Tobacco, alcohol, food: the same tactics to weaken public health policies

In a report published on September 15, 2026, the NCD Alliance Scotland, a coalition of 26 Scottish health organizations, analyzes how the tobacco, alcohol, and high-fat, high-sugar, and high-salt food industries manage to delay, weaken, or block public health policies. Entitled "Health Under Influence," the report identifies eight tactics shared by these three sectors, ranging from challenging scientific evidence and funding favorable research to legal threats, corporate social responsibility initiatives, the use of third-party spokespeople, and lobbying elected officials. The authors note that these strategies, long used by the tobacco industry, are now being replicated almost identically by alcohol and ultra-processed food producers. They call on the Scottish Parliament to extend the transparency and governance rules inspired by Article 5.3 of the WHO Framework Convention on Tobacco Control to all these industries.[1].

A largely avoidable health burden

The report notes that Scotland currently has the lowest life expectancy in Western Europe. Non-communicable diseases, including cardiovascular disease, cancer, type 2 diabetes, chronic kidney disease, dementia, and respiratory illnesses, cause approximately 55,000 deaths annually, representing 88% of all deaths. According to an analysis by the British Heart Foundation based on data from Scottish national registries, nearly 9,000 of these deaths, or about one in six, could be prevented through public health measures. Social inequality significantly impacts this record: residents of the most deprived areas live approximately 25 fewer years in good health than those in the most affluent areas.

The NCD Alliance Scotland frames its analysis within the context of the commercial determinants of health. It explicitly targets large commercial players, most often multinational corporations, whose business model relies on the production or sale of products harmful to health, which it clearly distinguishes from small businesses. This approach aligns with Scottish public opinion: according to a survey conducted by members of the coalition, 70% of Scots believe that the influence of these industries on government decisions is detrimental to public health, a majority consider it inappropriate for them to have direct access to ministers and members of parliament, and only 2% of respondents trust representatives of these industries to influence health decisions.

A common repertoire of interference tactics

The core of the report rests on a framework of eight tactics, taken from the British report Killer Tactics published in 2024 by the Obesity Health Alliance, the Alcohol Health Alliance, and Action on Smoking and Health.[2]. For each of them, the authors present Scottish examples taken from the three sectors, and it is precisely this juxtaposition that reveals the unity of method between seemingly distinct industries.

The first tactic involves contesting or minimizing the scientific evidence demonstrating the harmful effects of these products and industrial practices. Before the Scottish Parliament, the representative of the vaping industry argued that flavorings played no role in youth vaping, while the alcohol producers' organization asserted that advertising had no effect on consumption, contrary to numerous independent studies that rigorously establish the opposite. These same actors readily present themselves as partners of public authorities, promoting messages of "responsible consumption" that place the responsibility on the consumer rather than on the product manufacturer and its associated marketing. The report recalls that the tobacco industry pioneered this approach as early as the 1950s regarding the risks of active smoking, and then again in the 1980s concerning passive smoking, by funding research designed to sow doubt about the dangers. This challenge to independent research and the funding of biased research, known as "junk science," continues today: Coca-Cola funded a network of researchers tasked with attributing obesity to lack of exercise rather than sugary drinks, and an alcohol education program funded by Diageo (a British company specializing in alcoholic beverages) is being disseminated in Scottish high schools without any mandate from health authorities.

When a measure does progress despite opposition, industry players seek to delay it through legal means. Tobacco companies threatened the Scottish government with up to £11 billion in damages to prevent the implementation of plain packaging. These threats were unsuccessful, but they delayed the measure for several years. The minimum price for alcohol, passed in 2012, only came into effect in 2018, after six years of legal action initiated by the Scotch Whisky Association, even though its effectiveness on consumption and mortality has since been confirmed. The report also describes how these industries buy respectability and access to decision-makers: sponsorship of festivals by the e-cigarette manufacturer ELFBAR, Coca-Cola's partnership with the Glasgow 2026 Commonwealth Games, and funding of organizations presented as independent, such as Drinkaware, which is supported by more than 130 players in the alcohol industry. In the 2000s, tobacco manufacturers fought the law on smoke-free places by hiding behind restaurant owners' organizations and pseudo-groups dedicated to "smokers' rights." Today, major manufacturers are using federations of small businesses to voice their arguments, which carry more weight with elected officials.

Alcohol and food: measures delayed or stripped of their substance

Two case studies conducted at the University of Stirling provide concrete examples of the effects of these tactics. Regarding the ban on alcohol advertising, the Scottish government launched a public consultation in 2022-2023 and collected nearly 3,000 responses. Among these, 585 identical responses, drafted using a template distributed by brewers' and pubs' associations, gave the impression of a much more divided public opinion than it actually was. Although Public Health Scotland recommended full restrictions in September 2025, the government again postponed any decision in March 2026, deferring the issue until after the elections. Meanwhile, industry representatives met with ministers more frequently than public health officials.

The second example concerns the regulation of promotions on products that are too fatty, too sugary, or too salty. Between 2017 and 2024, four successive consultations were held, and at each stage, the initial proposals were weakened: the framework for discounted menus, temporary promotions, and takeaway food was reduced or abandoned before the legislation was adopted, which will come into force on October 1, 2026. Food and retail federations consistently presented these measures in terms of their cost to businesses and the need to align with the rest of the United Kingdom—arguments echoed in the government's final impact assessment. A former Minister for Public Health himself admitted that the adopted regulations were "better than nothing," but did not go as far as they should have.

Extend the logic of article 5.3 to all harmful industries

The report's authors make four recommendations to Scottish MPs. First, they call on them to recognize the fundamental conflict of interest between the commercial objectives of these industries and those of public health. Second, they advocate for the adoption of transparency and governance measures similar to those governing interactions with the tobacco industry under Article 5.3 of the WHO Framework Convention on Tobacco Control. These measures stipulate limiting interactions between public actors and any representative of the tobacco industry to what is strictly necessary and conducted transparently. Industry representatives should not be involved in the definition and implementation of public policies. They also have an obligation of transparency regarding their activities and products. The report's authors further recommend that information provided by industry representatives be subject to rigorous scrutiny and that public officials prioritize partnerships with actors free from conflicts of interest. They also reiterate the importance of defending prevention policies, whose long-term economic benefits outweigh the alleged costs for the sectors concerned.

The authors draw on the precedent of tobacco control to demonstrate that population-wide regulation remains possible in the face of powerful industries: advertising restrictions, the ban on smoking in public places, and plain packaging have reduced smoking prevalence and transformed social norms. For Kym Kestell, head of the NCD Alliance Scotland, Scotland's health needs should never be pitted against the vested interests of industries harmful to health. Scottish Minister for Public Health Maree Todd, for her part, reaffirmed the goal of a tobacco-free Scotland by 2034, as well as the entry into force in October of restrictions on the promotion of unhealthy foods.[3].

This document extends a series of recent works, from the report[4] from WHO Europe on the commercial determinants of non-communicable diseases to the ten-year strategy[5] from the NCD Alliance Scotland, which converge on the same observation: the tobacco, alcohol and ultra-processed food industries share a common repertoire of interference, and the protection instruments developed for tobacco, foremost among them Article 5.3 of the FCTC and its implementing directives, constitute today the most successful model for preserving health policies from their influence.

©Generation Without Tobacco

AE

[1] Health Under Influence: The Industry Playbook Behind Scotland's Preventable Health Harms, NCD Alliance Scotland, published on September 15, 2026, accessed on September 15, 2026.

[2] Killer Tactics: How tobacco, alcohol, and unhealthy food and drink industries hold back public health progress, Obesity Health Alliance, Alcohol Health Alliance and Action on Smoking and Health, published in 2024, accessed on September 15, 2026

[3] Experts warn tobacco, alcohol, and junk food giants undermining health policies, STV News, published on September 15, 2026, accessed on September 15, 2026.

[4] Commercial determinants of noncommunicable diseases in the WHO European Region, World Health Organization, Regional Office for Europe, published on 12 June 2024, accessed on 15 September 2026.

[5] NCD Prevention: A Commercial Determinants of Health Approach, NCD Alliance Scotland, published in 2024, accessed on September 15, 2026.

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