This study expanded the understanding of NGOs and their roles in the governance system regulating the ultra-processed food and alcohol industries in Australia. While the Australian NGOs can be considered active players in food and alcohol governance nationally and/or in states/territories, their role as surrogate regulators needs a more detailed examination. There are many opportunities for them to shape harmful commodity industries (HCI) policies and practices, building on their focus on agenda setting and capacity building, and expanding their activities in monitoring and implementation.


Dori Patay, Sharon Friel (e-mail: e-mail:, Belinda Townsend, Fran Baum, Jeff Collin, Katherine Cullerton, Katie Dain, Rodney Holmes, Jane Martin, Rob Ralston, Lucy Westerman


Patay D, Friel S, Townsend B, Baum F, Collin J, Cullerton K, Dain K, Holmes R, Martin J, Ralston R, Westerman L. Governing ultra-processed food and alcohol industries: the presence and role of non-government organisations in Australia. Aust N Z J Public Health. 2022 Aug;46(4):455-462. doi: 10.1111/1753-6405.13263. Epub 2022 May 26. PMID: 35616401. Copy

Australian and New Zealand Journal of Public Health
Release date

Governing ultra-processed food and alcohol industries: the presence and role of non-government organisations in Australia

Research article



The roles of non-governmental organisations (NGOs) in regulating harmful commodity industries (HCIs) are understudied. The aim of this paper is to identify the NGOs and the roles that they play in the governance of the ultra-processed food and alcohol industries in Australia.


The researchers undertook an exploratory descriptive analysis of NGOs identified from an online search based on the typology we developed of type, issue area and governance function.


A total of 134 relevant Australian NGOs were identified:

  • 38 work on food issues,
  • 61 with alcohol issues, and
  • 35 are active in both.

In the food domain, 90% of NGOs engage in agenda setting, 88% in capacity building, 15% in implementation and 12% in monitoring.

In the alcohol domain, 92% of NGOs are active in agenda setting, 72% in capacity building, 35% in implementation and 8% in monitoring.


Australian NGOs are active actors in the food and alcohol governance system.

Implications for public health

There are many opportunities for NGOs to regulate HCI practices, building on their relative strengths in agenda setting and capacity building, and expanding their activities in monitoring and implementation.

A more detailed examination is needed of strategies that can be used by NGOs to be effective regulators in the governance system.

NGOs active on alcohol issues

A broad spectrum of NGOs (N=97) worked on alcohol-related topics in Australia. A total of 35 solely focused on alcohol; however, several other NGOs were relevant through their work on alcohol in relation to disease-specific areas (n=15), broader health issues (n=30) and other topics (n=17).

For example, the National Aboriginal Community Controlled Health Organisation influenced alcohol policy through government submissions in addition to other health concerns. Families Australia was one of the 14 non-statutory organisations that primarily worked on a variety of non-health-related topics, but some of its activities were directly related to alcohol issues, such as providing knowledge resources to families to curb alcohol consumption; thus, it was classed within the ‘other focus’ category. Similarly, Step Bank Think was also listed in this category. As well as focusing on awareness-raising to reduce violence it also lobbied for stricter alcohol regulation.

Three of the four identified statutory organisations primarily focused on broader health issues, which also include alcohol: for example, VicHealth had an alcohol harm prevention portfolio. While some coalitions, such as the Aboriginal Drug and Alcohol Residential Rehabilitation Network or the National Alliance for Action on Alcohol worked on alcohol issues, others, like the Lowitja Institute Health System Coalition, worked on broader health matters. As in the food domain, professional associations (n=14) tended to be active on broader health concerns while engaging in alcohol-related activities as well, often by government submissions on alcohol policy and training health professionals; PHAA was a good example of these organisations. The Russell Family Fetal Alcohol Disorders Association, with a concentrated activity on reducing alcohol consumption among pregnant women, was the only private philanthropy identified as being relevant for this study.

Who is doing what? NGOs active on alcohol issues

NGOs working on alcohol issues demonstrated a similar pattern of participation in governance functions to those active in food. Agenda setting and capacity building were performed by the majority of organisations, while monitoring remained in the background. Implementation happened more frequently than in the food domain.

Agenda setting: Almost all (92%) of NGOs (n=89) engaged in agenda setting. All statutory, industry-funded and private philanthropic organisations engaged in agenda-setting activities, with the other types close behind: 96% coalitions, 95% professional associations, and 88% non-statutory NGOs. Each of the private philanthropy and industry-funded NGO was active in agenda setting via government submissions.

Capacity building: Similarly to NGOs working in the food domain, capacity building activities were performed by 72% of NGOs (n=70) active on alcohol issues. All statutory, industry-funded, and private philanthropic organisations regularly conducted capacity building. Most NGOs provided capacity building to civil society groups (48%) and the public (46%); such activities touched on a broad spectrum of topics regarding alcohol.

For example, the Aboriginal Health Council of South Australia educated the public and health professionals about the harm due to alcohol, while the People’s Health Movement Australia raised awareness about alcohol industry influence over policy making. Government actors were targeted by the McCabe Centre for Law and Cancer, which provided training for policy makers on making better public policy to regulate the alcohol industry. No NGO presented themselves as working with alcohol industry actors.

Implementation: 35% of NGOs (n=34) working on alcohol issues implemented initiatives; this is 20% more compared to food. Half of statutory and 49% of non-statutory NGOs ran programs and/or projects, while 21% of professional associations, 13% of coalitions, and the private philanthropy did so. The industry-funded NGO was not engaged in this function. The initiatives most often related to alcohol harm reduction.

For example, among the non-statutory organisations, the Alcohol and Drug Foundation and the Foundation for Alcohol Research and Education ran initiatives focusing on alcohol harm prevention. Altogether, 34% of NGOs (n=33) active on alcohol issues ran their own initiatives, and one actor, the Police Federation of Australia, had a role in implementing government regulations.

Monitoring: Only 8% of NGOs (n=8) working on alcohol issues were active in monitoring alcohol industry or government actors. The government was targeted by the Network of Alcohol and other Drugs Agencies, the People’s Health Movement Australia, the Australian Fair Trade and Investment Network, Queensland Network of Alcohol and Other Drug Agencies.

Four organisations monitored alcohol industry activities: the People’s Health Movement Australia, Foundation for Alcohol Research and Education, Australian Council on Children and the Media, and the Gunbang Action Group. Statutory, industry-funded, and private philanthropic NGOs were not involved in such activities. This may be because sectoral or internal standards are primarily monitored by companies themselves rather than ‘arm’s length’ philanthropies.

Implications for public health

The researchers identified four distinct opportunities to strengthen NGOs’ governance activities in the food and alcohol domains in Australia.

First, the majority of NGOs that use their apparent focus and relative strengths in capacity building targeting the public, health professionals and their members could expand their activities to involve government agencies in their initiatives, particularly to help them formulate better regulatory policies. Doing so could serve as another avenue to balance out the influence of HCI interests in policy making.

The second opportunity relates to agenda setting. This is a common activity among the NGOs who engage in food and alcohol issues, and even more so among those who work across both domains. This presents an opportunity for already engaged NGOs to support coalition building to advance collective action on CDOH more generally.

  • For example, public health and consumer groups with an interest in food and alcohol have been jointly advocating against the changes proposed to the Food Standards Australia New Zealand Act 1991 that would elevate trade interests over health in food regulation.
  • Another example is the work led by VicHealth around a unified approach regarding the marketing of unhealthy products on digital platforms.
  • Such coalitions could be better supported by government mechanisms that privilege engagement of NGOs rather than commercial actors in policy and regulation development processes.

Third, our data suggest that NGOs active on food and alcohol issues in Australia rarely consult, collaborate or provide capacity building for HCIs. This can be explained by the common understanding of the conflicts of interest between private, profit-oriented industries and public health.

Available evidence indicates that partnerships between NGOs and HCIs ultimately tend to serve vested interests due to the inherent power imbalance between the private and civil sectors, whereby NGO participation in multi-stakeholder platforms may legitimate governance arrangements that privilege commercial sector interests.

There are many opportunities for NGOs to engage in monitoring both HCIs and the government to advance health governance. Coalitions are already leading monitoring initiatives and are well placed to assess compliance in the private sector. This study of governance roles could support a coordinated review of NGOs’ work and capacities to best utilise the aggregated resources of member organisations. The resources required for such work to be sustainable are, however, significant and often under-estimated.

Establishing rigorous international monitoring of the tobacco industry, for example, has entailed a US$20 million investment by Bloomberg Philanthropies. Adequate funds to support monitoring activities from government or philanthropy could ensure that NGOs have the capacity to perform this function. However, receipt of such funds must not be conditional and so limit NGOs’ capacity to advocate.

In addition, government measures to increase the transparency of HCI activities by requiring regular and consistent disclosure would help NGOs to hold industry actors to account.

Fourth, government agencies in Australia should not only recognise NGOs as surrogate regulators of HCIs but actively create an enabling environment for them to engage in formulating and implementing public policies. As Gunningham et al. write, “in the absence of external [government] intervention, many of the potential opportunities for the third party interventions may never be realised”.

Institutionalising the presence of NGOs in policy making, ensuring their legal protection, and increasing government funds, could help in levelling the playing field between civil society and industry actors. Moreover, government agencies can support NGOs to act as surrogate regulators by providing them with greater access to information about corporate political activity.

Source Website: Wiley Online Library