Eurocare submission to WHO Working document for development of an action plan to strengthen implementation of the Global Strategy to Reduce the Harmful Use of Alcohol

The European Alcohol Policy Alliance (Eurocare) would like to thank World Health Organization (WHO) for the opportunity to give our feedback to the WHO ‘Working document for development of an action plan to strengthen implementation of the Global Strategy to Reduce Harmful Use of Alcohol’.

This is a positive step forward for achieving the implementation of the Global Strategy to reduce harmful use of alcohol from 2010.

Eurocare is an accredited civil society organization to WHO Europe and look forward to supporting the WHO Global Action Plan.

Regional level needs to be included  
There is no clear reference or actions directed to neither a regional political body, such as the European Union nor the WHO regional offices.  

As a European civil society umbrella organization, we experience the need and value of addressing alcohol policy at a regional level. Cross border policy areas like trade, taxation, labelling, and marketing are examples of policy areas that needs a regional/international approach. In a European context it has been valuable to discuss these areas in addition to capacity building and knowledge sharing of best practice – both between and among Member States and civil society.  

WHO regional offices are important for technical support to Member States in areas like following trends in alcohol consumption, estimates of alcohol harm, and financial costs.    

Eurocare would therefore propose addressing the role of the Regional levels and offices in a final version of the action plan.  

Enforcement of a written policy  
In ‘Setting the scene’, the document refers to the development of written national alcohol policies: ‘However, the presence of written national alcohol policies continues to be most common in high-income countries and least common among low-income countries’.    

Eurocare would like to highlight the importance of enforcement and implementation of the policy documents, and not only that they are written. We therefore welcome Global Target 1.1 ‘By 2030, 75% of countries have introduced and/or strengthened and sustainably enforced implementation of high-impact policy options and interventions. However, we suggest streamlining target 1.1 and 1.3, and suggest that the target will be 80 % in both targets.  

Proportionate universalism  
The working document points out that ‘A significant proportion of alcoholic beverages is consumed in heavy drinking occasions and by people affected by AUD, illustrating the inherent contradiction between the interests of alcohol producers and public health.’  

Eurocare would like to stress the need for the implementation of the WHO Best Buys which have an particular impact on high risk situations and populations such as heavy drinking occasions and people affected by alcohol use disorder, but also affect alcohol consumption and harm more generally.  

Eurocare see additional policies, such as brief interventions and treatment, as complementary policies to the prevention effects of the WHO Best Buys. These interventions with individuals work alongside the WHO Best Buys. They are not a replacement for them. The working document should describe the synergistic relationship between prevention and intervention policies more strongly.  

Accountability and transparency  
Eurocare believe that the issue of accountability should be better reflected in the working document. How will reporting and publishing of the reporting take place?  

We are 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 reduce alcohol harm, Eurocare would like to echo GAPA’s recommendation that the Director General be requested to report to the WHA biennially on the progress of implementing the Global Action Plan including any challenges faced by Member States and the nature and extent of collaboration between UN agencies.  

Furthermore, the numerous and sometimes overlapping recommendations in the draft document tend to obscure a focus on the most cost-effective policies to reduce alcohol-related harms. The Action Plan should be strongly framed around every country implementing the five most effective, science-based interventions, as articulated in the SAFER guidance.  

WHO’s decision-making process should be as transparent and open as possible. The more open the process is, the easier it is to ensure balanced representation and avoid undue pressure and illegitimate or privileged access to information or to decision-makers.  

Eurocare would suggest a transparency register, a database of special interest groups whose goal is to influence policy to be set up by WHO. The register makes visible what interests are being pursued, by whom and with what budgets. In this way, the register allows for public scrutiny, giving citizens and other interest groups the possibility to track the activities of lobbyists.  WHO officials should publish information on meetings held with organisations or self-employed individuals. Meetings relating to policymaking and implementation should only take place if the interest representative are registered in the WHO transparency register. Minutes from all meetings should be published.  

Role of economic operators  
In the current document the “economic operators” – i.e., alcohol industry entities (producers, distributors, retailers, etc) are listed as stakeholders in equal standing alongside civil society and other UN organizations. This is inappropriate, given their inherent conflict of interest and long record of influence against effective alcohol policies, including in low- and middle-income countries (LMIC). The alcohol industry should, instead, be addressed in a separate section with due regard to conflict of interest toward safeguarding public health. Please also see above the suggestion for a transparency register.  

Exposure, not target group, of marketing and advertisement  
Marketing, and particularly advertisement, is an issue Eurocare has been following for years at the EU level, in relation to e.g. the EU Audiovisual Media Services Directive (EU AVMSD). Based on this experience, Eurocare would like to suggest changing the language from ‘targeted’ in relation to commercial activities, to ‘exposure’. This would follow the recent developments at EU level.  

The issue in relation to the groups identified in the working document is the exposure of advertisement, and not whether they were a target group or not. We therefore suggest changing this at least in the following two places in the working document: Scope of the action plan, page 6: ‘Alcohol marketing, advertising and promotional activities of alcoholic beverages are of deep concern, including those implemented through cross-border marketing, and targeting young people and adolescents’ Action Area 1, Action 3 Proposed actions for international partners and non-State actors, page 22: ‘Economic operators in alcohol production and trade, as well as economic operators in other relevant sectors (such as retail, advertisements, social media and communication), are encouraged to contribute to the elimination of marketing and sales of alcoholic beverages to minors and targeted commercial activities towards other high-risk groups.’  

Opportunities for reducing the harmful use of alcohol  
Harmful and hazardous alcohol consumption has a major impact on public health and also generates costs related to health care, health insurance, law enforcement and public order, and workplaces, and thus has a negative impact on economic development and on society as a whole. There are several areas for concern that Eurocare would like to raise as:  
·       Exposure to alcohol during pregnancy can impair brain development of the fetus and is associated with intellectual deficits that become apparent later in childhood. It is imperative to reduce exposure to alcohol during pregnancy, thereby reducing the number of children born with Fetal Alcohol Disorders.
·       Young people are particularly at risk and are disproportionately affected by alcohol. While 5,5% of all deaths in a population are alcohol attributable for the age group 15-19 this is 19% and for the age group 20-24 it is even higher reaching 23,3%.
·       Traffic accidents related to alcohol consumption are a major cause for concern. About one accident in four in EU can be linked to alcohol consumption and at least 10.000 people are killed in alcohol-related road accidents in the EU each year.
·       Alcohol is addictive and WHO Action Plan should generate knowledge and capacity building in how to best help individuals in society, communities and their families and prevent relapse.  

International legal instrument  
Eurocare support the understanding that alcohol remains the only psychoactive and dependence-producing substance that exerts a significant impact on global population health that is not controlled at the international level by legally binding regulatory instruments. This needs to be addressed at an intergovernmental level. Cross border issues are hard to tackle as one Member State alone, which calls for a regional or global approach to these policies.