BACKGROUND In 2020, the Secretariat of the World Health Organization (WHO) conducted an open consultation, with public submissions, for the purpose of developing an Alcohol Action Plan to "strengthen implementation" of the WHO's 2010 Global Strategy to Reduce the Harmful Use of Alcohol. The consultation process and public submissions provided an opportunity to critically examine alcohol industry perspectives and arguments in relation to the global governance of alcohol.

METHODS 48 alcohol industry submissions to the WHO's 2020 consultation were included for analysis. Directed content analysis was used to examine the policy positions and arguments made by industry actors. Thematic analysis was employed to further explore the framing of industry arguments.

RESULTS In framing their arguments, alcohol industry actors positioned themselves as important stakeholders in policy debates; differentiated "normal" drinking from consumption that merits intervention; argued that alcohol policy should be made at the national, rather than global, level; and supported industry self-regulation or co-regulation rather than cost-effective public health measures to prevent harms from alcohol.

CONCLUSION The alcohol industry's submissions to the WHO's 2020 consultation could be seen as efforts to stymie improvements in the global governance of alcohol, and repeats several framing strategies that the industry has used in other forums, both national and global. However, their arguments appear to have had little traction in the creation of the Alcohol Action Plan. Changes from the Working Document to the adopted Action Plan show little acceptance by WHO of industry arguments.