Abstract
Although alcohol is a leading cause of health and social harms in Canada, policies directed at alleviating the public health burden created by alcohol are rarely adopted and often reversed. This study analyses alcohol-related policy lobbying activity to better understand how lobbying might impact policy development in Canada. This was deemed not human subjects research. A cross-sectional analysis was conducted using data from the federal Canadian Registry of Lobbyists to characterize the frequency and nature of alcohol industry and public health lobbying activities between May 2022 and May 2023. In this period, there was substantially more lobbying activity by alcohol industry representatives compared to public health stakeholders. Over three-quarters of lobby groups represented alcohol industry organizations (n = 13) compared to public health organizations (n = 4), with industry recording a majority of registered lobbyists (81.3%), meetings reported (66.2%), and number of officials lobbied (71.2%). Alcohol industry organizations predominantly lobbied bureaucrats in policy making/governance roles (54.2% of industry meetings), while public health stakeholders mainly lobbied legislators (60.4% of public health meetings). The alcohol industry’s dominance in federal lobbying activities may enable corporate influence over alcohol policy development and undermine public health approaches. The nature of lobbying in Canada has international implications for the regulation of a product that is an important commercial determinant of health, showing the potential role lobbying may play in weakening alcohol regulation.
Keywords: lobbying, commercial determinants of health, alcohol drinking, legislation, federal government, Canada
Contribution to Health Promotion.
Alcohol use is a leading cause of health and social problems in Canada and worldwide.
Alcohol control policies can reduce alcohol-caused harms, but lower sales reduce revenue for alcohol companies.
Alcohol companies often lobby against policies to reduce harms, but these lobbying activities are not well characterized or understood by the public, policy makers or health officials.
This paper outlines the magnitude and nature of alcohol lobbying at the federal level in Canada which has not been studied previously.
This research offers insight in industry lobbying which may be similar across nations as major alcohol companies operate internationally.
INTRODUCTION
Alcohol contributes to a variety of diseases and lifelong conditions (e.g. cancer, foetal alcohol syndrome) and is a factor in a range of social problems (e.g. impaired driving, domestic violence) (World Health Organization 2018). In 2020, approximately 17 000 Canadians died from alcohol-attributable causes, and alcohol cost Canada $19.7 billion in lost productivity, medical costs, and criminal justice proceedings (Canadian Substance Use Costs and Harms Scientific Working Group 2023). There are a range of effective policies which can be used to curtail the harm caused by alcohol (e.g. policies affecting alcohol affordability and availability), however these policies have either not been adopted or have been implemented sub-optimally (Babor et al. 2022, Farkouh et al. 2024). One major contributing factor to this lack of progress may be alcohol industry involvement in and interference with policy development (McCambridge et al. 2018, Mialon 2020, Gilmore et al. 2023). Commercial interests have extensive capacity to engage with and influence governments. These activities include many forms such as political donations, meeting with public servants, public tenders, consulting, participating in policy developments, grass roots advocacy campaigns, and hiring former politicians and public servants (Lacy-Nichols et al. 2024).While industry interference with alcohol policy has been characterized qualitatively (McCambridge et al. 2018), knowledge about the quantitative extent of these lobbying activities is limited. Therefore, to understand the extent of industry and public health advocate lobbying on national alcohol policies, this study will look towards federal, alcohol-related lobbying in Canada.
To participate in and influence policy discussions, the alcohol industry positions themselves and their products as a socially and economically positive or neutral force (Mialon 2020, Gilmore et al. 2023, Ulucanlar et al. 2023, Aravena-Rivas et al. 2024). Globally, advocacy organizations funded by the alcohol industry have consistently published reports that discredit or downplay research on the ill-effects of alcohol, such as the evidence for light and moderate drinking increasing cancer risks (Petticrew et al. 2018). Corporate Social Responsibility organizations associated with producers—which take the form of both industry third parties and front groups—shift blame for harms, influence policy-making, enhance brand image and credibility, and pre-emptively address threats to business practices (Burgess et al. 2024a). Simultaneously, these organizations have promoted research which frames alcohol as having health benefits, such as claiming wine is positive for heart health (Miller et al. 2023).
Beyond claiming alcohol is healthy, the alcohol industry focuses on so-called ‘problem drinkers’ to distract from the substantial harm caused by their products among the general population (Miller et al. 2023). By spending money on anti-impaired driving or addiction support campaigns, the alcohol industry distracts from the other health harms caused by their products (e.g. chronic disease risk) while also framing themselves as supporters of the public good (Babor et al. 2018). Thus, these public advocacy campaigns often serve as a form of advertising for alcohol companies. When it comes to alcohol warnings, the industry staple is to say, ‘drink responsibly’ without defining ‘responsibly’ (Maani and Petticrew 2017). Beyond health framings, the industry also acts to depict themselves as a key, productive part of the national economy (McCambridge et al. 2018). Together, these industry tactics contribute to a pro-alcohol culture around the world and in Canada, laying the groundwork for a permissive political environment.
Informal lobbying performed by the alcohol industry serves to create an artificial, self-legitimizing platform and information basis for direct lobbying. Direct lobbying (henceforth simply referred to as lobbying) occurs when a stakeholder communicates with a government official to provide them with information and perspective on the predicted effects of a proposed policy or how a current policy is affecting that stakeholder (Gold 2020). This lobbying is directed at both legislators in a position to pass laws and bureaucrats in a position to advise legislators on which policy options to consider and to make practical governance choices on how laws are enacted. The alcohol industry’s primary lobbying strategy is building long term relationships with officials (Hawkins and Holden 2014). These relationships provide a consistent block of support for the alcohol industry when facing regulatory pressure. Within lobbying communications, alcohol industry representatives are often highly coordinated in promoting particular messages, creating consistent ideas within their influence campaigns (Kypri et al. 2014, Lesch and McCambridge 2022). Heterogeneity has been observed in the way that different segments of the alcohol industry have responded to minimum pricing laws (Herrick 2010). Similar to public outreach efforts, these coordinated lobbying messages often centre around distracting from the issue at hand by framing alcohol as problematic for only certain segments of the population (e.g. young or heavy drinkers) (Katikireddi et al. 2014, Kypri et al. 2014). Through these lobbying strategies, industry representatives direct the political and governance conversations about alcohol regulations towards their interests (Gilmore et al. 2023).
While these strategies have been well observed, the extent to which alcohol industry actors use these strategies and the specific parts of government to which they direct their lobbying are not well known in Canada, particularly in quantitative analyses. The Canadian Registry of Lobbyists (Office of the Commissioner of Lobbying 2023) is a unique data source that can identify alcohol industry strategies that can provide insight as to why health policies not implemented or reversed in Canada and also provides a mechanism by which to assess whether lobbying activities in Canada are similar to those in other countries.
This study examines the Canadian Federal Registry of Lobbyists to quantify recorded lobbying efforts related to alcohol from May 2022 to May 2023 by industry and non-industry stakeholders. Statistical understandings of alcohol industry influence efforts have been limited to analysis of the source of public comments regarding particular legislative actions and money spent on lobbying (Kypri et al. 2014, 2018, Chung et al. 2024). Both methods carry limited representational power as each only reveals the extent to which organizations attempt to lobby the government, not the specific degree to which interest groups are meeting with government officials nor the areas of government lobbied. Canada’s Federal Registry of Lobbyists represents a distinct opportunity to track and quantify lobbying activity as it provides specific data on the attendees in meetings lobbyists and government officials, allowing for a more detailed analysis of the substantive extent of lobbying activity and where those efforts are being directed across stakeholder groups. Moreover, this study may further the understanding of the reasons behind the lack of health-oriented alcohol policy in Canada in particular.
MATERIALS AND METHODS
Lobbying registry and lobbying regulation
The Registry of Lobbyists, the federal repository for formal lobbying activity in Canada, served as the basis of our analyses. Under the Canadian federal Lobbying Act, lobbying is defined as a paid individual scheduling and attending formal meetings with public office holders (Office of the Commissioner of Lobbying 2023). Anyone who lobbies on behalf of an organization that is not their primary employer is considered a consultant lobbyist, while anyone who spends 20% or more of their time lobbying on behalf of their employer is considered an in-house lobbyist. Both lobbyist types are required to register as lobbyists and record all meetings they have with officials. Each organization only has one registered senior in-house lobbyist who is responsible for recording all meetings between members of their organization and public officials (Office of the Commissioner of Lobbying 2022). In registering, the lobbyist must describe the policy positions for which they are advocating. After a lobbyist meets with a public official, they must record their meeting by the 15th of the following month. All meeting reporting is completely reliant on the lobbyist with minimal external monitoring and enforcement of such reporting. In recording these meetings, the lobbyist must describe the topics discussed, although there is no specification regarding the level of detail required. Because of this lack of specification, it is generally not possible to determine which specific policies are discussed in any particular meeting. Rather, the content of these meetings can only be inferred from the overarching list of policies provided by each lobbyist in their registration details.
Study period
This study recorded lobbying from the Registry between May 2022 and May 2023 to coincide with three significant alcohol policy developments in Canada. Specifically, a bill and a motion to mandate alcohol warning labels were introduced in the senate and the house, with the bill moving into committee consideration during that time (M-61 2023, S-254 2023). Given that this law would affect all segments of the alcohol industry equally, it can be assumed that the industry was generally opposed to the implementation of such a law (Herrick 2010). In addition, the new Canadian Guidance on Alcohol and Health was announced for public comment and subsequently released by the Canadian Centre on Substance Use and Addiction (Paradis et al. 2023) –a non-profit organization created through an Act of Parliament to ‘provide national leadership on substance use’ (CCSA 2024). The revised guidance substantially lowered previously recommended limits for low-risk drinking, and recommended implementation of mandatory standard drink and health warning labels for alcohol products (Paradis et al. 2023). Finally, federal alcohol excise taxes were also raised by 2%; lower than the planned inflation-matched raise of 6%, which would have been the highest increase in over 40 years (Woods 2023). According to investigative journalists, the reduction in the tax increase was the result of coordinated efforts by alcohol industry representatives (Woods 2023).
Data source, data availability, and ethics
Lobbying registration and monthly communication report files were downloaded from the Registry of Lobbyists on 23 June 2023. These data are publicly available online at https://lobbycanada.gc.ca/app/secure/ocl/lrs/do/guest. The subject matter details (i.e. policy positions) of lobbying registrations were filtered based on their inclusion of keywords associated with alcohol policy (e.g. alcohol, harmful drinking, S-254). The list of filtered registrations was manually verified to ensure the relevancy of each organization and to confirm the registration had been active within the analysis period. Once deemed relevant for the study, the names of the organizations and their registrant identification (ID) numbers were recorded. Both in-house and consultant lobbyists and their firms were identified. In the registry, the in-house or consultant status of a lobbyist is denoted. All individual consultant lobbyists create a separate registration for each of their clients.
Each of the included organizations was then classified as either an alcohol industry or a non-industry public health group based on the framing of their registration and who they represented. The alcohol industry group was primarily composed of alcohol companies and trade organizations representing sectors of the alcohol industry (e.g. Molson Canada, Beer Canada). The non-industry group was composed of public health organizations whose mandates include advocating for a range of topics that impact health, including alcohol (e.g. Canadian Public Health Association, Canadian Cancer Society). In our analysis there were no non-industry advocacy organizations who may be concerned with alcohol policy but not public health (e.g. groups concerned with domestic abuse or drunk driving) identified. Therefore, our non-industry acts as a representation of public health advocacy organization lobbying and will be referred to as such henceforth. Monthly communication reports were then filtered based on the registration ID numbers of the relevant organizations and by date to ensure that they occurred within the analysis period. The meeting ID numbers, date of communication, official’s name, title, and government office of each meeting were also recorded.
This project was deemed not human subjects research by the University of Victoria.
Analysis
Using the identified data, the organization names were then manually re-entered into the lobbying registry to determine the total number of individual lobbyists working for each organization. Individual lobbyists were counted based on unique registration numbers. Likewise, the number of total meetings was counted based on unique meeting ID numbers. Often, lobbyists were meeting with multiple officials in an individual meeting, so the total number of government officials contacted was counted separately from meetings. To provide scale to the scope and authority of each government official that met with the lobbyists, a segmented analysis was performed which catalogued the officials by their ministry and their position title. Titles were categorized through a separate analysis of comparable job postings for each of the position titles, and by cross-checking job and position descriptions listed on publicly available websites such as LinkedIn (position titles in each category provided in Supplementary Appendix A). In breaking down the position titles into categories there were certain officials whose role and scope could be equally applied across multiple groups; in these situations, those position titles were included in each category which applied to them. As a result, totals in the segmented analysis are slightly larger than the real number of total officials contacted. Descriptive univariate statistical analyses were completed using Microsoft Excel with coding assistance from ChatGPT (Azaria et al. 2024). ChatGPT was used for creating filter commands based on a base-command provided, a list of terms, and instructions on how to change code to fit with different parts of the excel worksheet. No original code nor search terms were generated by ChatGPT. All code generated by ChatGPT was manually reviewed by the first author to ensure accuracy.
RESULTS
In full, the alcohol industry had thirteen organizations that included 39 individual lobbyists; meanwhile, there were four public health organizations that included nine individual lobbyists working under them (Table 1). While public health organizations relied exclusively on consultant lobbyists (n = 9), the alcohol industry were able to hire some in-house lobbyists (n = 3). The alcohol industry organizations had a slightly higher mean lobbyists per organization (x̅ = 3) compared to organizations within the public health group (x̅ = 2.3). Organizations from both groups conducted a total of 471 individual meetings and contacted 620 officials during the study period. Lobbyists representing the alcohol industry were more prevalent across all measures, making up the majority of active organizations (76.5%), individual lobbyists (81.3%), meetings conducted (66.2%), and number of officials contacted (71.2%). The fewer lobbyists representing public health organizations had more than double the mean number of meetings per individual lobbyist (x̅ = 17.7) than their alcohol industry counterparts (x̅ = 8.0). The mean number of officials within each meeting was comparable between alcohol industry (x̅ = 1.6) and public health lobbyists (x̅ = 1.2). No outliers are present across all the measures whose mean values are reported here.
Table 1.
Lobbying activity measures, Canadian Federal Registry of Lobbyists, May 2022–May 2023.
| Stakeholder type | Number of registered organizations (%) | Total number of individual lobbyists serving (%) | Number of consultant lobbyists serving (%) | Mean number of lobbyists per registered organization | Number of meetings (%) | Mean number of meetings per individual lobbyist | Number of officials contacted (%) | Mean number of officials per meeting |
|---|---|---|---|---|---|---|---|---|
| Industry | 13 (76.5) | 39 (81.3) | 36 (80) | 3 | 312 (66.2) | 8 | 485 (71.2) | 1.6 |
| Public health | 4 (23.5) | 9 (18.8) | 9 (20) | 2.25 | 159 (33.8) | 17.7 | 196 (28.8) | 1.2 |
| Total/overall | 17 (100) | 48 (100) | 45 (100) | 2.8 | 471 (100) | 9.8 | 620 (100) | 1.3 |
The distribution of the number of meetings taken by each individual lobbying organization differs between the public health and industry groups, in which the public health meetings are concentrated in a single organization while industry meetings are spread out between the various organizations (Tables 2 and 3). Almost all (96.9%) public health organization meetings involved lobbyists from the Canadian Cancer Society, while no alcohol industry organization represented more than 20.5% of industry meetings.
Table 2.
Description of industry organizations’ meeting activity, Canadian Federal Registry of Lobbyists, May 2022–May 2023.
| Organization name | Brief description of organization | Number of meetings (% of total) | Number of individual lobbyists (% of total) |
|---|---|---|---|
| Coalition of Canadian Independent Craft Brewers | Trade association representing craft brewers | 64 (20.5) | 1 (2.5) |
| Wine Growers Canada | Trade association representing wine producers | 58 (18.6) | 4 (10.3) |
| Labatt breweries of Canada | Beer and Cider company owned by AB InBev | 42 (13.5) | 3 (7.7) |
| Beer Canada | Trade association representing beer producers | 41 (13.1) | 2 (5.1) |
| Molson Canada 2005 | Beer company owned by Molson Coors | 34 (10.9) | 5 (12.8) |
| Association Of Canadian Distillers | Trade association representing spirits producers | 33 (10.6) | 8 (20.5) |
| Canadian Craft Brewers Association | Trade association representing craft brewers | 19 (6.1) | 2 (5.1) |
| Arterra Wines Canada | Wine company owned by constellation brands | 11 (3.5) | 3 (7.7) |
| Grape Growers of Ontario | Regional trade association representing wine growers | 4 (1.3) | 2 (5.1) |
| Diageo Canada | Canadian office of Diageo, a multinational alcohol company | 3 (1) | 5 (12.8) |
| Éduc’alcool | Industry funded SAPRO | 2 (0.6) | 2 (5.1) |
| Paul Leblanc, Deborah Leblanc O/A Smokie Ridge Winery | Locally owned wine grower | 1 (0.3) | 1 (2.6) |
| Sleeman Breweries Ltd. | Beer company owned by Sapporo Holdings | 0 (0) | 1 (2.6) |
| TOTAL | N/A | 312 (100) | 39 (100) |
Table 3.
Description of public health Organizations’ meeting activity, Canadian Federal Registry of Lobbyists, May 2022–May 2023.
| Organization name | Brief description | Number of meetings (%) | Number of individual lobbyists (%) |
|---|---|---|---|
| Canadian Cancer Society | Cancer research and advocacy organization | 154 (96.9) | 4 (44.4) |
| Canada Fetal Alcohol Spectrum Disorder Research Network | Foetal alcohol spectrum disorder research and advocacy organization | 3 (1.9) | 3 (33.3) |
| Centre for Health Science and Law | Non-profit research centre mainly concerned with nutrition policy | 2 (1.3) | 1 (11.1) |
| Canadian Public Health Association (CPHA) | General public health advocacy organization | 0 (0) | 1 (11.1) |
| TOTAL | N/A | 159 (100) | 9 (100) |
The two lobbyist groups focused on different types of government officials: alcohol industry organizations focused more of their lobbying efforts on meetings with bureaucratic (i.e. governance and policy shaping) officials (50.3%), while public health lobbyists conducted more meetings with legislators (60.4%) (Table 4). Of meetings with bureaucratic officials, alcohol industry organizations had more meetings and a higher proportion of meetings with senior staff. Both alcohol industry and public health lobbyists conducted a similar proportion of their total meetings with ministers (3.9% vs 3.6%), while public health organizations had a slightly larger proportion of meetings with associate ministers (7.1%) than alcohol industry organizations (3.9%, Table 4). However, the alcohol industry had a larger proportion of meetings that were conducted with senior policy advisors and director generals compared to public health organizations (18.5% vs 9.6%, 5.1% vs 2.5%).
Table 4.
Types of officials lobbied, by stakeholder type, Canadian Federal Registry of Lobbyists, May 2022–May 2023.
| Position title | Industry (% industry total) | Public health (% public health total) |
|---|---|---|
| Legislators | 226 (45.8) | 119 (60.4) |
| Ministers | 19 (3.9) | 7 (3.6) |
| Associate/Deputy Ministers | 19 (3.9) | 14 (7.1) |
| Senior Policy Officials | 91 (18.5) | 19 (9.6) |
| Non-senior Policy Officials | 44 (8.9) | 17 (8.6) |
| Regional Advisors | 26 (5.3) | 2 (1.0) |
| Chiefs of Staff | 22 (4.5) | 0 (0) |
| Director Generals | 25 (5.1) | 5 (2.5) |
| Sub-directors/Assistant | 7 (1.4) | 8 (4.1) |
| Parliamentary Affairs | 9 (1.8) | 4 (2.0) |
| Other | 5(1.0) | 2 (1.0) |
| Total Non-Elected Officials | 248 (50.3) | 71 (36.0) |
| TOTAL | 493 (100) | 197 (100) |
The alcohol industry group also showed a wide range of institutions lobbied ranging from Agriculture and Agri-Food Canada to Finance Canada (Table 5). Meanwhile, public health groups focused most of their lobbying efforts towards Health Canada. No bureaucratic organization took up more than 11.4% of industry’s meetings, meanwhile Health Canada was the institution for 27.9% of public health meetings. Of all meetings with Health Canada officials, public health had 55 (63.2%) meetings while the alcohol industry had 32 (36.8%).
Table 5.
Federal institutions lobbied, by stakeholder type, Canadian Federal Registry of Lobbyists, May 2022–May 2023.
| Federal institution | Industry (% of industry total) | Public health (% of public health total) |
|---|---|---|
| House of Commons | 248 (50.3) | 117 (59.4) |
| Senate of Canada | 12 (2.4) | 8 (4.1) |
| Innovation, Science and Economic Development Canada (ISED) | 25 (5.1) | 0 (0) |
| Prime Minister’s Office (PMO) | 37 (7.5) | 2 (1.0) |
| Rural Economic Development (Minister’s Office) | 3 (0.6) | 0 (0) |
| Employment and Social Development Canada (ESDC) | 7 (1.4) | 6 (3.1) |
| Agriculture and Agri-Food Canada (AAFC) | 39 (7.9) | 0 (0) |
| Finance Canada (FIN) | 56 (11.4) | 3 (1.5) |
| Environment and Climate Change Canada (ECCC) | 4 (0.8) | 0 (0) |
| Health Canada (HC) | 32 (6.5) | 55 (27.9) |
| Infrastructure Canada (INFC) | 1 (0.2) | 0 (0) |
| Privy Council Office (PCO) | 3 (0.6) | 3 (1.5) |
| Federal Economic Development Agency for Southern Ontario (FedDev) | 5 (1.0) | 0 (0) |
| Intergovernmental Affairs Secretariat (IGA) | 2 (0.4) | 0 (0) |
| Treasury Board Of Canada Secretariat (TBS) | 3 (0.6) | 0 (0) |
| Global Affairs Canada (GAC) | 6 (1.2) | 0 (0) |
| Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC) | 2 (0.4) | 0 (0) |
| Atlantic Canada Opportunities Agency (ACOA) | 2 (0.4) | 0 (0) |
| Pacific Economic Development Canada (PacifiCan) | 3 (0.6) | 0 (0) |
| Public Health Agency of Canada (PHAC) | 0 (0) | 3 (1.5) |
| Canada Revenue Agency (CRA) | 3 (0.6) | 0 (0) |
| TOTAL | 493 (100) | 197 (100) |
DISCUSSION
This study analysed direct alcohol-related lobbying activity recorded in the Registry of Lobbyists from May 2022 to May 2023 to assess the extent of lobbying efforts by alcohol industry and public health groups in Canada. Within the one-year analysis period of the federal lobbyist registry, representatives of the alcohol industry dominated their public health counterparts in lobbying activities across almost every measure analysed. Notably, the alcohol industry represented the majority of identified organizations, individual lobbyists, meetings, and government officials contacted. These results mirror previous research on lobbying around alcohol, food, and other commercial determinants of health policy, which show industry lobbying as similarly overshadowing that of public health efforts (Kypri et al. 2018, Lencucha and Thow 2020, Mulligan et al. 2021, Gaucher-Holm et al. 2022, Chung et al. 2024, Burgess et al. 2024b). Further, in the Canadian context, commercial actors have been shown to be tied to 65% of all lobbying, with a greater rate of lobbying senior officials in that lobbying than other stakeholder types (Boucher and Cooper 2022). In all, compared to public health lobbyists, alcohol industry lobbyists both had more total lobbying activities registered and met more with government officials whose positions include governance and the ability to direct policy.
The alcohol industry lobbied a wide variety of bureaucratic institutions, while public health lobbying activities were focused primarily on communications and meetings with Health Canada. However, based on public communications, officials representing Health Canada still reflect positions supporting alcohol industry interests. For example, when asked about the prospect of implementing mandatory warning labels on alcohol products, the Minister of Mental Health and Addictions at the time said she preferred industry self-regulation over a mandated label (The Canadian Press 2023), even though there is strong evidence that mandated enhanced warning labels on alcohol containers impact perceptions and behaviour (Hobin et al. 2020). The concentration of meetings between public health lobbying groups and Health Canada is more likely a result of the policy positions expressed in their lobbying registrations, which covered a range of health topics in addition to alcohol. Indeed, many public health organization lobbyists had health topics beyond alcohol in their registration details, likely resulting in these topics being discussed in some of the observed meetings. In contrast, based on lobbying within other countries, alcohol is likely to be the primary component of health policy considered by alcohol industry lobbyists (Lesch and McCambridge 2022, Aravena-Rivas et al. 2024). Thus, although alcohol industry and public health stakeholders met with a similar number of senior Health Canada officials, this does not necessarily translate into policy momentum on health-focused alcohol regulation. Further, both lobbyist groups conducted similar numbers of meetings with senior government officials with the authority to make policy changes related to alcohol and health. The alcohol industry’s wide range of government institutions lobbied also likely means their messaging is better translated into how these various institutions relate to alcohol regulation, creating multiple routes of policy influence.
The observation that the alcohol industry focused most of their efforts on lobbying government officials in bureaucratic or policymaking positions is noteworthy. Many government bureaucrats are in unelected roles that may be positions held by the same person for many years. In such cases, bureaucrats may serve over multiple political administrations, meaning time spent lobbying them will have more potential impact on future policy outcomes (Gold 2020) and may represent a better time investment for lobbyists. Furthermore, government bureaucrats typically write the details of how each law will be enacted and allocate funds, meaning they may have as much or more policy influence than legislators (Gold 2020). By consistently and regularly lobbying those in the government’s bureaucracy, alcohol industry lobbyists can also increase the likelihood of developing permissive institutional perceptions towards their products within government which becomes reflected in public health policy (Munro 2004, Bennedsen and Feldmann 2006).
This research is subject to caveats and limitations. The data on official industry lobbying activities accessed for this study represent only a fraction of stakeholder engagement around alcohol policy (Boucher and Cooper 2022). Representatives of the alcohol industry may have additional opportunities to talk with government officials in informal settings which are not captured in the official lobbying registry. For example, major industry groups will hold receptions where they can speak with politicians and discuss any number of topics without the interaction counting as a lobbying activity (Gold 2020). This type of ‘soft lobbying’ has been observed as a tactic used by the alcohol industry in Ireland (Lesch and McCambridge 2022).
Likewise, the registry does not capture meetings with groups that do not spend more than 20% of their time on lobbying activities and are therefore not obligated to register as lobbyists. This may include research scientists and subject matter experts who can provide evidence-based recommendations on a specific issue but could also include alcohol industry representatives who focus only a small portion of their time on lobbying activities (e.g. independent vintners); none of these engagements are captured by the registry of lobbyists. Also, given that only the senior in-house lobbyist is required to register and record all of the meetings conducted by members of their organization, this study may be missing a series of in-house lobbying personnel who schedule and attend meetings with officials. Also, as noted by Lacy-Nichols et al. (2024) in their scoping review of lobbying disclosures, it was not possible to add weighting to the interactions that we documented because all lobbying activity was treated as equally important. Finally, within this analysis we did not determine if organizations lobbied together or coordinated lobbying such that multiple meetings on the same topic or with the same government stakeholder occurred on the same day. Analysis of such coordinated efforts represents a potential area for further research.
While Canada has moderately strong federal regulations around lobbying, these rules have substantial loopholes and the extent to which lobbyists follow the existing rules is unclear. Beyond inundating officials with information that supports their position, lobbying opens the door towards soft corruption. For example, there is the ‘revolving door’ of lobbying in which officials will be more supportive of the policies supported by large corporations in hopes of being given a high-paying lobbying position after leaving office (Fry 2022). To address this, former officials are not allowed to serve as a lobbyist until five years after leaving office. Still, given the allowance that individuals can spend less than 20% of their time lobbying and not be considered a lobbyist, former officials can and have legally become unregistered lobbyists shortly after serving (Chari et al. 2007).
Previous research on the lobbying behaviour of unhealthy commodity industries shows these industries hiring formal officials to conduct their lobbying activities at high rates (Robertson et al. 2019, Chung et al. 2024) Similar risks of potential corruption exist for compliance with gift and hospitality spending limits for lobbyists (Chari et al. 2007, Gold 2020). Beyond potential corruption, as the registry is currently designed, there is no way to authenticate the accuracy and completeness of the meetings recorded. Meeting recording is the responsibility of lobbyists, not officials, with minimal authentication of the accuracy and completeness of the meetings recorded. In a qualitative study, lobbyists revealed that they follow the reporting requirements more to advertise the scope of their operation to potential clients than out of fear of potential repercussions (Chari et al. 2007). All these factors raise questions over the accuracy of the data and how representative it is of the degree of influence exerted.
Lobbying groups were included in the analysis only if they explicitly placed terms associated with alcohol in their registration subject matter details. However, the topic of alcohol has a great amount of spill-over into other types of private industry groups who do not directly produce alcohol (i.e. restaurant and bar owners) but still profit from alcohol in some capacity (Herrick 2010). While these groups did not mention alcohol in their registrations and thus were not identified for inclusion in the current analysis, it is possible that they also lobby in favour of alcohol deregulation. For example, the hospitality industry has been demonstrated to follow the alcohol industry in lobbying for limited regulation through the promotion of common messages which distract from the primary issue (Kypri et al. 2014). As a result, our findings are likely an underestimation of the full extent of alcohol industry lobbying of federal, public officials occurring in Canada.
CONCLUSIONS
The results of this study indicate that there is a substantial and disproportionate level of alcohol industry lobbying of high-level government officials in Canada compared to public health lobbying. The alcohol industry’s substantial presence and level of activity recorded within the federal Lobby Registry points to their potential ability to influence alcohol policy through ongoing lobbying of government officials. This may be an important contributing factor to Canada’s relatively weak alcohol regulatory environment (Farkouh et al. 2024), along with Canadian alcohol companies’ overall contributions to the economy. These direct lobbying activities also provide a sense of scope to the power of the alcohol industry, as the results of this study only serve as a quantifiable ‘tip of the iceberg’ of overall industry activity (Gilmore et al. 2023). As mentioned previously, the alcohol industry funds research, social aspects public relations organizations and a variety of other activities to support their objectives (Ulucanlar et al. 2023). These actions are mirrored by more obvious forms of cultural ingratiation such as widespread alcohol advertising. Furthermore, there are a series of other avenues of policy influence (i.e. campaign finance) which are also afforded by the wealth and power demonstrated in the results of this study. The results of this study may reflect alcohol lobbying in other countries, particularly high-income countries.
To close the gap between industry and public health voices being heard by policy makers and to facilitate more health-oriented policy, substantive regulation on the volume and mode industry lobbying activity on both alcohol and other corporate determinants of health is needed. Meeting descriptions ought to be made more specific, outlining the specific policies discussed, as is the case in Chile (Aravena-Rivas et al. 2024). Ideally, enforcement and compliance could also be enhanced through an independent oversight agency. These reporting schemes should also be extended to provincial and territorial governments that likewise play a key role in shaping the regulatory landscape around alcohol. Alternatively, policies should be put into place that expressly limit lobbying by alcohol industry actors. Such an expansion in lobbying regulation may be facilitated through the adoption of a WHO framework convention targeted at alcohol which includes provisions on limiting lobbying for alcohol producers, similar to the current convention on tobacco control (Room and Örnberg 2021). However, as it stands, any health policy around alcohol will likely continue to be blocked or deflated because of industry’s dominance over lobbying. To promote effective public health focused alcohol policy, stricter lobbying regulations and increased lobbying transparency are needed. In addition, based on our findings public health lobbying is under-resourced relative to industry-backed lobbying, and might benefit from adopting tactics to reach a broader range of government officials, particularly those whom are un-elected and who may be in longer-term government roles than elected officials.
Supplementary Material
Acknowledgements
We wish to acknowledge Raquel Burgess and the University of Victoria Library staff for providing resource suggestions.
Contributor Information
Aaron Grinberg, Canadian Institute for Substance Use Research, University of Victoria, 2300 McKenzie Ave., Room 273, Victoria, BC, Canada V8P 5C2; Reed College, 3203 SE Woodstock Blvd., Portland, OR 97202, United States.
Kate Vallance, Canadian Institute for Substance Use Research, University of Victoria, 2300 McKenzie Ave., Room 273, Victoria, BC, Canada V8P 5C2.
Elizabeth K Farkouh, Canadian Institute for Substance Use Research, University of Victoria, 2300 McKenzie Ave., Room 273, Victoria, BC, Canada V8P 5C2; Brigham and Womens Hospital, 75 Francis St., Boston, MA 02115, United States.
Norman Giesbrecht, Institute for Mental Health Policy Research, Centre for Addiction and Mental Health, 1001 Queens St. West, Toronto, ON, Canada M6J 1H4; Dalla Lana School of Public Health, University of Toronto, 155 College St., Toronto, ON, Canada M5T 3M7.
Ashley Wettlaufer, Institute for Mental Health Policy Research, Centre for Addiction and Mental Health, 1001 Queens St. West, Toronto, ON, Canada M6J 1H4; Dalla Lana School of Public Health, University of Toronto, 155 College St., Toronto, ON, Canada M5T 3M7.
Timothy S Naimi, Canadian Institute for Substance Use Research, University of Victoria, 2300 McKenzie Ave., Room 273, Victoria, BC, Canada V8P 5C2.
Author Contributions
All authors contributed to the study conception and design. Material preparation, data collection, and analysis were performed by A.G. The first draft of the manuscript was written by A.G., and all authors commented/edited previous versions of the manuscript. T.N. obtained funding for the project and supervised the scientific and administrative aspects of the paper. All authors read and approved the final manuscript.
Supplementary data
Supplementary data is available at Health Promotion International online.
Conflict of interest
None declared.
Funding
This work was supported by a Fulbright-MITACS Globalink research scholarship awarded to Aaron Grinberg. The views and opinions expressed in this manuscript are those of the research team and do not necessarily represent that of our funder.
Data availability
The data underlying this article will be shared on reasonable request to the corresponding author. However, these data came from publicly available data which can be accessed at https://lobbycanada.gc.ca/app/secure/ocl/lrs/do/guest.
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Associated Data
This section collects any data citations, data availability statements, or supplementary materials included in this article.
Supplementary Materials
Data Availability Statement
The data underlying this article will be shared on reasonable request to the corresponding author. However, these data came from publicly available data which can be accessed at https://lobbycanada.gc.ca/app/secure/ocl/lrs/do/guest.
