Submission to WHO public consultation on the draft guideline ‘fiscal policies to promote healthy diets’

The George Institute for Global Health is pleased to contribute to the public consultation on the World Health Organization (WHO) draft Guideline on fiscal policies to promote healthy diets in February 2023.

We applaud the World Health Organization (WHO) for recognising that Member States may benefit from additional guidance to help them establish or strengthen fiscal policies on food and non-alcoholic beverages as part of a larger package of policies to promote healthy diets and, in so doing, reduce the burden of non-communicable diseases (NCDs).

In our response, we shared recommendations including (but not limited) to:

1. Create a shorter and more concise document that explicitly mentions that evidence availability and certainty are linked to the level of implementation. Therefore ‘conditional’ recommendations, if well designed, would be expected to have a desirable and large effect. Otherwise, the guideline runs the risk of undermining the importance of implementing fiscal policies for healthy diets beyond taxes on sugar-sweetened beverages.
2. Strengthen adaptation and implementation of the guideline by specifying that its primary audience is Member States and including considerations on substitution and reformulation and its impact on the effectiveness of taxes.
3. Address more directly the legitimate equity concerns of consumers and other stakeholders; including the affordability and accessibility of healthy foods.
4. Define the terms ‘healthy diets,’ ‘subsidies,’ ‘non-alcoholic beverages’ and ‘discretionary foods’.
5. Include recommendations that (1) further research needs to be done to shed a light on this issue, and (2) consider gender-responsive budgeting for fiscal policies.

This submission was prepared by members of the Food Policy, Health Systems Research, and Impact and Engagement Team, in addition to a complementary, joint submission that was co-developed with the NCD Alliance.

We congratulate the WHO on the development of the Guideline and stand ready to collaborate to address research gaps and considerations identified by the WHO.