Commercial use of evidence in public health policy: a critical assessment of food industry submissions to global-level consultations on non-communicable disease prevention

Kathrin Lauber, Darragh McGee, Anna Gilmore

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Ultra-processed food industry (UPFI) actors have consistently opposed statutory regulation in health policy debates, including at the WHO. They do so most commonly with claims that regulatory policies do not work, will have negative consequences or that alternatives such as self-regulation work well or better. Underlying this are often assertions that industry is aligned with principles of evidence-based policymaking. In this study, we interrogate if this holds true by exploring the extent and quality of the evidence UPFI respondents employed to support claims around regulatory policy, and how they did this. First, we identified all submissions from organisations who overtly represent UPFI companies to consultations held by the WHO on non-communicable disease policy between 2016 and 2018. Second, we extracted all relevant factual claims made in these submissions and noted if any evidence was referenced in support. Third, we assessed the quality of evidence using independence from UPFI, nature, and publication route as indicators. Lastly, where peer-reviewed research was cited, we examined if the claims made could be justified by the source cited. Across 26 included consultation responses, factual claims around regulation were made in 18, although only 10 referenced any evidence at all. Of all 114 claims made, 39 pieces of identifiable evidence were cited in support of 56 claims. Of the 39 distinct pieces of evidence, two-thirds were industry-funded or industry-linked, with only 16 externally peer-reviewed. Over half of industry-funded or industry-linked academic articles failed to declare a conflict of interest (COI). Overall, of only six claims which drew on peer-reviewedandindependent research, none appropriately represented the source. UPFI respondents made far-reaching claims which were rarely supported by high-quality, independent evidence. This indicates that there may be few, if any, benefits from consulting actors with such a clear COI.

Original languageEnglish
Article numbere006176
JournalBMJ Global Health
Issue number8
Publication statusPublished - 23 Aug 2021

Bibliographical note

Funding Information:
Statement included that the research was financially supported by a food industry entity (ie, UPFI corporations, business associations, and other organisations majority funded or run by UPFI corporations). No statement or other indication that the research was directly funded by the UPFI, but evidence of other connection: for example, author(s) or publishing organisation has financial links to UPFI entities (within five years of publication).


  • health policy
  • nutrition
  • prevention strategies
  • public health

ASJC Scopus subject areas

  • Public Health, Environmental and Occupational Health
  • Health Policy


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    Gilmore, A. & Rutter, H.



    Project: Research council

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