Very recently, Big Alcohol – Brewers of Europe, Spirits Europe and a media agency – has been attacking two of our member organisations in Europe – IOGT-NTO and UNF – as well as our close partner (our European youth platform) Active – sobriety, friendship and peace – which gathers all our European members that are youth organisations.

What did they do to deserve the scorn of Big Alcohol?
They publicly announced to leave the European Alcohol and Health Forum (EAHF), critiquing the results of the EAHF, the processes within it when it comes to Big Alcohol performance and the EAHF’s overall impact on alcohol harm in Europe (or the lack thereof).

I have worked for many years with alcohol policy advocacy in Europe and the European Union, meeting high-level decision-makers within the European Commission and the European Parliament and bringing some of them to events we conducted back then. In all those years, the global alcohol industry has posed a paramount obstacle to the development and implementation of evidence-based, high-impact alcohol policy measures. Having on mind the recent development and discussions in European alcohol policy, I want to share some of my opinions and experiences.

Let me start by briefly reminding you that we, as IOGT International, strongly supported the Statement of concern by the united, global public health community reacting to Big Alcohol tactics.

What the global alcohol industry did then and what it still does – as recent examples in Europe show – is to misrepresent its role in relation to the WHO Global Alcohol Strategy, in that the WHO Global Alcohol Strategy gave Big Alcohol no authority to engage in public health activities on behalf of WHO or the public health community. Based on the track record of the global alcohol producers and their social aspect organizations during the past five years, we expressed major reservations about their stated commitments to reduce underage alcohol use, strengthen self-regulatory marketing codes, reduce driving under the influence, act responsibly in the area of product innovation, and encourage retailers to reduce harmful alcohol use.

To cut a long story short, Big Alcohol uses the same or very similar tactics like Big Tobacco and has thus accumulated a track record all over the world that speaks for itself. Check out our booklet of examples and evidence for violations of ethics and Human Rights.

Arguably, this is nothing new. This conflict of interest between public health, development, Human Rights on the one side and thirst for ever more profits and higher alcohol use on the other has pitted Big Alcohol against evidence-based alcohol policy measure since forever.

It’s for this reason that the EAHF never really seemed like a good idea, why civil society has only joined it with huge stomach ache, and why IOGT International chose to stay away and why a number of NGOs now pulled the emergency break and left again.

And additional to those moral reasons, there is also a very practical one: Big Alcohol actually does not need the EAHF at all because they have a myriad of entry points to advance their interests through aggressive lobbying. The EU and Brussels is a bonanza for Big Alcohol.

The tip of the iceberg

Check out this mind map of entry points for aggressive and extremely well-funded Big Alcohol lobbyism targeted at EU institutions and decision-makers.

Unlimited access for Big Alcohol - lobbying entry points to EU

Unlimited access for Big Alcohol – lobbying entry points to EU

Much could and should be said about this map and the different aspects of it need be explored in detail. I leave that to another blog entry however. I think to look at this map is scary because civil society does not have this power, these entry points and does not find these open doors.

We created this mind map in collaboration with colleagues of IOGT-NTO and please note: it just shows a snapshot, the tip of the iceberg. This is not the full picture because we do not (and cannot) show you the multiple law firms and consultancy firms that Big Alcohol hires to work on their behalf. We do not and cannot show the details of every single country – so we focus mainly on the UK.

And we cannot show all the organisations and corporations that are behind the conglomerates shown above. Just to give you a taste, check out the structure of ICAP, the International Center for Alcohol Policy.

ICAP_mindmap

And just two more examples of the entanglement of Big Alcohol with decision-makers in Brussels:

We wrote about it earlier this year, that European Commissioner for Trade, De Gucht, is owning a million Euro stake in an alcohol company.

Screenshot 2015-12-04 12.04.39The former Chair of the European Alcohol and Health Forum, Despina Spanou, who I have met a couple of times and who always talked to me about Big Alcohol, like she was advertising for them, was employed by the law firm Cleary Gottlieb before she joined the European Commission.

Cleary Gottlieb has been working for Heineken (2013, 2010), SAB Miller (2012) and Diageo (2011) and has also been dealing with media, advertising and sponsoring cases for corporations.

I am not making any allegations for either of the examples. The examples serve to illustrate some challenges when it comes to EU democracy and policy-making in the best interest of the people. And they should inform how civil society works within the EU.

Refuting some claims by Big Alcohol

Civil society is in a losing position when it comes to entry points for lobbying, access to decision-makers and even access to the media. That’s true for Brussels as it is true for Washington D.C. and any other major hub for politics. That’s why we need accountability, transparency, openness – the virtues of democracy.

The EAHF has been used by Big Alcohol to delay, to question independent research and evidence and to promote research they have paid themselves (see ICAP, above) as well as to market themselves as if they cared about public health, about the suffering and harm their products cause.

You can see that easily by looking at the programs of the meetings: they were almost all largely occupied by Big Alcohol. And they used the time to make often questionable and sometimes outrages claims, like they did in the articles and press releases of recently.

So, allow me the chance to address some issues (also check out this resource for Busting Big Alcohol myths)

The director general of Spirits Europe writes: “No. Consumption per se is not the problem – behaviour is.”
The fact is: alcohol is on par with asbestos when it comes to causing cancer. We know today that there is no safe amount of alcohol consumption concerning cancer risk.

He goes on to claim: “Indeed, we would argue that it is directly in our commercial interests to eradicate all harms, and promote healthier, longer lives for all our consumers.”
The fact is: More than 80% of girls made to sell alcohol in Cambodia (“beer girls”) are exposed to unwanted, forced sexual contact. Human Rights violations and health hazards are part of the alcohol trade. The fact is: alcohol is not an ordinary consumer commodity. It is toxic, carcinogenic, teratogenic and addictive – especially for children and young people. And yet Big Alcohol keeps targeting children and young people with the marketing, and does so deliberately.

The facts is, too: Diageo, the world’s largest producer of liquor is targeting youth and has recently admitted this.
I remember, when Active and UNF tested a commitment made by Diageo in the EAHF in 2011: The City of Copenhagen was running a project called “tryg den af” (“Have fun. Be safe”) together with Diageo. UNF had thus sent some 15-year old mystery shoppers to test a total of 9 bars and pubs in the city of Copenhagen. They were allowed into 7 of those bars and they were able to buy strong alcohol all the 11 times they tried without any problems. 4 out of these 7 bars were part of the above mentioned project. Diageo targets youth and wants young people to start using alcohol as early as possible. It’s an investment into their future profits because independent evidence shows that the earlier a person starts using alcohol, the more they use later on in life.

He also chooses to write this: “Alcohol harm is not a straightforward issue. If it were, the problems would have been solved long ago by clever policy-makers, by concerned health practitioners, and by the drinks sector itself.”
The fact is: Big Alcohol keeps lobbying against evidence-based alcohol policy measures wherever possible and very aggressively. We can see this in South Africa, we’ve seen this in Lithuania and we know this from the entire policy area of international trade. The fact is: alcohol harm is complex because it is so widespread and pervasive. But much of it is actually preventable. We could prevent alcohol harm, if Big Alcohol would not deploy its resources (see above) in whatever way to oppose, obstruct and stop evidence-based, high-impact measures.

And this quote makes his article ridiculous: “Some anti-alcohol activists push one-size-fits-all solutions…” The fact is: ICAP has been trying to suggest “tailor-made” (as they claimed) alcohol policies to a number sub-Saharan countries. Examination showed, however, they were the same for every country and originated from one Word document of an ICAP consultant.

The director of corporate affairs at Media Intelligence Partners (MIP) writes: “Regrettably, cynical members of the NGO lobby appear to be preparing for the debate by trying to silence industry figures from participating in future discussions.” First of all: MIP earns money from the global alcohol industry. They also work with Big Pharma, Big Financial, TV broadcasters and the arms industry. As far as I can tell, that is not exactly a who is who of moral respectability. Concerning his statement, the fact is:  In a comment to an article in the British Medical Journal on 11 April 2013, Dr. Chan stated that the WHO global alcohol strategy stipulates that “member states have a primary responsibility for formulating, implementing, monitoring and evaluating public policies to reduce the harmful use of alcohol. The development of alcohol policies is the sole prerogative of national authorities. In the view of WHO, the alcohol industry has no role in the formulation of alcohol policies, which must be protected from distortion by commercial or vested interests.”

He continued to write about the EAHF: “In order to be a member of the forum, participants had to pledge to step up actions to reduce alcohol related harm.” The fact is that Big Alcohol has not been stepping up action in the sense that they implemented evidence-based actions. They committed to actions that would allow them to market themselves, target young people and not jeopardise any of their profits by reducing alcohol consumption.

He actually admits that himself by writing: “The most successful method to effectively change risky alcohol consumption is through media communications.” I ask myself, why would a person working in media recommend media communications as the most effective way? Obviously he is in a conflict of interest.

The fact is: independent research shows that education campaigns, media campaigns are largely ineffective in changing behaviour and reducing and preventing alcohol harm. Often they are outright counterproductive – as a recent presentation at the World health Summit showed.

Boomerang effect of media campaigns to educate about "harmful drinking"

Boomerang effect of media campaigns to educate about “harmful drinking”

There is a whole body of research that simply falsifies his following statement: “The public will not listen if dictated to about alcohol issues – they welcome education.” As explained above, this is not the case.

His troublesome relationship with what is actual, independent evidence and what is industry-made, and industry-paid evidence continues, as he writes: “Many of the policies advocated by Active are extreme in content and relatively light on evidence. Furthermore, they are expensive and when expense is compared to overall success in reducing risky behaviour, such policies are not cost effective.”
The fact is: Active’s alcohol policy paper addresses first and foremost alcohol marketing, alcohol affordability and alcohol availability. Labelling is just a minor part in it. Those three areas are recognised by World Economic Forum, the World Bank and the WHO, as the “three best buys” to prevent and reduce alcohol harm. They are high-impact and cost-effective. It is logic: increasing taxes on alcohol brings more revenue to the state and reduces the costs caused by alcohol harm.

The fact is: Active’s alcohol policy paper has been discussed with the European Commission multiple times in high-level meetings, and especially in a meeting with the chair of the EAHF after Active had joined the EAHF. The entire content of the policy program is evidence based and rooted in WHO data, the data from the report commissioned by DG Sanco “Alcohol in Europe”, and the landmark book “Alcohol. No Ordinary Commodity”. The policy programme is in line with the EU council conclusions taken over the years in the European Union and it is in line with the WHO Global Alcohol Strategy.

He goes on to call on the European Commission and misrepresents the scope of the European Youth Forum, Active, UNF and IOGT-NTO: “The European Commission must not be influenced by these devious attempts by a minority of NGOs to stifle debate on such an important issue.”
The fact is: Active has 25.000 members, the IOGT-NTO movement in Sweden has approximately 60.000 members and the European Youth Forum is representing 99 youth organisations from all over Europe. I am sure any parliamentarian would welcome their support running for election.

And finally he contradicts himself once more by demanding: “We need sensible debate from all sides of the argument.” The fact is: Using words like “cynical”, “devious” and “savage” doesn’t show a commitment to “sensible debate”. Reading the press release of YFJ, Active, UNF and IOGT-NTO I didn’t find any trace of this type of language. A debate is not possible if actors like MIP are unwilling to use independent evidence, and instead choose to make false claims all the time. But his text is (sadly) a good indication of what it is like in the European Alcohol and Health Forum.

The brewers of Europe also felt compelled to comment and issued a press release through their communications senior advisor. He says among other things: “As we all know, excessive alcohol consumption carries a health risk, and we must work together to address this.”

The fact is: All alcohol use carries risks and there is no safe amount of alcohol consumption. It’s not just “excessive” consumption.

Just to make this evidence of alcohol’s inherent risk to get cancer graphic for you, please take a look at this video:

He also counts the quantity of commitments to the EAHF: “…brewers have made over 100 of the total 250 commitments to the Forum.”
The fact is: The large bulk of the so called commitments belong into the categories of action proven to be most ineffective in preventing and reducing alcohol harm.

He then invokes Mr Barroso: “European Commission President Barroso praised the Brewers’ pan-European Forum commitment on beer advertising, saying, “I would like to commend the efforts of your sector to introduce self-regulation to promote responsible beer advertising across Europe. […] Own-initiatives like this and pro-active involvement of industry representations are an excellent example of industry working with regulators to make legislation truly smart. In the same vein, I commend your action and commitment to addressing alcohol-related harm.
First of all: the European Commission has a mandate to protect and promote the welfare of the people of the European Union. It is supposed to be the guardian of the public good. Nowhere in his speech did Mr Barroso mention alcohol harm, the number of children of alcoholics, the numbers of alcohol-related violence, the costs of such harm to the EU and the people living in Europe. And he got vast criticism for it.

The fact is: Mr. Barroso is no expert in alcohol policy and doesn’t understand the burden that alcohol harm is putting on Europe and its people. He did not come even close to mention alcohol in his speech at the World Health Summit earlier this autumn.
The fact is: Self-regulation does not work. A UK parliamentary committee found that the alcohol industry is systematically violating its own codes of conduct.

He continues by explaining what he thinks action is and is not: “While Eurocare’s call for action is welcome, the choice of some organisations to leave the Forum does not seem compatible with ‘action’. Similarly, the choice of some to oppose any partnerships with the brewing sector is not ‘action’. And bemoaning the presence of economic operators in the Forum is not ‘action’.”
The fact is: What Big Alcohol does as its core business, what they earn money from, what pays Mr. Spillane’s salary and the huge bonuses to the CEOs are operations that cause alcohol harm in the first place. Any commitment in a European Health Forum, or wherever else in the world, is just a minor dent in the universe of Big Alcohol. In stark contrast to this, all civil society organisations in the health promotion field are doing, is to prevent and reduce alcohol harm, to create environments for young people where they can thrive, to give them opportunities to participate in society as active citizens and influence policy decisions in democratic ways. This is a contrast between profit-driven and heart-driven.
So, it’s a self-defeating point to talk about who takes action and who doesn’t. Just compare what civil society organisations do to tackle alcohol harm – and many of them are not member of the EAHF – with what Big Alcohol is doing day in and day out and it cannot become more obvious.

Eventually he then moves on to advertising for the Brewers of Europe in writing they “demonstrate our commitment through dialogue, partnership – and above all – action. It’s what citizens and policymakers expect.”
The fact is: Beer producers often take action that are contradictory to what citizens expect. The Eurobarometer shows that 2/3 of EU citizens think alcohol advertising targeting youth should be banned.

Citizens are also angry and upset about the fact that the Heineken Group has been paying rebel groups and government troops in Congo over years to be able to increase beer sales, fuelling bloodshed and war for profit.
Citizens are also angry and upset that beer producers in Germany seem to illegally rig prices. And the fact is: What some decision-makers expect is clear – regulation of Big Alcohol, transparency and a mandatory registration for their aggressive lobbyism “actions”, and the implementation of evidence-based alcohol policies that protect children and young people, that protect women and girls, that reduce and prevent alcohol harm.
“Actions” that other decision-makers in the EU expect are also clear: free beer and goody bags from the Brewers of Europe. And that brings me back to the map above about the vast, aggressive lobbyism actions – one tool is the European Parliament Beer Club.

But why does Big Alcohol make all this fuss, feel the need to come out attacking a small “minority”?

Their concerted move, a move across the industry, contradicts what they are saying. They say it’s just a minority of NGOs. Why do they feel the need to address this little, “devious”, “savage” minority?
The reason is: their stage and platform is threatened. Big Alcohol does not need the European Alcohol and Health Forum to speak to decision-makers. They have all the channels that we revealed above for their aggressive lobbyism. They, too, could make commitments without any forum – like so many civil society organisations are doing every day.

The only reason they need the EAHF is legitimacy and credibility. They know they do not have it on their own and they need such a platform to be able to claim their spot in processes where they do not belong. And now they feel this platform threatened, see their legitimacy disappearing.

The crucial question going forward is this: Is the civil society community willing to keep giving Big Alcohol this legitimacy? Civil society can take it easily by walking away from the EAHF and demanding a revamping and a forum free from Big Alcohol. But civil society can also choose to contradict its own statements of concern about conflict of interest and remain part of dysfunctional forum that has only benefited Big Alcohol.

What does all this add up to?

Big Alcohol is in a losing position when it comes to evidence about alcohol harm and about measures that prevent and reduce it. Civil society is in a losing position when it comes to entry points and access to decision-makers.

It also means, we as civil society need to be smart about how we conduct our advocacy work, about where we deploy our resources. The European Alcohol and Health Forum is a sad example for how civil society kept playing a losing game. As we sat there, listening to Big Alcohol bragging about ineffective measures, about self-regulation which they violate systematically themselves, their hired consultants, law firms, paid employees of branch organisations – the whole bunch as depicted above – kept on aggressively lobbying, making their case in ways we can hardly imagine and will never know about.

Civil society in Europe needs to learn the lesson from the successful and inspiring work of NGOs in the field of tobacco control. Like Big Tobacco, the global alcohol industry simply has no role to play in public health policy making and thus vehicles like the European Alcohol and Health Forum are not the way forward.

The EAHF has been used by Big Alcohol to delay processes, to question independent science and to promote research they have paid themselves (see ICAP, above) and to market themselves as if they cared about public health, about the suffering and harm their products cause. Civil society should not be part of offering a stage to Big Alcohol.

Just look at the stuff the director of corporate affairs at Media Intelligence Partners (MIP) claimed about labelling. It’s one of the few issues where the EAHF seemed to achieve some progress as some among Big Alcohol introduced warning labels and some NGOs advocate for the issue and the European Commission supported those initiatives.

The EAHF has not been instrumental in getting a new, updated, improved EU Alcohol Strategy. Instead DG Sanco is proposing a limited Action Plan that is not equipped to tackle alcohol harm in a comprehensive way, right from the start. What are the reasons that civil society continues to support a forum that has not delivered what it promised because the global alcohol industry hijacked it?

We all supported the statement of concern which has garnered support from more than 1000 health professionals, NGOs and independent researchers. We said this spring:

As an independent coalition of public health professionals, health scientists and NGO representatives, we are submitting this public Statement of Concern to the WHO Secretariat in response to the activities of the global alcohol producers. Based on their lack of support for effective alcohol policies, misinterpretation of the Global Strategy’s provisions, and their lobbying against effective public health measures, we believe that the alcohol industry’s inappropriate commitments must be met with a united response from global health community.

Our reservations can be summarised as follows:

  1. The commitments are based on questionable assumptions, as stated in the signatories’ Preamble.
  2. The actions proposed … are weak, rarely evidence-based and are unlikely to reduce harmful alcohol use.
  3. Prior initiatives advanced by the alcohol industry as contributions to the WHO Global Strategy have major limitations from a public health perspective.
  4. The signatories [global alcohol industry] are misrepresenting their roles with respect to the implementation of the WHO Global Strategy. “

Just replace “WHO” with “EU” and we describe the situation in Europe, within the EAHF – because the actors are the same. Why would they act differently on global level, than on European level.

It is clear, after observing alcohol policy in Europe, after having written and done the research for this text: if the EAHF is not revamped and Big Alcohol excluded, there will not be change. The bonanza for Big Alcohol will continue.

Unless civil society seizes the momentum now. All the know-how is available and all the evidence and principles are in place: the WHO Alcohol Strategy, the WHO Global NCDs Action Plan, the WHO Mental Health Global Action Plan, the WHO Europe Alcohol Action Plan, the statement of concern, the WHO principle of Big Alcohol’s non-role in public health policy-making, the lessons learnt from the success of the tobacco control work. We know what works and what doesn’t.

We should use that knowledge to bring the Big Alcohol bonanza in the EU to a halt and pave the way towards the implementation of effective, high-impact alcohol policy measures.

For more information, all the evidence that is the background for this text’s arguments:

Amphora Project and alcohol harm in Europe

Finding: EU alcohol users consume more than 600 times the exposure level set by the European Food Safety Authority for genotoxic carcinogens, of which ethanol is one.

Ethanol is a carcinogen, a teratogen and toxic to many body organs. Using the European Food Safety Authority guidance on risky exposure for human consumption of toxic substances in food and drink products, European alcohol users consume more than 600 times the exposure level for genotoxic carcinogens, which is set at 50 milligrams alcohol per day; and more than 100 times the exposure level for non-carcinogenic toxins, which is set at 0.3 grams alcohol per day (1, 2). [The average consumption of the 89% of EU citizens who drink alcohol is just over 30g/day].

Alcohol and cancer

It is the ethanol within alcohol that is carcinogenic and it is impossible to differentiate between different risks associated with different alcohol.

The Global Burden of Disease: Generating Evidence, Guiding Policy

Report: Alcohol in Europe. A public health perspective

WHO Europe Alcohol Action Plan

Overview of most cost-effective and high-impact alcohol policy measures, as outlined by Babor et. al. in “Alcohol. No ordinary commodity

The WHO Global Alcohol Strategy, its guidelines and policy recommendations

NCDs Global Action Plan 2013 – 2020

WHO Global Mental Health Action Plan 2013 – 2020

The 3 Best Buys to prevent and reduce alcohol harm

World Economic Forum and Harvard School of Public Health: Global Economic Burden of NCDs (alcohol, as one of four major risk factors is mentioned at least 30 times)

World Bank: Marquez, P. V., Farrington, J. L. (2013) “The Challenge of Non-Communicable Diseases and Road Traffic Injuries in Sub-Saharan Africa. An Overview”. Washington, DC.: The World Bank. (alcohol is mentioned 82 times)

More on cost-effective and high-impact alcohol policy measures

Criticism of Barosso: “Barroso promotes special interests instead of welfare of young Europeans”

BMJ: Doctors and the alcohol industry: an unhealthy mix?

Letter in reply to BMJ feature on the alcohol industry from WHO DG, Dr. Margaret Chan

Global Fund needs to address conflict of interest, by Anna B Gilmore and Gary Fooks

Conflict of interest in the alcoholic drinks industry: How much alcohol consumption do “unhealthy drinkers” account for in the UK, 2000-2001, by Baumberg, Ben, London School of Economics and Political Science

Addiction Journal: The alcohol industry has a conflict of interest in alcohol research and policy, by Colin Drummond

Addiction Journal: Alcohol research and the alcoholic beverage industry: issues, concerns and conflicts of interest, by Thomas F. Babor

Self-regulation failure

Scientific article by Øystein Bakke and Dag Endal: The failure of self-regulation Vested Interests in Addiction Research and Policy. Alcohol policies out of context: drinks industry supplanting government role in alcohol policies in sub-Saharan Africa

Diageo targeting young people with alcohol products

Big Alcohol’s self regulation of advertising does not work: Alcohol companies do not abide with their own codes of conduct, according to a new review of alcohol advertising in the UK. The industry still promotes alcohol to young people, according to a report presented in the British Medical Journal.

AMMIE project (Alcohol Monitoring Marketing in Europe)

The project is co-financed by the European Commission and coordinated by the Dutch Institute for Alcohol Policy (STAP). The research has been implemented in Bulgaria, Denmark, Germany, Italy and the Netherlands in cooperation with the John Hopkins Bloomberg School for Public Health in the US.
Unique shocking data about the exposure of alcohol commercials to young people
The AMMIE project shows that a minor in the five participating countries was exposed 970 times to an alcohol commercial during the months May and October 2010 via three popular TV channels. In Bulgaria, a minor was exposed 36 million times, in Denmark 10 million times, in Germany 610 million times, in Italy 54 million times and in the Netherlands 54 million times.
Vulnerable young people are often more intensively confronted with alcohol marketing via TV than adults
During the two months of the study a total number of 11.122 alcohol commercials were broadcasted in the five participating countries. Analysis of the AMMIE project data showed that often relatively more young people were exposed to alcohol marketing than adults. As an example: in the Netherlands 27% of all the commercials were relatively seen by more young people of 12-17 years of age (compared to the total number of young people of this age group) than by adults. The conclusion is that young people of 12-17 years of age are often exposed to huge numbers of alcohol ads.Especially the age group of 12-17 is very sensitive for the impact of alcohol marketing. Many of these young people start to experiment with alcohol use.
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