Non-Communicable Diseases 4
Profits and pandemics: prevention of harmful effects of
tobacco, alcohol, and ultra-processed food and drink
Rob Moodie, David Stuckler, Carlos Monteiro, Nick Sheron, Bruce Neal, Thaksaphon Thamarangsi, Paul Lincoln, Sally Casswell, on behalf of
The Lancet NCD Action Group
The 2011 UN high-level meeting on non-communicable diseases (NCDs) called for multisectoral action including
with the private sector and industry. However, through the sale and promotion of tobacco, alcohol, and ultra-processed
food and drink (unhealthy commodities), transnational corporations are major drivers of global epidemics of NCDs.
What role then should these industries have in NCD prevention and control? We emphasise the rise in sales of these
unhealthy commodities in low-income and middle-income countries, and consider the common strategies that the
transnational corporations use to undermine NCD prevention and control. We assess the effectiveness of self-
regulation, public–private partnerships, and public regulation models of interaction with these industries and
conclude that unhealthy commodity industries should have no role in the formation of national or international NCD
policy. Despite the common reliance on industry self-regulation and public–private partnerships, there is no evidence
of their effectiveness or safety. Public regulation and market intervention are the only evidence-based mechanisms to
prevent harm caused by the unhealthy commodity industries.
At the 2011 UN high-level meeting on non-com municable
diseases (NCDs), the political declaration presented the
case for prevention of NCDs in low-income and middle-
income countries.1 Participants agreed that no one factor
could fully address the burden of NCDs and called for
collaboration with “non-health
stakeholders, where appropriate, in cluding the private
sector and civil society, in collaborative partnerships to
promote health and to reduce non-communicable disease
risk factors”.1 To achieve the agreed goal to reduce
premature mortality due to NCDs of 25% by 20252 will
need a massive scale-up of concerted action to reduce
consumption of unhealthy
tobacco, alcohol, and ultra-pro cessed food and drink
products (panel 1). National governments, non-
governmental organisations, academ ics, and civil society
need to consider what the appropriate role of the private
sector will be in NCD prevention and control. The debate
is most contentious about the unhealthy commodities
industries, which are major drivers of NCD epidemics
worldwide. What role should these industries have in
NCD prevention and control? What type of interaction—
defined here as a reciprocal action or influence—with
these industries promotes health and protects the public
from conflicts of interest? The global health community
has different views about how to proceed, which range
from collaborative part nerships to outright criticism.
Although there is now consensus that the tobacco
industry’s conflict of interest with public health is
irreconcilable, whether the competing interests of
the alcohol, food, and drink industries are similarly
ir reconcilable is debated. This lack of clarity stems partly
actors and key
from the absence of a coherent and agreed upon frame-
work for interaction; the normalisation of unhealthy
commodities in many countries;10 the financial and
institutional relations many public health researchers,11
non-governmental organisations, and national and inter-
national health agencies have with these companies; and
little appreciation that the purpose of corporations is to
maximise profits.12 These conflicts are largely unstudied in
public health. The science of the effect of corporate
behaviour on health is an emerging area of public
February 12, 2013
This is the fourth in a Series
of five papers about
Melbourne School of
Population Health, University
of Melbourne, Melbourne, VIC,
Australia (R Moodie MBBS);
Department of Sociology,
University of Cambridge, UK
(D Stuckler PhD); Department
of Nutrition, School of Public
Health, University of Sao Paulo,
Sao Paulo, Brazil
(C Monteiro PhD); Division of
Infection, Inflammation and
Immunity, Faculty of Medicine,
University of Southampton,
Southampton, UK (N Sheron);
George Institute for Global
Health, University of Sydney,
Sydney, NSW, Australia
(B Neal PhD); International
Health Policy Program,
Ministry of Public Health,
(T Thamarangsi PhD); National
Heart Forum, London, UK
(P Lincoln BSc); and SHORE and
Whariki Research Centre,
School of Public Health, Massey
New Zealand (S Casswell PhD)
Prof Rob Moodie, Melbourne
School of Population Health,
University of Melbourne,
Melbourne, VIC 3010, Australia
non-communicable disease epidemics and profit from
increased consumption of tobacco, alcohol, and
ultra-processed food and drink (so-called unhealthy
similar strategies to the tobacco industry to undermine
effective public health policies and programmes
the formation of national or international policy for
non-communicable disease policy
and public–private partnerships to improve public health,
there is no evidence to support their effectiveness or safety
non-communicable disease epidemics, the only
evidence-based mechanisms that can prevent harm
caused by unhealthy commodity industries are public
regulation and market intervention
health that needs to be developed substantially; it studies
the health risks of transnational corporations and the
distribution of the unhealthy commodities that they make
and market. The term industrial epidemic13,14 has been used
to describe health harms associated with various goods
including tobacco,9,15 alcohol,16,17 vinyl chloride,18 asbestos,19
cars,20 and the food and drink industries.14 In industrial
epidemics, the vectors of spread are not biological agents,
but transnational corporations. Unlike infectious disease
epidemics, however, these corporate disease vectors
implement sophisticated cam paigns to undermine public
health interventions. To minimise the harmful effects of
unhealthy commodity industries on NCD prevention, we
call for a substantially scaled up response from
governments, public health organisations, and civil society
to regulate the harmful activities of these industries.
Unhealthy commodities in low-income and
In 2010, tobacco was estimated to have been responsible
for 6·3 million deaths and alcohol accounted for
4·9 million deaths. Together tobacco and alcohol—the
second and third leading risk factors for the global
disease burden, respectively—cause nearly 12% of
global disability-adjusted life-years.21 The consumption
of energy-dense ultra-processed foods, unlike low-
energy foods such as fruits and vegetables, promotes
obesity.22 Similarly, consump tion of sugar-sweetened
beverages is associated with increased rates of obesity
and diabetes,23 childhood obesity,24,25 long-term weight
gain, and cardiovascular disease.26,27 In addition to the
deaths caused by tobacco and alcohol, more than
18 million deaths every year are caused by high blood
pressure (9·4 million),
(3·4 million), high fasting blood glucose (3·4 million),
and high total cholesterol (2·0 million),21 much of which
could be attributed to the consumption of ultra-
processed foods and drinks (panel 1). Almost all growth
in the foreseeable future in profits from the sale of these
unhealthy commodities will be in low-income and
Saturation of markets in high-income countries28 and
the high global average of income that people spend on
food (20%) has caused the alcohol and ultra-processed
food and drink industries to rapidly penetrate emerging
global markets, as the tobacco industry has done. Trans-
national corporations are major drivers of the acceler-
ation of the nutrition transition—ie, from traditional
diets of whole or minimally processed foods to highly
processed foods and drinks. The substantial growth
of ultra-processed products3,7,29 has paralleled and
contributed to the increase in obesity, diabetes, and other
diet-related chronic diseases,30 especially in low-income
and middle-income countries.23,31 To assess existing and
future trends in unhealthy commodities, activities of the
major corporations need to be monitored. For low-
income and middle-income countries, we used official
market sales data because survey data for the
consumption of unhealthy commodities, measurable
across countries and over time, are scarce. Additionally,
market data are not subject to recall biases, which
complicate the recording of individuals’ consumption of
unhealthy commodities. We used market data for
commodity sales from the EuroMonitor Passport Global
Market Information database 2011 edition,32 covering up
to 80 countries between 1997 and 2010 (panel 2).
Tobacco, alcohol, and several categories of packaged
food—a good proxy for ultra-processed food and drink
products—are rising most rapidly in low-income and
middle-income countries (table 1). Little, if any, growth is
expected in high-income countries in the next 5 years
because of the economic recession (figure 1), strict
tobacco-control policies, and saturation of established
markets with ultra-processed food and drink products.28,33
high body-mass index
Panel 1: Ultra-processed products
Ultra-processed products are made from processed
substances extracted or refined from whole foods—eg, oils,
hydrogenated oils and fats, flours and starches, variants of
sugar, and cheap parts or remnants of animal foods—with
little or no whole foods. Products include burgers, frozen
pizza and pasta dishes, nuggets and sticks, crisps, biscuits,
confectionery, cereal bars, carbonated and other sugared
drinks, and various snack products.
Most are made, advertised, and sold by large or transnational
corporations and are very durable, palatable, and ready to
consume,3–6 which is an enormous commercial advantage
over fresh and perishable whole or minimally processed
foods. Consequently, their production and consumption is
rising quickly worldwide.3,7 In the global north—ie, North
America and Europe—ultra-processed products have largely
replaced food systems and dietary patterns based on fresh
and minimally processed food and culinary ingredients that
have less fat, sugar, and salt. In the global south—ie, Asia,
Africa, and Latin America—ultra-processed products are
displacing established dietary patterns, which are more
suitable socially and environmentally.
Ultra-processed products are typically energy dense; have a
high glycaemic load; are low in dietary fibre, micronutrients,
and phytochemicals; and are high in unhealthy types of
dietary fat, free sugars, and sodium.3,8 When consumed in
small amounts and with other healthy sources of calories,
ultra-processed products are harmless; however, intense
palatability (achieved by high content fat, sugar, salt, and
cosmetic and other additives), omnipresence, and
sophisticated and aggressive marketing strategies (such as
reduced price for super-size servings), all make modest
consumption of ultra-processed products unlikely and
displacement of fresh or minimally processed foods very
likely. These factors also make ultra-processed products liable
to harm endogenous satiety mechanisms and so promote
energy overconsumption and thus obesity.8,9
The frequently used term competitive market suggests a
wide variety of traders; however, the most powerful
corporate sectors of the world’s food system are in-
creasingly concentrated to the point of oligopoly. For
example, in the USA, the ten largest food companies
control more than half of all food sales.34 Worldwide, this
proportion is about 15% and is rising rapidly. More than
half of global soft drinks are produced by large
transnational companies, mainly Coca-Cola and PepsiCo.
75% of world food sales are of processed foods, whose
largest manufacturers control more than a third of the
global market.32,34–36 The industry body International
Center for Alcohol Policies (ICAP) states that the branded
alcohol market accounted for 38% of global alcohol
consumption in 2005, and the top ten producers
accounted for 66% of the global market share for beer,
59% for spirits, and 16% for wine.18,37 Leading alcohol
transnationals, Diageo, Pernod Ricard, and SAB Miller,
all claim growth in sales in low-income and middle-
income countries in recent annual reports.38–40 For
example, SAB Miller reported earnings growth in 2011 of
33% for Asia, 20% for Africa, and 11% for Latin America
compared with 4% for Europe. The aim of their African
division is for a two-times increase in the opaque (millet)
beer market and a six-times increase in the affordable
Table 2 lists the top five companies responsible for
sales of packaged foods in Brazil, China, India, Mexico,
South Africa, Russia, and the USA. With the exception
of China, there is a high degree of transnational
penetration into the food systems of low-income and
middle-income countries already similar to that in the
USA. For example, Kraft Foods, the main seller of
packaged food in the USA, is responsible for about 6·8%
of all sales in the USA, and Nestlé already has 8·4% of
all packaged food sales in Brazil. An even higher degree
of concentration is evident for sales of specific categories
of ultra-processed products.
To understand the causes of illness in populations, we
need to assess both individual-level and population-level
factors.43 Both supply and demand factors contribute to
the rising population consumption of unhealthy com-
modities.7 On the demand side, as economies grow and
purchasing power of people strengthens, unhealthy
com modities become more affordable; as people have
less time, convenience of these products becomes
important, which enhances consumption. Economic
growth seems to be strongly correlated with rising
consumption of unhealthy commodities, but only when
markets are highly integrated, and therefore enable the
large-scale entry of transnational corporations into low-
income and middle-income countries.42 Additionally, the
systematic and aggressive mass-marketing campaigns of
alcohol, ultra-processed foods and drink, and tobacco
contribute to demand. A contributory factor to supply is
economic policy and trade agreements that open
markets to foreign investment, and provide entry for
tobacco, alcohol, and ultra-processed food and drink
corporations through takeovers of domestic companies.
For example, free-trade agreements with the USA are
associated with high con sumption of fizzy drinks in
several countries.37 De regulation also contributes to
market spread of unhealthy commodities because it
constrains the ability of gov ernments to introduce fiscal
policies to limit their consumption.44,45 These supply and
demand drivers are similar in the tobacco, alcohol, and
ultra-processed food and beverage industries and it is
therefore not surprising
commodities stimulate comple mentary epidemics.
Nationally, there is a strong cor relation between tobacco,
alcohol, and processed food and drink product sales
(figure 2). Where tobacco markets are the greatest, so too
are markets for alcohol and for processed food products.
The relation between tobacco, alcohol, and ultra-
processed food and beverage corporations show the
failure of public health policy makers and professionals
to respond to the effect of unhealthy commodities on
global health, and shows how these industries
undermine public health.
that these unhealthy
Panel 2: EuroMonitor Passport Global Market Information
Data include per-person volumes for packaged foods—including
snacks, snack bars, ice cream, oils and fats, chilled processed
food, dried processed food, canned food, soft drinks, hot drinks,
and ready-to-eat meals—which are all ultra-processed products,
except for oils and fats, which are culinary ingredients. Industry
data for retail sales of tobacco were also obtained from
EuroMonitor. These official market data, as reported by
governments, have similar limitations to other frequently used
macroeconomic data such as gross domestic product and trade
statistics. Additionally, these data capture only sales volumes,
which are imperfect measures of consumption because they do
not include food and drink products produced at home or that
are wasted, or smuggled alcohol and tobacco.
Oil and fats
Snacks and snack bars
Adapted with permission from reference 7.* Tobacco data are in retail sales
Table 1: Annual growth rate (%) of volume consumption per person in
low-income and middle-income countries, and high-income countries
between 1997 and 2009
Strategies by industry to undermine effective
public health policies and programmes
Industry documents released because of tobacco46 and
asbestos20 litigation show how these industries affect
public health legislation and avoid regulation with both
hard power (ie, building financial and institutional
relations) and soft power (ie, influence of culture, ideas,
and cognitions of people, advocates, and scientists). There
is now evidence to show that the food, drink, and alcohol
industries use similar tactics and strategies to the tobacco
companies to undermine public health interventions. We
outline the common strategies that these industries use,
as reported in the disclosure of industry documents
relating to alcohol marketing,47,48 and in reviews of the
similarities between tobacco and food49 and the
similarities between alcohol and tobacco.50,51
The first strategy is to bias research findings. For
example, Philip Morris International implemented the
Whitecoat project to hire doctors to publish ghost-written
confounder studies purporting to negate links between
environmental tobacco smoke and harm.52 The tobacco
companies created quasi-independent organisations to
publish biased and partial scientific reports,53 deny harm,
and suppress health information.46,54 Similarly, funding
from transnational food and beverage corporations
biases research. A meta-analysis of research publications
showed systematic bias from industry funding,53,55 with
articles sponsored exclusively by food and drinks
companies four-times to eight-times more likely to have
conclusions favourable to the financial interests of the
sponsoring company than those that were not sponsored
by food or drinks companies.55 The International Center
for Alcohol Policies, an organisation established and
funded by large global alcohol producers, commissioned
reports from scientists that resemble WHO documents.
These reports were “incomplete, not subject to traditional
peer review, and either supportive of industry positions
or emphasizing high levels of disagreement among
The second stratgey is to co-opt policy makers and
health professionals. To undermine tobacco control
research, the US Tobacco Institute promoted partner-
ships with scientists. They hired researchers and dis-
seminated health promotion strategies to mislead the
public about the harmful effects of smoking. Like the
tobacco industry, the food and drink industry develops
customers as young as possible, using tactics such as
early-childhood health promotion schemes. SAB Miller
BrazilChina India MexicoRussiaSouth Africa USA
Brasil Foods (5·0%) Inner Mongolia Yili (4·7%)
Kraft Foods (3·9%) Kuok Oils & Grains (3·5%)
Unilever (3·3%)Ting Hsin International
Danone (2·8%) Shineway Group (2·9%)
China Mengniu Dairy (4·9%) ????????????????????????????·9%) Grupo Bimbo (9·1%) Wimm-Bill-Dann Foods (4·7%) Tiger Brands (19·5%)
Britannia Industries (5·0%)PepsiCo (5·3%)
Nestlé (4·9%) Nestlé (3·8%)
National Dairy Development
Parle Products (4·8%) Kraft Foods (2·8%)
Kraft Foods (6·8%)
Obiedinenye Konditery (2·3%)
Pioneer Foods (6·3%)
Clover Ltd (4·7%)Grupo Lala (3·6%)
5 Mars (2·1%) Parmalat Group (4·6%)Kellogg (2·7%)
Adapted with permission from reference 42. Percentages refer to proportion of the total market accounted for by each corporation.
Table 2: Top five companies responsible for sales of packaged foods in different countries
2000 200220042006 20082010
Tobacco sales (% change, 2007=1)
Soft–drink sales (% change, 2007=1)
B Soft drinks
Low-income and middle-income countries
Figure 1: Trends in tobacco and soft-drink retail sales
and the International Center for Alcohol Policies have
assisted the Lesotho, Malawi, Uganda, and Bostwana
Governments to write their national alcohol control
policies.57 The four draft National Alcohol Policy
documents were “almost identical in wording and
structure and that they are likely to originate from the
same source”,57 and were designed to “serve the industry’s
interests at the expense of public health by attempting to
enshrine ‘active participation of all levels of the beverage
alcohol industry as a key partner in the policy formulation
and imple mentation process’”.57
The third strategy is to lobby politicians and public
officials to oppose public regulation. Tobacco trans-
nationals lobby policymakers and fund campaigns
of politicians who support tobacco use. The lobbying
power of alcohol and ultra-processed food and drink
cor porations is also substantial. According to US
Senate records, the largest alcohol companies spent
US$150 million lobbying compared with $40 million for
tobacco between 1999 and 2011.58 US Senate Office of
Public Records shows that PepsiCo alone reported
spending more than $9 million in 2009 to lobby the US
Congress.59,60 On the basis of filings with the Federal
Elections Commission, in the 2008 election cycle, the
company’s Political Action Committee so-called Con-
cerned Citizen Fund alone contributed $547 700 to
candidates for federal office.61 Its policy emphasises
contributions to candidates who are “pro-business”, and
who have a “commitment to improving the business
climate” pending the “candidate’s position on key
committees where legislation of importance to PepsiCo
is considered”.62 In another example, the Sugar
Association threatened WHO that it would lobby the US
Government to withdraw its funding because WHO
strategy on diet, physical activity, and health highlighted
a strong link between sugar and NCD risk.63 Several
people from these industries were billed in the official
agenda of the September, 2011 UN high-level meeting on
NCDs as the lead representatives of civil society, and gave
keynote statements designed to guide policies. One was a
former US Ambassador who is now Vice President,
Global Public Policy and Government Affairs, at PepsiCo.
The high-level meeting civil society list also included
representatives from alcohol transnationals such as
Diageo, SAB Miller, and Molson Coors Brewing.64
The fourth strategy is to encourage voters to oppose
public health regulation. For example, the tobacco in-
dustry has, and continues to campaign for, a restricted
role of government, and against taxation and regulation.
Their campaigns emphasise that tobacco use is an
individual responsibility and raise arguments against so-
called nanny state governments.65 Contrastingly, public
health highlights the importance of social, economic,
and political factors, and ethical considerations.43 The
differences between high-risk individual and population
approaches underline the gap between public health
and industry perspectives.66 Similarly, blame-the-victim
cam paigns by transnational food corporations reduce
public support for government interventions.67 As an
alternative to regulatory measures, alcohol and food
industries promote ineffective individually-targeted
information and educational approaches,49,68–72 and
sometimes employ counter-productive
marketing.17,49,72–75 Their social-marketing campaigns place
responsibility for the purchasing decision on the
individual, and in doing so, separate these choices from
the circumstances in which they are made.49,75 The media
regularly emphasise personal choice and responsibility
and convey government inter vention as coercive and
oppressive. Despite the industries’ professed faith in
disclosure of relevant health information to consumers.
From the denial of tobacco addiction as late as 199476 to
the obstruction of traffic-light labelling of unhealthy
food77 and the recent detraction of alcoholic drinks from
EU labelling legislation,78 the tobacco, alcohol, and food
industries have all tried to block access to objective health
information and to manipulate
To deflect criticism, corporations promote actions
outside their areas of expertise. For example, tobacco
corporations promote the prevention of violence against
women79 and ultra-processed food and drink corporations
emphasise physical inactivity.3 Tobacco and alcohol
producers also highlight illegal distribution and
smuggling to deter policy makers from introducing
regulation that will curtail their own activity.80 The
similarities between strategies used by the tobacco,
alcohol, and food and drink corporations are
unsurprising in view of the flow of people, funds, and
approaches, they avoid
0 200 400 6000
Retail sales (constant $US per person, fixed 2011 exchange rates)
500 10000 200400 600
Retail sales (constant $US per person, fixed 2011 echange rates)
Figure 2: Data are from the EuroMonitor industry data 2011 edition32
Each datapoint is one country’s data for the latest available year, 2011.
activities across these industries, which also have
histories of joint ownership—eg, Philip Morris owned
both Kraft and Miller Brewing;81 Altria is a lead
shareholder in tobacco and food companies that have
shared directorships;50 SAB Miller Board includes at
least five past or present tobacco company executives
and board members;40 and the Diageo Executive Director,
responsible for public affairs, spent 17 years in a similar
role at Philip Morris.56 Additionally, tobacco and food
and drink corporations use the same public relations
firms to lobby worldwide82 and to design stakeholder
marketing campaigns such as Pernod Ricard’s drink
Responsib’All Day.39 The alcohol and food and drink63
industries are united in intense opposition to the
development of an equivalent to the WHO Framework
Convention on Tobacco Control. Article 5·3 of this
convention outlines the protection of public health
policies for tobacco control from com mercial and other
vested interests of the tobacco industry and is relevant to
the alcohol and ultra-processed food and drink
industries. The actions of transnational cor porations
have generated such major concerns in the public health
community,83 that there is now an emerging willingness
to address these issues with scientific methods and
Public health responses to unhealthy
What is the most effective way to address the disease
burden caused by unhealthy commodities: voluntary self-
regulation, public–private partnerships, or regulation
and market intervention?
Industry-operated, voluntary self-regulation is the de-
fault approach of many governments and the UN, and
the preferred approach of industry. It is argued that
market forces, driven by informed individual choice,
correct for negative results caused by high consumption
of unhealthy commodities. For example, the UK
Government based much of its initial public health
strategy on nudge theory84 and voluntary action of the
food and alcohol industries with the Public Health
Commission,85 and the Responsibility Deals.86 The UK’s
obesity control policy has been criticised heavily by
British public health experts as a smokescreen for
publicly endorsed mar keting.87,88 A new alcohol strategy89
for England released in March, 2012 is more evidence-
based than the obesity control policy and, as in Scotland,
sets a minimum price per unit of alcohol.
The second model of interaction is public–private
partnership, which is based on the belief that association
with industry leads to greater success than does acting
independently of them. Although the argument against
this approach is clear for tobacco and alcohol, the situation
for the food and drink industries is more complex.
Supporters of this view claim that people need to eat and
drink, that not all processed foods are unhealthy, and that
partnership with industry might lead to reformulation of
some products to less unhealthy compositions. It is
argued that the world’s population will consume more
ultra-processed foods and drinks over the coming decades
than ever before; therefore, a compromise that minimised
their harm might have substantial public health benefit.
Many public–private partnerships exist—eg, the recently
announced 3 year partnership between the International
Diabetes Federation and Nestlé, which was announced in
April, 2012.90 However, there is little objective evidence
that public–private partnerships deliver health benefits,
and many in the public health field argue that they are
just a delaying tactic of the unhealthy commodity
industries.10,91–94 Brownell believes that “when the history
of the world’s attempt to address obesity is written, the
greatest failure may be collaboration with, and
appeasement of, the food industry”.93 Potential benefits
are less apparent and the risks are greater in low-income
countries than in high-income countries (panel 3). The
UN and many national governments presently favour
such partner ships, but definitive outcomes of existing
partnerships need to be independently and objectively
monitored to establish whether they are effective. Another
engagement, which supports so-called round-the-table
interaction with industry to promote evidence-based
policy, the critical appraisal of industry-based approaches,
model is conditional
Panel 3: Product reformulation
A reason frequently given for public–private partnerships with food and drink
corporations—whose profits largely depend on ultra-processed products—is the
encouragement of product reformulation, so that at least some of the products will
contain less trans-fats or less salt.
The case for reformulation is most apparent in high-income countries where markets
might be saturated with ultra-processed products—ie, more than 60% of total energy
intake.33 If the market is saturated, consumers might prefer the new product without
consuming more ultra-processed products—eg, in the USA, sales of sugared soft drinks are
unchanged, and alternatives such as designer water have increased.95 Nonetheless, in such
countries, the main emphasis on and support of national governments and the public
health community should be promotion of healthy meals, dishes, and foods.
Discussions about product reformulation, with or without public–private partnerships,
have focused on risks and benefits in high-income countries. However, in low-income
countries, benefits are less obvious, and the dangers are very apparent. In such countries,
consumption of ultra-processed products is low. These countries are therefore the prime
targets of transnational corporations. If they reformulate, advertise, and promote some
of their less unhealthy products as healthy—eg, sodium-reduced (but still high energy-
dense) packaged snacks or artificially sweetened (but still nutrient-devoid) soft drinks—
the overall consumption of ultra-processed products is likely to increase, which would
undermine long-established dietary patterns based on fresh or minimally processed
foods. In low-income countries, the reformulation of ultra-processed food and drink
products is similar to the tactics of the tobacco industry in introduction of filtered
cigarettes and low-tar cigarettes.
The reformulation approach is a damage-limitation exercise,6 to avoid evidence-based
approaches such as the restriction of availability and of advertising, and pricing policies
designed to promote healthy food, such as now being undertaken by order of the Mayor
and municipal authorities of New York City.96
and the establishment and independent observation of
objectives and outcomes. A concern is that public–private
part nerships are simply a means for industry to co-opt
The third model of interaction is public regulation,
which specifically recognises the conflicts of interest
between promotion and protection of public health and
the corporations that profit from unhealthy commodities.
Because growth in sales, turnover, and profit12 are the
main goals of transnational corporations, supporters of
public regulation believe that self-regulation and working
from within are ineffective and counter productive.7 Most
advocate statutory regulations, analogous to those used to
control firearms, road traffic, drugs and tobacco, and to
protect parks, forests, and open spaces. Public regulation
is a model of very active critical analysis that can be
achieved in three ways. First, by galvanisation of an
evidence-based constituency that implements effective
and low-cost policies by making apparent the need for
regulation and market interven tion. Second, directly
pressuring industry to change by making harmful
practices obvious. Third, by raising of public awareness of
the negative actions of these industries—an approach
that is effective in changing the behaviour of the tobacco
industry. To make the regulation of tobacco, alcohol, salt,
sugar, and trans-fats politically feasible in most countries,
constant active public pressure is needed.
The case for public regulation
On the basis of evidence and experience so far, the tobacco
industry is ruled out of any interaction with public health
policy makers, researchers, and practi tioners, other than
what is consistent with the Framework Convention on
Tobacco Control. Guidelines for implementation of article
5·3 of the Convention state that the “parties should
interact with the tobacco industry only when and to the
extent strictly necessary to enable them to effectively
regulate the tobacco industry and tobacco products”.97 No
plausible rationale exists for action by public health
interests with alcohol and ultra-processed food and drink
industries, except when action is driven by the threat of
government regulation, such as the UK partnership on
salt reduction.98,99 However, a similar partnership in
Australia has not yet resulted in reduced salt consumption
because the companies implicated do not profit from the
process, and there is no threat of regulation or sanctions.100
Engagement with industry needs to generate profit, but
legitimate mechanisms through which public health
institutions and profes sionals could contribute to
increasing industry profits are hard to identify. To promote
health, the food and drink industries need to move
consumption patterns away from ultra-processed food
and drink products; however, these products are more
profitable than less-energy-dense, nutrient-rich foods. In
the alcohol industry, sales and profits are dependent on
many consumers drinking at risky quantities. As Coca-
Cola states, “increasing public concern about these issues;
possible new taxes and governmental regulations
concerning the marketing, labelling or availability of our
beverages; and negative publicity resulting from actual or
threatened legal actions against us or other companies in
our industry relating to the marketing, labelling, or sale of
sugar-sweetened beverages may reduce demand for our
beverages, which could affect our profitability”.101 Thus,
industry maintains profit only if it undermines attempts
to tax and regulate, or if people who consume more
healthy commodities continue to consume profit able, but
unhealthy commodities;7 neither is desirable from a health
The precautionary principle argues against public–
private partnership because there is no evidence that
the partnership of alcohol and ultra-processed food and
drink industries is safe or effective, unless driven by the
threat of government regulation.49,93 Similarly, there is little
evidence that self-regulatory
effective.56.75–78,102–104 For example, the so-called voluntary
decision by Kraft to ban trans-fats was a result of threatened
litigation.102 Furthermore, legislation for clean air,105
asbestos,106 road trauma,30 and tobacco86 was intro duced
Panel 4: Recommendations of action for non-communicable diseases
For public health policy making, research, and programmes
international policy for non-communicable diseases
recommendations of the Framework Convention on Tobacco Control
and have a clear goal of the use of evidence-based approaches by government
private–public partnership in alcohol, food, and drink industry, rigorous, timely, and
independent assessment is needed to show that they can improve health and profit
For public health professionals, institutions, and civil society
for change to implement effective and low-cost policies, to place direct pressure on
industry to change, and to raise public awareness of the unhealthy effects of these
accepted from the tobacco, alcohol, and ultra-processed food and drinks industries or
their affiliates and associates
For governments and international intergovernmental agencies
restriction of advertising and sponsorship should be introduced to reduce death and
disability from non-communicable diseases
For governments, foundations, and other funding agencies
self-regulation, public–private partnerships, legislation, pricing, and other regulatory
interventions should be accelerated and prioritised
corporations that drive them, should be developed
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only after the repeated failures of the industries responsible
for solving these problems through self-regulation. The
argument against self-regulation is that even if some
progressive food and alcohol companies use healthier
approaches, the gap in the market would be filled by
others. Another counter argument is that ill-conceived
partnerships with industry can lead to procrastination and
delay—a standard industry tactic to avoid regulation.
We believe that civil society should be aligned with
government, which has the responsibility and power to
protect public health, although compromised by trans-
national corporations. To fulfil this aim, governments
need information and support from civil society and from
public health interests. Regulation, or the threat of
government regulation, is the only way to change
transnational corporations; therefore, the audience for
public health is government and not industry. Dis-
cussions with unhealthy commodity industries will be
helpful only if they are with government and if the goal is
for government to use evidence-based approaches. To
respond to the scale and urgency of the global NCD
epidemics, the industrial drivers that underpin them, and
the tactics used by the unhealthy commodity industries
so far, we have ten recommendations for action (panel 4).
NS provided the original concept of the paper. RM and DS steered the
paper. All authors contributed to each draft of the paper, with special
contribution on food and drink industries by CM, DS, BN, and PL; and
on the alcohol industry from NS, SC, DS, and TT.
Conflicts of interest
BN is the Chair of the Australian Division of World Action on Salt and
Health (2007–ongoing). He has consulted to Roche (2010) and Takeda
(2010). He has received lecture fees, travel fees, or reimbursements from
Abbott (2012), Amgen (2007), AstraZeneca (2010), GeorgeClinical (2012),
GlaxoSmithKline (2007), Novartis (2012), PepsiCo (2011), Pfizer (2011),
Pharmacy Guild of Australia (2012), Roche (2012), Sanofi-Aventis (2006),
Servier (2008), and Tanabe (2007). He holds research support from the
Australian Food and Grocery Council (2012), Bupa Australia (2012),
Johnson and Johnson (2012), Merck Schering Plough (2011), Roche
(2012), Servier (2012), and United Healthcare Group (2012). He is not
employed by a commercial entity; has no equity ownership or stock
options, patents, or royalties; and has no other financial or non-financial
support that might be viewed as creating potential conflicts of interest.
NS is co-chair of the UK Government Responsibility Deal network,
trustee of the Drinkaware Trust, member of the EU Alcohol and Health
Forum, and was a member of the Public Health Commission—all
bodies with alcohol industry representation. NS is also a member of the
Alcohol Health Alliance UK executive board, Royal College of Physicians’
alcohol committee, and is involved in other health NGOs including
Alcohol Concern. None of these commitments included financial gain
but some have reimbursed travelling expenses.
BN is supported by an Australian Research Council Future Fellowship.
CM acknowledges discussions with and suggestions from Geoffrey
Cannon and other colleagues at the Centre for Epidemiological Studies
in Health and Nutrition at the University of Sao Paulo, Brazil. The
authors would like to acknowledge the assistance of Robert Beaglehole
and Ruth Bonita in the preparation of this paper.
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