of alcohol.
Since adoption of the Global Strategy in 2010, extensive research has been conducted into the operations, strategies, and policy impacts of alcohol industry actors. Driven by deep concern regarding the influence of commercial interests on alcohol policy development, the “commercial determinants of health” approach has included extensive study of the “political practices” (of the alcohol industry at a national level.
In a systematic review of 20 such studies in 2018, McCambridge et al. concluded that “alcohol industry actors are highly strategic, rhetorically sophisticated and well organized in influencing national policymaking”, thereby shaping “norms” in the “interest of the commercial elite”.
There has, however, been considerably less research on the methods and arguments used by the alcohol industry to influence the “global governance” of alcohol. This paper therefore aims to better understand:
- which industry actors are engaging at this level
- the positions, arguments, and framing that they are adopting, and
- their impact on the development of alcohol-related norms in the WHO
To achieve this, researchers analyzed all alcohol industry submissions to the open consultation conducted by the WHO secretariat in 2020 for the development of the Global Alcohol Action Plan. Another consultation was carried out in 2021, but the submissions to this consultation have not been released by WHO and can therefore not be analyzed.
The WHO received a total of 253 submissions to the 2020 consultation. Most of the submissions came from health-focused civil society organisations (44%), but a substantial amount of submissions also came from the alcohol industry (or private sector benefiting from alcohol industry) (24%).
|Submitting organisation type||Number of submissions||% of submissions|
|UN bodies or other intergovernmental orgs||4||1.6|
|Health-focused non-government organisations||110||43.8|
|Private Sector Entity – Alcohol Industry||46||18.3|
|Private Sector Entity – Other||14||5.6|
|Other entity/organisation (mostly free market think tanks and legal firms)||27||10.8|
Four key arguments by the alcohol industry
Using a directed content analysis and a thematic analysis the researchers identified four key themes in alcohol industry submissions:
(1) The positive role of industry in alcohol policy and its contributions to society
This is the most consistent and recurrent argument made in alcohol industry submissions – 89.5% challenged the WHO document for what they identified as its marginalisation of industry from global alcohol policy-making. Many of the submissions (62.5%) rejected the notion that there is a conflict between alcohol industry interests and public health. Most of the submissions (83%) also sought to buttress their claims about the importance of their inclusion in the processes by attempting to underscore their major contributions to public health efforts directed at reducing alcohol-related harms
”The primary purpose of the industry’s submissions to the 2020 consultation appears to have been assuring the industry’s place in the WHO’s ongoing work relating to the Alcohol Action Plan and the Global Strategy”
(2) The framing of the alcohol problem as being about harms and not consumption
A dominant argument across the alcohol industry actors’ submissions (79,5%) was the insistence that the Alcohol Action Plan should focus on “reducing the harmful use of alcohol and not on consumption”. The centrality of this framing for alcohol industry actors was evident in its positioning and emphasis within the submission—it was either noted on the first page, listed as the first of the submitting organisation’s “concerns,” or presented in a specific section within the submission through the use of subheadings or bold/underlined text. The alcohol industry’s submissions characterised alcohol use that was not “excessive” as non-problematic. Indeed, in the case of wine consumption, it was even framed “as part of a healthy diet and lifestyle”
(3) The rejection of global governance approaches to alcohol policy
A majority (62%) of alcohol industry submitters argued against alcohol being subject to global governance, instead arguing for national and sub-national responses to alcohol problems specific to the social and cultural circumstances at a country level. Multiple submitters emphasised that there cannot be a “one-size fits all” approach to alcohol policy, and insisted that social and cultural differences between countries mean that different approaches are required.
(4) The rejection of the validity of WHO’s preferred strategies for alcohol policy
Half of the alcohol industry submissions questioned a primary focus on the SAFER initiatives. [Note from the editor: SAFER is a WHO technical package guiding member states to implement evidence based alcohol policy measures.] There was particularly strong opposition to banning or further government regulation of alcohol marketing. The common line across the submissions was that alcohol industry actors were responsible advertisers, who never marketed to children, and who had implemented highly effective self-regulatory advertising codes across many countries.
Similar to arguments made on national level
The submissions to the 2020 consultation were made by a more diverse range of commercial actors (including alcohol producers, alcohol trade associations, chambers of commerce, and marketing organisations than those active at the time that the Global Strategy was approved in 2010. These actors deployed arguments that have been used in industry political practices at a domestic level (shown in previous research).
In the analysis, researchers found that the submissions reflect many of the ”policy framing strategies” described in previous research. Some of the conclusions drawn in this paper are:
- Maintaining the seat at the table seems to have been the the alcohol industry’s primary concern in the consultation. This is a ”a longstanding policy-framing strategy advanced in many different policy-making forums at the national level, along with related arguments that industry actors are responsible and significant economic actors”.
- Alcohol industry uses framing of the the policy problem as harmful use by a small subset of people who use alcohol heavily. Previous studies have documented repeated use of this framing in national policy forums. This framing ”enables the industry to advocate for less effective policy solutions”.
- The alcohol industry opposes evidence-based alcohol policy solutions, and promotes less effective practices such as education and awareness campaigns (but not via health warning labels), industry self-regulatory mechanisms, and personal responsibility for alcohol consumption. The interventions proposed by alcohol industry do not regulate the behaviour of industry actors and “absolve” them of blame, and frame the solutions as “supposedly better choices” made by consumers.
Industry influence on the Global Alcohol Action Plan
The next question for the analysis relates to the impact of the industry’s submissions on the final version of the Global Alcohol Action Plan.
The paper concludes that the industry’s submissions were not without impact on the drafting of the Action Plan. Although the findings suggest that the industry may not, at a global level in the WHO, be as strategic, rhetorically sophisticated and well-organised as they are in influencing national policy-making”.
Some key takeaways regarding alcohol industry influence are:
- The alcohol industry is less influential towards WHO compared to the World Trade Organization (WTO), where previous research has indicated substantial industry influence on government trade policy.
- The industry was successful at maintaining a place for itself in global governance at the WHO, with the alcohol industry continuing to be part of the discussions relating to drafts of the Global Alcohol Action Plan, and being granted a role in each of the six action areas provided for under the Action Plan.
- That said, the Global Alcohol Action Plan has greatly narrowed the role for industry compared to the Global Strategy, and now includes more warnings about the threats posed by industry interference in alcohol policy.
- The alcohol industry’s urgent reiteration in its submissions to the 2020 consultation that concern should be with harmful use, not use per se, suggests that the industry is losing ground in a public health context.
- Yet, the concept of “harmful use” was maintained in the adopted version of the Global Alcohol Action Plan – with a substantial discussion on the broad meaning attributed to “harmful use” by WHO included, which cover social and economic harms, and harms to others besides the person who uses alcohol.
- The Regional Committee for WHO Europe had abandoned the formulation of “harmful use of alcohol” and adopted a “Framework for Action on Alcohol” This formulation that has been accepted by WHO’s headquarters in Geneva, which may signal the future direction of alcohol policy at a global level.
The researchers conclude that ”the findings in this study reveal that commercial entities are active in the WHO and are intent upon shaping global norms on alcohol. In the context of the Alcohol Action Plan, the WHO has demonstrated some capacity to resist the influence of the alcohol industry.”
In 2020, the Secretariat of the World Health Organization (WHO) conducted an open consultation, with public submissions, for the purpose of developing an Alcohol Action Plan to “strengthen implementation” of the WHO’s 2010 Global Strategy to Reduce the Harmful Use of Alcohol. The consultation process and public submissions provided an opportunity to critically examine alcohol industry perspectives and arguments in relation to the global governance of alcohol.
48 alcohol industry submissions to the WHO’s 2020 consultation were included for analysis. Directed content analysis was used to examine the policy positions and arguments made by industry actors. Thematic analysis was employed to further explore the framing of industry arguments.
In framing their arguments, alcohol industry actors positioned themselves as important stakeholders in policy debates; differentiated “normal” alcohol use from consumption that merits intervention; argued that alcohol policy should be made at the national, rather than global, level; and supported industry self-regulation or co-regulation rather than cost-effective public health measures to prevent harms from alcohol.
The alcohol industry’s submissions to the WHO’s 2020 consultation could be seen as efforts to stymie improvements in the global governance of alcohol, and repeats several framing strategies that the industry has used in other forums, both national and global. However, their arguments appear to have had little traction in the creation of the Alcohol Action Plan. Changes from the Working Document to the adopted Action Plan show little acceptance by WHO of industry arguments.