A/79/177
81. “Surrogate marketing” 177 is frequently an avenue to circumvent legally
mandated advertising bans or restrictions. 178 Such tactics are often combined with
sponsorship or other corporate social responsibility programmes, 179 with dubious
health benefits that increase brand reputation, 180 and these must stop.
82. In the action plan 2022–2030 to effectively implement the global strategy to
reduce the harmful use of alcohol as a public health priority, WHO provides steps for
both the prevention and the treatment of alcohol use disorders. 181 In 2023, for the first
time, WHO included two medications for the treatment of alcohol use disorders on
the Model List of Essential Medicines. 182 The action plan further emphasizes the need
to reduce the harms of alcohol for people with alcohol use disorders, as well as for
their families, friends and communities. 183
83. States have obligations under the Framework Convention on Tobacco Control 184
to use revenue from tobacco taxes to build robust cessation programmes. 185
84. Action that States can take to reduce harm stemming from diet-related
non-communicable diseases includes: measures to protect biodiversity and the
enjoyment of the right to land; requiring the food industry to provide accurate and
easy-to-read information through front-of-package nutrition labelling; and healthy
food procurement policies. Fiscal policies, including taxation and subsidy strategies,
can redistribute the relative cost of food, thereby promoting equity and empowering
decision-making. 186
85. Likewise, action is needed by States with respect to breast-milk substitutes,
which are indirectly cross-promoted through the marketing of toddler milks that use
similar colour schemes, designs, names, slogans or mascots, in an attempt to
circumvent the provisions of the International Code of Marketing of Breast-milk
Substitutes. Such practices create confusion and may pose risks for infants’ health. 187
86. Children, particularly those who are of lower socioeconomic status within high income countries, are vulnerable to the advertising of unhealthy food and drinks.
States are required to reduce children’s exposure to food and beverage advertising. 188
VII. Harm reduction in humanitarian and emergency settings
87. Humanitarian and emergency settings, including conflicts, pandemics, natural
disasters and other crises pose distinct threats and harms to health. Each individual’s
__________________
177
178
179
180
181
182
183
184
185
186
187
188
24-13226
WHO, Reducing the Harm from Alcohol, p. xv (Glossary). There is discussion in the literature
regarding the use of the terminology to refer to these practices, using other terms including “alibi
marketing” and “brand marketing” to refer to similar, albeit not identical, tactics. See Nathan
Critchlow, John Holmes and Niamh Fitzgerald, “Alibi marketing? Surrogate marketing? Brand
sharing? What is the correct terminology to discuss marketing for alcohol‐free and low‐alcohol
products which share branding with regular strength alcohol products?”, Addiction (2024).
WHO, A Public Health Perspective on Zero- and Low-Alcohol Beverages, Snapshot Series on
Alcohol Control Policies and Practice, Brief No. 10 (Geneva, 2023).
WHO, Reducing the Harm from Alcohol, p. 23.
Submission from Global Health Advocacy Incubator.
WHO, Global Alcohol Action Plan 2022–2030 (Geneva, 2024).
WHO, “Landmark public health decision by WHO on essential medicines for alcohol use
disorders”, 8 August 2023.
WHO, Global Alcohol Action Plan 2022–2030.
See www.who.int/teams/health-promotion/tobacco-control/quitting/offer-help-to-quit-tobacco-use.
Ibid.
A/78/185, paras. 78 and 80.
WHO and UNICEF, “WHO/UNICEF information note: cross-promotion of infant formula and
toddler milk”, 2019.
A/HRC/26/31, para. 22; and A/78/185, para. 78.
19/28