International Journal of Drug Policy 129 (2024) 104475

Contents lists available at ScienceDirect

International Journal of Drug Policy

journal homepage: www.elsevier.com/locate/drugpo

Research Paper

Industries, citizens, and non-governmental organizations’ positioning and

arguments used in European Union initiatives for alcohol taxation and
cross-border regulation
Selina Baumann a, b, c , Teresa Leão a, b, c, *
a
EPIUnit - Instituto de Saúde Pública, Universidade do Porto, Rua das Taipas, n◦ 135, 4050-600 Porto, Portugal
b
Laboratório para a Investigação Integrativa e Translacional em Saúde Populacional (ITR), Universidade do Porto, Rua das Taipas, n◦ 135, 4050-600 Porto, Portugal
c
Departamento de Ciências da Saúde Pública e Forenses, e Educação Médica, Faculdade de Medicina, Universidade do Porto, Alameda Prof. Hernâni Monteiro, 4200
Porto, Portugal

A R T I C L E I N F O A B S T R A C T

Keywords: Background: The European region has the highest daily alcohol consumption per capita and a high alcohol-related
Alcohol-related disorders [MeSH] burden of disease. Policymaking at the European Union level is open to participation by interest groups, from
Lobbying [MeSH] public health organizations to alcohol industry representatives. This study aimed to map the interest groups
Policy making [MeSH]
present in the alcohol taxation and cross-border regulation initiatives and identify which arguments were used to
Health behavior [MeSH]
Commercial determinants of health
support positions in favor or against them.
Methods: We used qualitative content analysis on the comments submitted on the official European Commission
website during the 2017, 2018, 2020, and 2022 participation periods. Interest groups were characterized
considering their positioning, and arguments were identified and compared by position and type of initiative.
Results: Opponents of changes to the structures of alcohol excise duties and cross-border regulations were mostly
representatives of the alcohol and agricultural industries, and the proponents were mostly health-related
nongovernmental organizations. Opponents of these initiatives used a wide variety of arguments, from eco­
nomic and trade to health arguments, while proponents focused mainly on health arguments, such as the
effectiveness of alcohol taxation in preventing alcohol-related morbidity and mortality.
Conclusion: This study highlights the wide range of arguments used by opponents around alcohol control policies,
contrasting with the health-centered arguments of proponents. It further shows that there is a lobbying network
at the European Union level, combining national and international representatives of industry and non-
governmental organizations. These findings provide an opportunity for better preparation for upcoming dis­
cussions on alcohol control at national and regional levels.

Introduction strategies that include taxation, limits on availability, and bans on

marketing, to (2) strategies for high-risk populations, such as
In 2019, alcohol use was responsible for 4.3% of deaths and 3.6% of drunk-driving countermeasures, screening, brief interventions, and
total disability-adjusted life years worldwide (Institute for Health Met­ treatment of alcohol disorders, as well as (3) environmental strategies
rics and Evaluation, 2021). In the World Health Organization (WHO) such as education, registration of alcohol production (including indus­
European region, figures reached up to 5.1% of the overall trial alcohol), and informal controls by using social dynamics (e.g.
disability-adjusted life years (WHO, 2018). through role modeling, or denormalization) to influence drinking be­
As mortality and morbidity increase with the level of alcohol con­ haviors (Berdzuli et al., 2020; WHO, 2019). Among those, alcohol
sumption, alcohol control policies are of high importance for health taxation is considered by the WHO a “best buy” strategy due to its high
promotion and disease prevention (Hope, 2006). Several strategies can cost-effectiveness, in low-, middle-income, and high-income countries
be used to prevent alcohol-related morbidity and mortality. Those (Chisholm D., 2018; WHO, 2017). It can be implemented through uni­
currently employed in Europe range from (1) general population tary taxation (based on the volume of the alcoholic beverage), specific or

* Corresponding author at: Teresa Leão, Instituto de Saúde Pública, Universidade do Porto, Rua das Taipas, n◦ 135, 4050-600 Porto, Portugal.
E-mail address: teresa.leao@ispup.up.pt (T. Leão).

https://doi.org/10.1016/j.drugpo.2024.104475

Available online 5 July 2024

0955-3959/© 2024 The Author(s). Published by Elsevier B.V. This is an open access article under the CC BY-NC-ND license (http://creativecommons.org/licenses/by-
nc-nd/4.0/).
S. Baumann and T. Leão International Journal of Drug Policy 129 (2024) 104475

volumetric taxation (based on the amount of ethanol a beverage con­ considering the variety of alcohol taxation policies across European
tains), ad-valorem taxation (based on the value of the product), as well countries and of actors and interests shaping these policies at the EU-
as a combination of two or more basic taxation methods (Sornpaisarn level.
et al., 2017). The aim of this study was, first, to identify and map the interest
The 92/83/EEC European Commission (EC) Directive from 1992, groups that have participated in feedback processes on alcohol taxation
last updated in 2020, set out structures for the excise duties on alcohol and cross-border regulations under EC initiatives. The second aim was to
for different beverage types, including minimum rates, as well as general identify the arguments used by these different actors and interest groups
rules and criteria for taxation and exceptions from those rules (European in the various feedback and consultation moments. The understanding
Council, 2020). Yet, European Union (EU) Member States are free to of the public positions of different actors and interest groups can shed
levy taxes on alcoholic beverages or to offer exemptions in specific cases light on the influence exerted by the alcohol industry and other stake­
(as for small producers to support local production), leading to a wide holders, the network of influences and potential coalitions supporting or
variety of duty rates for the different beverage types across the entire opposing public health-oriented policies, and the common narratives
region (Angus et al., 2019). Eastern and southern European countries set employed in policy discussions.
low levels of taxation, particularly for wine; only half of the Member
States (mostly northern European countries) levy any duty on wine; and Material and methods
only five EU countries set taxes at the minimum level for beer and spirits.
Finland, Sweden, Ireland, and the United Kingdom (UK) contrast with Four feedback and consultation processes occurred in total (details
the remaining countries for having higher rates for all alcoholic bever­ about the initiatives can be found in Table 1). In 2017 the EU proposed
ages. This longstanding wide variety of alcohol taxes applied across the the revision of the Directive that addresses EU rules on the structures of
EU has not only an influence on its effect on public health but also on excise duty applied to alcohol and alcoholic beverages (European
fostering cross-border acquisitions to circumvent the price differences, Commission, 2017). The initiative presented descriptions of the prob­
further undermining the effect of some countries’ stricter alcohol pol­ lems and possible policy options under analysis. In 2018, a proposal for a
icies (Angus et al., 2019; Romanus, 2006). To address these policy pit­ Directive was developed, which outlined a preliminary set of potential
falls, in the last few years, new regulations have been under discussion in policy options (European Commission, 2018). In 2021, the EC aimed to
the EU. Changes in the structures of excise duties on alcohol and alco­ increase the effectiveness of cross-border acquisitions regulations (Eu­
holic beverages have been proposed by the EC, as well as on the ropean Commission, 2021a). In 2022, the most recent initiative tackling
cross-border acquisitions of excise goods by private individuals, through alcohol taxation in the EU, aimed to assess the validity and effectiveness
different initiatives in 2017, 2018, 2021, and 2022 (Table 1). Each of of the minimum rates of excise duties on alcohol and alcoholic beverages
these initiatives was open to feedback and consultation from citizens, and the basis of taxation of alcohol on the volume or alcoholic content of
institutions, and organizations, as mechanisms to provide transparent beverages, which had not been updated since 1992 (European Com­
decision-making processes. Feedback and consultation can occur at mission, 2022). All these initiatives were open for consultation and
different moments of the policy cycle, either in the design of a roadmap feedback, which was provided by citizens, institutions, and organiza­
or a proposal, during the evaluation, or after the adoption of legislative tions, using open-ended written comments.
initiatives. Considering the nature of these data, a qualitative content analysis
The alcohol industry is considered of high economic and political was applied to the comments collected during the feedback and
importance in several EU Member States as it meets three major eco­ consultation processes to identify and map the actors and interest
nomic pillars – jobs creation and maintenance, wealth generated, and groups, as well as the arguments used by them. This analysis allows a
government revenue (The Brewers of Europe, 2020). The EU is the systematic approach to a volume of qualitative data, to identify con­
world’s largest producer of wine (European Parliament Research Ser­ sistencies, patterns, themes, and meanings (Hsieh & Shannon, 2005;
vice, 2023), and, after China, the second largest beer producer in the Patton, 2002). It also allows the understanding of the frequency of
world (The Brewers of Europe, 2020). Thus, despite the risk of its in­ categories and themes used, relevant to better grasp the weight of
fluence on policymaking (Stockwell & Crosbie, 2001) the alcohol in­ themes and positions held by participants in the feedback and consul­
dustry carries lobbying activities around alcohol control policies tation processes (Mayring, 2023).
(Barlow et al., 2022; Foundation for Alcohol Research & Education,
2022; McCambridge et al., 2019). The alcohol industry has been influ­ Data sources
encing political strategies at the World Trade Organization discussions
on alcohol health warning labeling policies (Barlow et al., 2022; We consulted and extracted all comments submitted by actors and
McCambridge et al., 2019) and on the revision of the WHO draft of the interest groups during these feedback and consultation processes, made
Global Alcohol Action Plan (2022–2030), with apparent effectiveness available by the EC on their official website under the headline “Have
(Foundation for Alcohol Research & Education, 2022; McCambridge & your say”. A total of 75 comments was analyzed: (i) six comments
Lesch, 2024) submitted on the Inception Impact Assessment on the structures of
The analysis of lobbying efforts, both related to alcohol health excise duties on alcohol and alcoholic beverages (European Commission
warning labels – in France and close to the World Trade Organization 2017), (ii) five comments submitted on the Proposal for a Council
(Barlow et al., 2022; Millot et al., 2022) – and to alcohol taxation pol­ Directive amending Directive 92/83/EEC on the harmonization of the
icies – in Ireland and the UK (Drink Industry Group of Ireland, 2002; structures of excise duties on alcohol and alcoholic beverages - struc­
Hawkins & Holden, 2013a; Hope, 2006; McCambridge, Hawkins & tures of excise duties on alcohol and alcoholic beverages, (iii) 22 com­
Holden, 2013; Babor & Robaina, 2013; Holden & Hawkins, 2013) – has ments submitted on the cross-border acquisitions of excise goods by
shown the arguments most commonly used by the industry. In these private individuals – revision of Article 32 of Directive 2008/118/EC
settings, the common arguments are that "most of the population is (European Commission 2020) and (iv) 42 comments submitted on the
drinking responsibly", and "education and public information about harmful evaluation of the rates and structures of excise duty on alcohol and
drinking would be preferred", thereby minimizing the role of taxation and alcoholic beverages (European Commission 2022a). All comments were
price raises to control the burden of alcohol-related diseases. converted to PDF files and imported to MAXQDA Analytics Pro 2022 on
Though the lobbying strategies employed by the alcohol industry at the 27th of October 2022.
the EU level may be similar to those used in the settings previously
described, the role of other actors and the arguments used by both
parties in the discussion of taxation policies is still unknown, especially

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S. Baumann and T. Leão International Journal of Drug Policy 129 (2024) 104475

Table 1 Table 1 (continued )

Content of four policy initiatives. Name of the initiative Main proposals Feedback /
Name of the initiative Main proposals Feedback / (year) consultation period
(year) consultation period
basis of taxation of alcohol
Inception Impact • Define product categories to From 2nd to 30th on the volume or alcoholic
Assessment on the avoid the exploitation of tax of March 2017 content of beverages, which
structures of excise incentives by have not been updated since
duties on alcohol and manufacturers of certain 1992.
alcoholic beverages alcoholic beverages.
(2017) • Clarify the objectives of the
Directive and differentiate Data analysis
its impacts in reduced rates
for alcoholic beverages
These comments were analyzed using content analysis. For this
below a certain alcoholic
strength. study, we used directed content analysis which aims to validate or
• Rule the administration and extend a theoretical framework or theory by using a deductive-inductive
economic operation in the method (Hsieh& Shannon, 2005). We identified the actors who sub­
application of the rules for mitted their comments on the platform and characterized them as citi­
the exemption for the
different types of denatured
zens, organizations, or institutions, and according to their countries of
alcohol, how it is granted, origin (if citizens or national-level organizations and institutions).
and what mutual Additionally, we searched for explicit connections with other organi­
recognition means in zations either in the comments or in by consulting their official websites,
practical terms.
and their position (pro or con) regarding each of the proposed policy
• Define consistent
calculations of excise duties changes, based on the written comments within the feedback and
on beer (especially consultation process. A network analysis was used to map the different
sweetened beer) hence actors and interest groups, and their relationships.
economic operators in some Then, we assessed the comments submitted to these four feedback
Member States were having
an additional burden that
and consultation processes. We coded the type of arguments given by
evolved through the each actor. To build a coding tree based on the literature (deductive
differences between using phase), we first identified arguments described in previous papers
degrees Plato as a reference (Hope, 2006; Drink Industry Group of Ireland, 2002; Hawkins &
rather than using alcohol by
McCambridge, 2014a; Hawkins & Holden, 2013a; Hawkins & Holden,
volume for taxation.
• Review, define and clarify 2013b; Holden & Hawkins, 2013; McCambridge et al., 2018; Babor
who and which types of et al., 2010.; McCambridge et al., 2019; Stockwell & Crosbie, 2001;
alcohol are exempted from Romanus, 2006; Zatonski et al., 2018; Paixão & Mialon, 2019;
duties. McCambridge et al., 2018) about the lobbying of the alcohol industry on
Proposal for a Council • Identify problem areas to be From 25th of May
Directive amending addressed to ensure to 20th of July
taxation policies. In the second step, the inductive one, the content of the
Directive 92/83/EEC on effective implementation of 2018 comments was analyzed and used to revise and add new codes to the
the harmonization of the policy proposals. initial coding tree. Comments available in languages other than English,
structures of excise • Set potential policy options German, or Portuguese (for example, in Polish, Spanish, French, and
duties on alcohol and for proper functioning of
Italian) were translated into English using DeepL as an online translation
alcoholic beverages the internal market for
(2018) alcoholic beverages, software. Data analyses were performed using MAXQDA Analytics Pro
safeguarding the revenues 2022.
of the EU Member States but
also contributing to the Results
protection of human health
based on the Inception
Assessment from 2017. Actors and interest groups characterization
Cross-border acquisitions • Tackle the effectiveness From 8th of
of excise goods by issues of the guide levels December 2020 to One third of all actors were based in Belgium (26%), followed by
private individuals and the concept of "own 5th of January
Germany (13%), Sweden (9%), and Poland (7%), with the remaining
(2021) use" of these goods since 2021
every EU Member State from other countries such as Austria, Croatia, Finland, France, Estonia,
could define the amount of Ireland, Italy, Malta, Malaysia, the Netherlands, Portugal, Spain,
alcohol for their citizens’ Switzerland, and the UK.
use. A fourth of the comments were submitted by health-focused non-
• Limit the potential of the
governmental organizations (NGOs) (25%), 23% by the alcohol (beer,
current provision to
undermine national health wine, and spirits) industry, 23% by EU citizens. The remaining com­
policies. Another point was ments were submitted by trade associations (9%), the agricultural in­
the risk of fraudulent dustry (7%), and consumer organizations (6%). About 7% were
activities of individuals and
submitted by other stakeholders such as the cosmetics or chemical in­
organized criminal
organizations due to dustry. For more details consult Supplementary Table 1.
minimal risk and minimal About 60% of the actors were part of networks or groups repre­
difficulty. senting associations, foundations, producers, or companies from
Evaluation of the rates and • Assess the validity and From 11th of April different European countries, such as The European Heart Network, The
structures of excise duty effectiveness of the to 4th of July 2022
Brewers of Europe, and spiritsEUROPE. Two-thirds were explicitly
on alcohol and alcoholic minimum rates of excise
beverages (2022) duties on alcohol and aligned with other actors. Health-related NGOs had as cooperation
alcoholic beverages and the partners other NGOs active in alcohol policies (for example, The Euro­
pean Alcohol Policy Alliance, European Public Health Alliance, The

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S. Baumann and T. Leão International Journal of Drug Policy 129 (2024) 104475

European Association for the Study of the Liver). Several actors from the citizens’ and consumer organizations’ were often mixed, taking both
alcohol industry were explicitly aligned with large organizations rep­ sides: some mirrored health-related NGOs’ arguments, but others
resenting and cooperating with smaller industries or family businesses in showed the same interests as the alcohol industry.
the whole Europe, as The Comité Européen des Entreprises Vins (CEEV) These arguments were categorized into two themes: economy and
or The Brewers of Europe. The network analysis showed that consumer trade as well as health promotion and disease prevention.
unions and agriculture associations were part of networks of actors from
the alcohol industry and that, overall, European associations or pro­
Economy and trade
ducers were interrelated (Supplementary Figure 1). Regarding health-
related NGOs and other associations, there was a clear proximity be­
The arguments used in the four periods (2017, 2018, 2021, and
tween those located in northern countries. The link between these
2022) are presented in Fig. 1 and detailed in Table 2. Several arguments
nordic NGOs and the European-level alliances and associations (also
related to the economy and trade theme emerged, garnering a total of
closely interrelated) was facilitated by the European Alcohol Policy
115 mentions.
Alliance (Supplementary Figure 2).
These were predominantly used by opponents of higher taxation,
notably from the alcohol and agricultural industries, and often pointed
Positions of actors and interest groups out the inadequacy of these proposals or the risk of disrupting compe­
tition in the market. They contended that policy initiatives would
Most comments (59%) welcomed the policy change initiatives, 32% heighten the risk of the black market (11 mentions) and fraud (10
stated a preference for the maintenance of current regulations, and 9% mentions) due to increased taxation. Also, the alcohol industry and some
showed mixed opinions. Actors who supported the proposed policy citizens argued that most consumers drink moderately, and higher taxes
changes (i.e., proponents), were mostly health-related NGOs (such as the would penalize these moderate drinkers (ten mentions) and they
European Heart Network, the European Health Alliance, the European asserted that reduced rates would enhance consumer choice (four
Chronic Disease Alliance, or the European Alcohol Policy Alliance), mentions). According to the perspective of these opponents, reducing
some alcohol producers (mostly spirits industry), and other stakeholders consumption would be more effectively achieved through alternative
(chemical and cosmetic industry, research group, representatives from means, particularly awareness campaigns (four mentions).
European social insurances). The opposition mostly emerged from the Another aspect highlighted by the alcohol industry was the impor­
alcohol industry and trade associations such as The Brewers of Europe, tance of alcohol industries for the economy. The beer and wine sectors
the Portuguese Wine and Spirits Association, and the agricultural in­ emphasized their role in sustaining jobs (eight mentions) and indirect
dustry representatives like the Italian company Colidretti, the government revenues (six mentions). The agricultural sector on the
“Deutscher Raiffeisenverband e.V.” and Copa Cogeca. The positions of other hand highlighted the dependence of various businesses on alcohol

Fig. 1. Actors and interest groups, positions, and arguments used in the four policy discussion periods. In the left column, the participants in these discussion periods
are listed and categorized according to their positioning (proponent, opponent, or mixed) and, in the right column, arguments used are grouped by theme. ±
Participants with different perspectives regarding the revision of structures of excise duty.

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S. Baumann and T. Leão International Journal of Drug Policy 129 (2024) 104475

Table 2 Table 2 (continued )

Actors and interest groups and arguments used in the four feedback and Themes Arguments Code explanation Quotes
consultation processes. (frequency, (frequency, n)
Themes Arguments Code explanation Quotes n)
(frequency, (frequency, n) for especially low
n) alcoholic drinks.
Economy Taxation All alcoholic “The possibility to apply Alcohol sales are Many businesses “A hypothetical increase
and Trade increases the risk beverages different rates based important for the of the private in the excise duty rates
(n=115) of disruption of contain ethanol purely on the alcoholic private sector sector depend on would result in the tax
competition but are taxed strength of the product (n=7) the production being passed on through
across beverage differently based would disrupt and the sale of lower prices paid for raw
industries on categories. A competition” (CEEV, alcohol materials to farmers who
(n=16) taxation based 2022) receive a lower
on the content of remuneration for their
pure alcohol products.” (Croatian
would lead to a Chamber of Agriculture,
disadvantage for 2022)
the wine industry Wine should be Wine production “Continuing to apply a
on the market. exempt of taxes is more zero-excise duty rate for
Taxation based All alcoholic “The EU needs to change due to its high expensive wines makes sense for
on alcohol beverages the structure of excise production costs the following reasons: 1)
content is a better contain the same duties to ensure all types (n=6) wine production is a very
alternative type of alcohol of alcohol beverages can demanding agricultural
(n=12) (ethanol). Basing be taxed in relation to activity; 2) production
taxation based the volume of alcohol costs exceed by far those
on it instead of they contain.” (European for other alcoholic
product Alcohol Policy Alliance, beverages” (Copa-
categories would 2017) Cogeca, 2022)
be fairer. Harmonization of To avoid trade “A higher level of
Taxation People could “Increasing taxes would excise duties distortions in the harmonization is
increases the risk start producing run counter to the would be fairer single market, necessary to ensure the
of fraud and the their own (low current efforts of (n=6) ensure fair establishment and the
black market quality) alcohol national authorities to competition functioning of the
(n=10) and sell/buy it on curb fraud and between internal market and to
the black market counterfeiting, nurture businesses and avoid distortion of
illicit markets” (Croatian reduce competition”
Chamber of Agriculture, administrative (spiritsEUROPE,2021) )
2022) burdens for
New regulations When “It is important that the businesses
with easier regulations are change of guide levels to Alcohol sales are The excise duties “Wine production
enforcement are easy to be concrete and easily important for levied on alcohol significantly contributes
needed enforced its more enforceable limits government contribute to the to national incomes.”
(n=10) likely to work (quantitative limits) is revenues governmental (ACIBEV - Associação de
out and to included within the (n=6) revenues Vinhos e Espirituosas de
strengthen scope of the policy Portugal, 2022)
internal markets option “revised and The alcohol Alcohol “Lastly, viticulture plays
and improve adjust the guide levels”.” industry is production a key role in the
Public Health (Movendi International, important for contributes for economic, social and
2021) territorial the harmonious environmental
Taxation The vast majority “The vast majority of the cohesion development of sustainability […]”
penalizes is drinking population is consuming (n=5) diverse (Deutscher
moderate moderately and wine responsibly and in landscapes, Raiffeisenverband e.V.,
consumers gets penalized by moderation and should cultures, and 2022)
(n=10) higher taxation not be penalized by communities
unjustified tax There is a misuse Cross-border “The current regulations
increases.” (ACIBEV, of cross-border acquisition have the potential to
2021) regulations regulations are undermine national
The alcohol The production “The reduced rates (n=5) not adequate. A public health policies.”
industry is of alcohol provision follows the large amount of (Austrian Federal
important for guarantees many principles of the EU’s alcohol can be Economic Chamber,
employment jobs inclusive growth agenda bought abroad 2021)
(n=8) […] providing higher which
employment undermines
opportunities” (The national alcohol
Brewers of Europe, control policies
2018) There are better Other “The promotion of
Taxation Due to lower “The use of reduced rates alternatives to approaches are awareness campaigns
promotes the taxes for some should promote reduce the risk of more adequate could contribute to
creation of lower product a higher diversity.” (The Brewers fraud reduce the risk of fraud.”
strength variety of of Europe, 2018 ) (n=4) (CEEV, 2021)
beverages alcoholic Taxation can be The alcohol used “Due to the scale at
(n=8) beverages will be unfair to other there is not which ethyl alcohol is
produced and unrelated meant for used industrially, this
therefore industries consumption and quickly leads to
consumers have (n=2) should therefore disproportionate
a better choice follow other taxation of companies
regulations. into the six-figure
range.” (Verband der
(continued on next page)

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S. Baumann and T. Leão International Journal of Drug Policy 129 (2024) 104475

Table 2 (continued ) Table 2 (continued )

Themes Arguments Code explanation Quotes Themes Arguments Code explanation Quotes
(frequency, (frequency, n) (frequency, (frequency, n)
n) n)

Chemischen Industrie e. prevent alcohol Research & Consulting,

V. – VCI, 2022) consumption 2022)
Health Taxation is an Taxation on “There is strong and Beverages with There is no or “There is no scientific
promotion effective tool to alcohol can lead consistent evidence that higher alcohol insufficient evidence that higher
and prevent alcohol- to a reduction of increasing the price of content are not evidence on an strength alcoholic
disease related disease the consumption alcohol reduces more harmful alcohol strength beverages are more
prevention (n=17) rate and immediate and chronic than those with and health associated with harm
(84) therefore lower harm related to drinking lower correlation compared to low
harm. among people of all (n=5) strength” (CEEV, 2022)
ages.” (European It is EU’s The EU is “The most important it is
Alcohol Policy Alliance, responsibility to responsible to that the European
2017) set measures for create guidance Commission fulfills its
Additional A combination of “[…] highlights the prevention and support for obligation to improve
interventions for different policy importance that (n=4) countries to health protection and
prevention are options is needed different combinations implement adapts existing
needed of the identified policy preventive regulations” (Deutsche
(n=15) options are considered. measures Sozialversicherung
This because the issues Europavertretung, 2022)
with the current rules are Enforcement of The current “CEEV is supportive of
multi-layered and the current rules thresholds are the status quo with a
challenges differ slightly is a better not seen as better enforcement of
between countries.” alternative (n=2) problematic. current legislation
(IOGT-NTO, 2021) Instead, the EU is without changes in the
Taxation can lead Higher taxation “Tax and price increases asked to enforce guide levels.” (CEEV,
to unintended can lead to the are poorly suited to the current rules 2021)
harmful alcohol consumption of targeting harmful use of better to reduce
consumption lower quality alcohol, as they often alcohol-related
(n=13) alcohol and is not bring the opposite harm
effective for results.” (Deutscher
tackling harmful Raiffeisenverband e.V.,
consumption of 2022) production and sales due to their related revenues for the private sector.
alcohol Additionally, it was emphasized alcohol’s contribution to territorial
Alcohol Alcohol “Mediterranean
consumption consumption countries, for instance,
cohesion by fostering the development of rural landscapes, cultures, and
rates are rates have been have the lowest communities (five mentions).
overrated declining, prevalence of heavy Although all alcohol industry representatives were opposed to higher
(n=8) despite the low episodic drinking and/or alcohol taxation, some endorsed specific initiatives aligning with their
taxes in some abuse despite applying
interests. The spirits industry advocated for taxation based on alcohol
countries. In zero or low excise duties
these countries, on wine.” (Copa-Cogeca, content to prevent discrimination against spirits and maintain fair
the rates were 2022) competition (12 mentions), aligning with health-related NGOs and trade
similar or even associations (related to spirits), who used this rationale to suggest
lower than in raising prices for low-alcohol beverages. Additionally, some spirits in­
other EU
countries
dustries supported the harmonization of EU-level excise duties for
There are better Alternatives or “To tackle harmful increased fairness (six mentions). Conversely, the beer industry sup­
alternatives for addition of consumption patterns, ported raising the alcohol content threshold (from 2.8% to 3.5%) for
prevention programs, like consumer education taxation, to encourage the consumption and development of low-alcohol
(n=8) educational should be a priority.”
beverages, and enhance product diversity for consumers (eight men­
programs (and (CEVI, 2022)
others), would be tions). In contrast, the wine industry strongly favored the continuation
more effective or of its tax exemption due to the high production costs associated with
more adequate wine (six mentions). The wine industry, in particular, argued that
Moderate Moderate alcohol “Scientific evidence altering excise duties into a taxation system based on pure alcohol
consumption is consumption is shows that drinking
part of a healthy part of a healthy wine in moderation,
content would put the wine industry at a disadvantage, disrupting
lifestyle diet with a meal, as part of competition across other beverage industries (16 mentions).
(n=7) healthy lifestyles and Unrelated industries, such as the chemical and cosmetics sectors, also
dietary patterns, in participated in these policy discussion initiatives, highlighting the un­
particular the
fairness of current regulations (two mentions), since the use of alcohol
Mediterranean diet, does
not seem to increase for industrial purposes has been charged with the same taxes. Conse­
health risk.” quently, they strongly advocated for changes through the new initiatives
(Confederazione Italiana to address this issue.
Della Vite e Del Vino, Regarding cross-border acquisitions, health-related NGOs and trade
2022)
There is There is no or “Empirical evidence
associations noted that the existing regulations are unclear to consumers
insufficient insufficient confirms that alcohol and can be confusing at times, particularly concerning the quantity
evidence of evidence on the affordability has little allowed for private use. They argued that this ambiguity leads to misuse
effectiveness effectiveness of impact on alcohol- of the existing regulations (five mentions), emphasizing the necessity for
(n=5) taxation (or of related harm & hence,
new regulations with simpler enforcement mechanisms to guarantee
reduction of excise duties are
affordability) to inadequate public health effectiveness (ten mentions). Thus, health-related NGOs and other pro­
policy tools.” (G. Z. ponents of policy changes, such as the European representative of social
insurance or some trade associations, suggested that clearer rules would

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avoid undermining alcohol control policies. Both proponents and some to produce cosmetics, was specific to this 2017 feedback and consulta­
opponents, like the spirits industry, highlighted the need for easily tion process and repeated in 2022. The argument that new regulations
enforceable regulations. While health-related NGOs used this way of must be enforceable to ensure effectiveness was first used in 2017 by
argumentation to make sure national policies will not be undermined by health-related NGOs and other proponents, such as the European
high cross-border purchases, the alcohol industry used this way of representative of social insurances, and the alcohol industry, but became
argumentation intending that their domestic products are being bought. more common in the 2021 feedback period.
The 2021 initiative on alcohol cross-border regulations observed
Health promotion and disease prevention specific arguments, namely related to the current misuse of this policy,
the risk of fraud and stimulation of the black market, and the need for
Also frequent were arguments presented under the health promotion better enforcement of current rules. While this argument was used by
and disease prevention theme (84 mentions). These were primarily put health-related NGOs to ensure that cross-border purchases are reduced,
forth by health-related NGOs, who were supportive of policy changes in the alcohol industry used it intending to ensure the consumption of
the taxation of alcohol. They argued that taxation serves as an effective domestic products. In this feedback period, the claim that it is the EU’s
tool in preventing alcohol-related harm (17 mentions), yet they responsibility to set impulses for prevention, used by health-related
emphasized that for taxation to be effective, it must be integrated with NGOs and other proponents, was first used. The argument of the
other preventive measures such as health warning labels and limitation alcohol industry that alcohol consumption prevalence estimates are
of availability (15 mentions), often referring to the “best buy” strategies overrated first emerged during this feedback process and was specific to
to tackle the harmful use of alcohol presented by the WHO (WHO, the 2021 and 2022 initiatives.
2017). Proponents, including representatives from European social in­ The 2022 feedback period on the initiative for the evaluation of
surance and health-related NGOs, even urged the European Commission excise duties and structures of tax rates aggregated the widest variety of
to assume the responsibility of guiding Member States in alcohol use actors and arguments. Yet, no new arguments emerged except the claim
prevention (four mentions). They asserted that it is the Commission’s that higher-strength beverages are not more harmful than those with
obligation to enhance health protection and adapt existing regulations lower alcohol content, provided by representatives of the alcohol
for the betterment of public health. industry.
Contrarily, opponents, primarily the alcohol industry and trade as­
sociations, raised concerns about taxation potentially leading to unin­ Discussion
tended effects, such as increasing the risk of proliferation of black
market lower-quality alcohol (13 mentions), or no effects on unhealthy The discussion of these European-level policy initiatives was popu­
alcohol consumption levels, stating that there is no or insufficient evi­ lated by a large range of actors. Besides the plurality of these actors, a
dence regarding the effectiveness of pricing policies (six mentions). variety of positions and arguments were presented. Representatives
They also argued that alcohol consumption rates are being exaggerated from the alcohol and agricultural industries and trade associations
(eight mentions). Copa-Cogeca, representing the agricultural sector, opposed policy changes. NGOs related to health advocacy were the most
reinforced this stance by pointing out that Mediterranean countries, vocal proponents, followed by consumer organizations, the chemical
despite having zero or low taxes on wine, exhibit a low prevalence of and cosmetics industries, and citizens.
heavy episodic drinking and abuse. The alcohol industry maintained
that alternatives such as educational programs would be more effective The complex web of interests: unveiling the spectrum of actors in alcohol
in reducing harmful alcohol consumption. Specifically, the wine in­ policy lobbying
dustry opposed any increase in alcohol taxation, citing studies that
frame moderate wine consumption as a part of a healthy lifestyle (seven While the presence of alcohol industry representatives in lobbying
mentions). They contended that beverages with higher alcohol content was expected and had been previously described (Babor et al., 2010,
are not inherently more harmful than lower-strength options (five 2018; Hope, 2006; McCambridge et al., 2018; O’Brien et al., 2023;
mentions), and that enforcing existing rules would present a better Paixão & Mialon, 2019; Zatonski et al., 2018; Hawkins & Holden, 2014;
alternative to reducing alcohol-related harm (two mentions) than Hawkins & McCambridge, 2021), mapping the other actors who lobby
increasing taxes. against or in favor of changes in taxation and cross-border regulations,
reveals a multitude of actors and their interdependence, as well as how
Differences in actors and arguments over the four feedback periods their argumentation is framed.
Proximity between industry representatives was noted. Many actors
The positions of actors and interest groups who participated in these from the alcohol industry were explicitly aligned with large organiza­
four feedback and consultation processes remained overall the same, as tions that represent and cooperate with smaller industries or family
well as the main scope of their arguments. Indeed, generally, the alcohol businesses throughout Europe, such as Anheuser-Busch InBev, The
industry led the opposition to tax increases, and health-related NGOs Comité Européen des Entreprises Vins (CEEV), and The Brewers of
remained as the main group of proponents. Europe, indicating a well-organized industry structure as previously
However, specific arguments emerged in some periods. In 2017 and described by Jernigan and Ross (2020). As highlighted in previous
2018, the feedback on the initiatives on the structures of excise duties on literature (Hawkins & McCambridge, 2014; Hawkins et al., 2018;
alcoholic beverages observed a large range of actors – from the alcohol McCambridge & Lesch, 2024; McCambridge, Hawkins & Holden, 2013;
industry, against the policy changes, to health-related NGOs or the Jernigan, 2011; Moodie et al., 2013), the alcohol industry exhibits
cosmetics industry, in favor. The advocacy for lower taxes for beverages similar strategies to those of the tobacco industry and other unhealthy
with low alcohol content, to promote new low-strength beverages, commodity industries (Ulucanlar et al., 2023), and significant cooper­
emerged from representatives from the beer industry. The claim for ation among the tobacco and alcohol industries affected tobacco regu­
structuring taxation based on the ethanol content, for more fairness, lation (Jiang & Ling, 2013). An example of the interconnectedness
emerged from the spirits industry. The wine industry, contrarily, argued between these industries is Anheuser-Busch InBev’s election of the
that higher taxation of wine or based on alcohol content could disrupt former CEO of Altria, one of the largest tobacco producers and marketers
the competition; this argument was first mentioned in these initiatives which holds 10% of Anheuser-Busch, as its new board chairman
and repeated in 2022. (Movendi International, 2019). This raised concerns among public
The participation of the cosmetics industry, unexpected and claiming health advocates, such as the NGO Movendi International, as this sends a
unfairness of the existing alcohol taxation, since it taxes alcohol bought clear message "[…] to systematically undermine, obstruct, and oppose

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S. Baumann and T. Leão International Journal of Drug Policy 129 (2024) 104475

public health policymaking and cast doubt about the scientific evidence A study from Australia that identified arguments used by the alcohol
concerning health-harmful products and business practices." (Movendi industry in alcohol policy submissions found that, in 66% of the sub­
International, 2019). missions, the industry had misused scientific evidence, namely on the
This evidence highlights the potential for increasingly negative im­ effects of alcohol on health (Stafford et al., 2020). The argument that
pacts on health that single corporations, especially the largest multina­ alcohol consumption rates are overestimated, also used in these dis­
tionals and transnationals, can wield (Collin & Hill, 2015; Freudenberg, cussions, aligns with the downscaling strategy previously found in de­
2021; Millar, 2013; Moodie et al., 2013; Schrecker & Bambra, 2016), in bates on label policies (Barlow et al., 2022).
alignment with the framework proposed by Gilmore et al., and Bondy As found in the literature, alternatives to taxation were frequently
(2023) of how commercial actors, particularly those in the alcohol, to­ posed by opponents: stronger enforcement of existing measures (Bakke
bacco, ultra-processed food, and fossil fuel sectors, affect health. & Endal, 2010; Bond et al., 2009; Hawkins & Holden, 2013b; Hope,
2006; Savell et al., 2016; Avery et al., 2016), and educational programs
The multifaceted lobbying of the wine, beer, and spirits sectors on EU to reduce harmful consumption (Barlow et al., 2022; McCambridge
taxation policy et al., 2018; O’Brien et al, 2023). During WHO consultation processes,
the industry framed taxation as an ineffective approach to tackling
Opponents of the policy changes have long argued the economic harmful consumption and expressed concerns over its potential to boost
relevance of the alcohol sector, in the maintenance of jobs, revenues for illegal trade. They also highlighted trends indicating that alcohol con­
the private sector and the government, and for the economic develop­ sumption has decreased without heightened excise taxes (O’Brien et al.,
ment of rural areas, contributing to territorial cohesion. This has been 2023).
used both in domestic discussions related to alcohol tax increases (Jer­ It is striking that the alcohol industry’s approach consistently asserts
nigan et al., 2011; McCambridge et al., 2018) and in discussions with its commitment to public health goals (Babor et al., 2010; Bakke &
intergovernmental organizations such as the World Trade Organization Endal, 2010; Hawkins & Holden, 2014; Hawkins & McCambridge, 2014;
and the WHO (Barlow et al., 2022; Foundation for Alcohol Research & Hope, 2006; Kypri et al., 2014; McCambridge et al., 2018, 2018; O’Brien
Education, 2022). In their study of the WHO’s consultation process for et al., 2023; Savell et al., 2016). Yet, this strategy masks the focus of
the Alcohol Action Plan 2022–2030, O’Brien et al. (2023) meticulously their argumentation on economic interests (O’Brien et al., 2023).
examined the framing techniques used by the alcohol industry at a
global level. The comparison with their results shows the consistent use
Health-related NGO perspectives on alcohol taxation and policy
of similar lobbying strategies at both the global and EU levels, with
arguments predicated on the economic impact being a prominent
Similar to the alcohol industry, the interconnectedness of public
feature across these discussions, emphasizing the significant contribu­
health-related organizations was noted. Health-related NGOs often
tions of the alcohol sector to society through employment and overall
cooperate with other NGOs active in alcohol policies, such as The Eu­
economic prosperity.
ropean Alcohol Policy Alliance, the European Public Health Alliance,
Yet, the emergence of different positions within the alcohol industry
and The European Association for the Study of the Liver.
in the discussion of the structure of excise duties revealed that the
Arguments from these NGOs and other advocacy groups were not
industry’s arguments are not unanimous, demonstrating the specific
systematically presented in the existing literature, presumably because
interests of the wine, beer, or spirits industry concerning taxation. The
the focus has been predominantly on the alcohol industry’s tactics in
spirits industry has framed the current taxation structure, based on
opposing alcohol taxation. These advocates have reiterated that taxation
product categorization rather than alcohol content, as unfair and sup­
is an effective tool for prevention, in accordance with “best buy” rec­
ported the change to a structure of excise duties based on the alcohol
ommendations from public health organizations (WHO, 2017), but they
content of beverages. The beer industry pushed for low taxes on low-
also advocate for additional measures, particularly when combined with
alcohol content beverages, to encourage the creation – and consump­
further actions such as restrictions on the availability of alcohol and
tion – of new, lower-alcohol beers, whereas the wine industry claimed
advertisement bans. Moreover, these NGOs have highlighted that it is
that higher taxation of wine or based on pure alcohol content would
the EU’s responsibility to set measures for alcohol-related morbidity and
disrupt competition across beverage sectors. While the spirits industry
mortality prevention, namely through taxation and control of
position had been already identified (Srivastava et al., 2022), the posi­
cross-border acquisitions. As O’Brien et al. (2023) concluded, it may be
tions and arguments of the beer and wine industries had not previously
more challenging for single governments to withstand the influence of
been reported in the literature, emerging in these competitive lobbying
commercial actors, such as those encountered in alcohol control poli­
processes.
cymaking. Being part of an intergovernmental organization can assist
Despite the different views on the alcohol taxation structure, the
individual Member States in resisting industry positions and arguments.
alcohol industry resorted to the argument of ‘moderate consumer
The high presence of health-related NGOs in these feedback and
penalization’ (Drink Industry Group of Ireland, 2002; Hawkins &
consultation processes, along with their health-focused argumentation,
Holden, 2013b). At both the EU and global levels the industry (espe­
demonstrates their lobbying efforts at the EU level, strategically man­
cially the wine sector) advocates that moderate consumption is part of a
aging their resources, which are more limited than those from the
healthy lifestyle, being beneficial for cardiovascular health and not
alcohol industry (Madden & McCambridge, 2021).
associated with any risks (McCambridge et al., 2018; O’Brien et al.,
2023; Petticrew et al., 2018; Romanus, 2006).
The argument that higher taxation could lead to more harm, often Diverse rationales in cross-border alcohol policy
used by representatives of the alcohol industry, alleges that higher
taxation could cause a shift to the use of low-quality products (Gehrsitz On the initiative to tackle cross-border acquisitions throughout the
et al., 2021; Stafford et al., 2020). The misinterpretation of scientific EU, the emergence of various rationales for the same positions was
evidence (Carragher & Chalnersm, 2011) or the funding of research unexpected. While health-related NGOs called for increased enforce­
teams and journals is long known (Babor & Robaina, 2013; Bennett ability to ensure the effectiveness of taxation efforts, some alcohol in­
et al., 2023; McCambridge, Hawkins et al., 2013; Mitchell & McCam­ dustry representatives argued that high taxes are the origin of cross-
bridge, 2022; Petticrew et al., 2018; Stenius & Babor, 2010), as is the border acquisitions, a rationale previously mentioned by the Finnish
questioning of the evidence on the effectiveness of taxation or com­ alcohol industry (Sagan, 2018). The advocacy for new regulations with
plaints about policies being too restrictive (Barlow et al., 2022; Drink more straightforward enforcement had not previously emerged in the
Industry Group of Ireland, 2002; Hawkins, 2013b; Stafford et al., 2020). literature.

8
S. Baumann and T. Leão International Journal of Drug Policy 129 (2024) 104475

Outcomes of these initiatives juggled by opponents. Economic arguments against the policy changes,
particularly regarding the impacts of taxation on employment and the
In response to the 2017 and 2018 initiatives, the EU Council set out a private sector, were primarily raised by the alcohol industries and
series of new rules through Council Directive 2020/1151, amending the agricultural sectors. The alcohol industry often downplayed the health
existing Directive 92/83/EEC to modernize the harmonization of excise risks of alcohol and the magnitude of its consumption and framed
duty structures on alcoholic beverages. As a notable change, applicable taxation as an ineffective alternative in the control of alcohol-related
since 2022, the Directive raised the maximum alcohol volume for lower- mortality. Yet, different positions regarding the structure of alcohol
strength beer eligible for reduced excise rates from 2.8% to 3.5% for taxation were found, with the spirits, wine, and beer industries showing
small independent breweries (European Council, 2020). This aims to different interests, a disunion that can be used to thwart their lobbying
support the competitiveness of independent small producers without efforts. In contrast, proponents, including health-related NGOs, advo­
distorting competition in the internal market (European Commission, cated for taxation as an effective tool for the prevention of alcohol-
2021b). The option to apply a reduced tax rate to drinks made by small, related harm, highlighted the EC’s responsibility in public health pol­
independent producers was extended from independent beer producers icy, and called for effective regulations with easier enforcement and
to producers of other types of alcoholic drinks like wine, cider, and Port complementary interventions.
wine (European Council, 2020). Additional technical amendments were With the insights from the study, non-governmental and govern­
allegedly made to facilitate the more efficient trade of excise goods and mental institutions advocating for public health-promoting policies can
increase the transparency of their movement, intending to reduce excise be better positioned to proactively engage in these discussions at the EU,
duty fraud. No change was observed regarding the exemption from national, and regional levels. Equipped with this knowledge and with
excise duty rules for denatured alcohol not meant for human con­ the existing evidence, they may predict the arguments most frequently
sumption, used by the cosmetics or chemical industry. EC adoptions of used by opponents of alcohol-control policies and present effective
the 2021 and 2022 initiatives were planned for the third quarter of 2021 counterarguments in the health, economy and trade arenas, challenging
and the second quarter of 2023, respectively, but yet to be released at the narratives posed by the alcohol industry. These lobbying efforts must
date (April 2024). The EC and its Member States continue to monitor be monitored, as their impact on policies adopted at national and in­
and assess the efficacy of the excise duty rules, looking at both economic ternational levels, and on health, for a higher transparency and
impacts and health outcomes, with annual publication of reviews of the accountability of lobbying groups and policymakers.
impact of taxation policies.
In the meanwhile, in 2022, the 75th World Health Assembly Acknowledgements
approved the Global Alcohol Action Plan which articulates a crucial
operational principle: the development of public policies aimed at The authors thank the contributions of the Scientific Committee of
reducing the harmful use of alcohol must be safeguarded from com­ the Institute of Public Health of Porto University on the review of this
mercial and other vested interests that may compromise public health manuscript. This work was supported by FCT - Fundação para a Ciência
goals, in line with national laws. This reflects the global experience of e Tecnologia, I.P. through the projects with references UIDB/04750/
significant challenges in enacting the Global Strategy, particularly 2020 and LA/P/0064/2020 and DOI identifiers https://doi.org/
concerning the influence of commercial interests in policymaking 10.54499/UIDB/04750/2020 and https://doi.org/10.54499/LA/P/
(McCambridge & Lesch, 2024; WHO, 2020; WHO, 2022). In light of this, 0064/2020. The funders of the study had no role in study design, data
the plan’s communication can serve as a catalyst for the European collection, data analysis, data interpretation, or writing of the
Union, encouraging it to adopt a similar approach with the imperative to manuscript.
protect public health.
CRediT authorship contribution statement
Limitations
Selina Baumann: Writing – original draft, Investigation, Formal
The analysis of comments submitted to a discussion platform does analysis. Teresa Leão: Writing – review & editing, Writing – original
not allow us to explore the actors lobbying through other means, nor draft, Visualization, Validation, Supervision, Project administration,
their strategies or arguments used. Similarly, we cannot unveil argu­ Methodology.
ments posed by actors that reflect the interests of their employers or
have been financed by others, namely the alcohol industry. Finally, not Declaration of competing interest
all European countries were represented in the comments submitted,
probably because their view was being represented by EU-level actors, The authors declare that they have no known competing financial
such as NGOs, trade associations, or international representatives of the interests or personal relationships that could have appeared to influence
alcohol industry, or not all countries show the same economic interests the work reported in this paper.
in this area. Countries where EU organizations and satellite lobbying
ones are based, like Belgium, and countries whose economies are greatly Supplementary materials
related to the beer industry could be more affected by policy changes
and may thus be overrepresented in these feedback and consultation Supplementary material associated with this article can be found, in
processes. the online version, at doi:10.1016/j.drugpo.2024.104475.

Conclusion
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