4 May 2018

Hon MP Minister for Health PO Box 6022 House of Representatives Parliament House CANBERRA ACT 2600

Dear Minister

The World Health Assembly (WHA) will soon be meeting in Geneva (21-26 May). As we look ahead to that event, and the deliberations on the Outcome Document (OD) for the United Nations (UN) High Level Meeting (HLM) on Non Communicable Diseases (NCDs) expected to start in June, we would like to provide our perspective for whole of Government position relating to alcohol.

WHA agenda

There are two items that are of interest to the Australian wine industry:

 The Preparation for the UN HLM on NCDs.  The Impact Framework of the 13th General Programme of Work (GPW) for the World Health Organization (WHO), as it proposes measuring harmful use of alcohol with the sole indicator of alcohol per capita consumption.

Framework of the 13th General Programme of Work We recognize there are legitimate concerns relating to the harmful use of alcohol, and we fully support the UN-wide consensus that the focus should be on reducing the harmful use of alcohol. However, while we welcome the changes made to the draft General Programme of Work (GPW) itself, we remain concerned with WHO’s proposal to use alcohol per capita consumption (APC) as the sole indicator of progress, as described in the WHO Impact and Outcome Framework for the GPW (2019-2023).

By focusing on consumption per se, WHO would have two different approaches to measure progress on reducing harmful use of alcohol. The Global Strategy to Reduce the Harmful Use of Alcohol (2010) clearly directs action on harmful use and not a narrow focus on per capita consumption. What is proposed in the Impact Framework in terms of measuring progress on reducing harmful use of alcohol is inconsistent with the indicators for the same health goal adopted by the WHA in 2013.

The WHA endorsed the WHO Global Action Plan for the Prevention and Control of NCDs 2013-2020, which included 2 additional indicators for the harmful use of alcohol. Member States agreed that APC was insufficient and that these two indicators were necessary to provide a complete picture about the harmful alcohol use:

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1. Age-standardized prevalence of heavy episodic drinking among adolescents and adults, as appropriate, within the national context; and, 2. Alcohol-related morbidity and mortality among adolescents and adults, as appropriate, within the national context.

We seek your support in ensuring that the General Programme of Work and its accompanying resolution, which do not make mention of APC, remain unchanged.

Additionally, we seek your support in ensuring that these two elements are included in the Indicator Framework, guaranteeing consistency between the GPW indicator, those adopted by the World Health Assembly, and the SDG (Sustainable Development Goal) indicators.

Preparations for UN High Level Meeting on NCDs We fully support the mandate given by Member States to WHO to focus on reducing the harmful use of alcohol, not on alcohol consumption per se. We also support the “whole of government, whole of society” approach, including the private sector, promoted by UN agencies and Member States to achieve the SDGs, and we will continue to play an active and important role in this approach. To this end, we believe there should be positive language in the outcome document of the HLM on NCDs that acknowledges the contribution of, and the important role played by many in the Beverage Alcohol Industry in combatting the harmful use of alcohol.

There are a number of issues arising from the documentation circulated for the meeting:

1. We note some significant changes to Document A71/14, the Report by the WHO Director General on the Preparation for the 3rd HLM on NCDs. We are pleased to note that the reference to per capita consumption was removed from the latest draft of the NCD report by the Director-General, as well the removal of the claim that “industry interference is one of the commercial determinants of health.” 2. Nonetheless, we have concerns with the negative references to the impact of economic, market, and commercial factors. We believe that focusing on country implementation of bans on advertising is disproportionate and inconsistent with the idea of promoting a range of policy options to address the harmful use of alcohol.

Conclusion

We support efforts to reducing the harmful use of alcohol and believe that industry and government play an important role. We also support the consideration of a broad range of policy options as the most effective means of addressing the problem. The impact of not doing so would result in ineffective mechanisms for addressing the issue and could create unnecessary trade implications. We therefore seek a “whole of government, whole of society” approach from the , which considers the issues we’ve raised above, in preparation for the upcoming meetings. I would be happy to discuss this further.

Yours sincerely

Tony Battaglene Chief Executive

Copy: Hon MP, Minister for Agriculture and Water Resources Senator the Hon , Assistant Minister for Agriculture and Water Resources Senator the Hon Bridget McKenzie, Minister for Rural Health