EuroHealthNet welcomes the opportunity to contribute to the WHO Secretariat’s call for feedback on the second draft of the WHO discussion paper containing a proposed update to Annex 3 of the WHO Global NCD Action Plan 2013-2030.
According to WHO, the updated Appendix 3 will include the best buys and other recommended interventions to reduce risk factors for NCDs (tobacco use, harmful use of alcohol, unhealthy diets, physical inactivity) and enable health systems to respond to the health care needs of people living with or at risk of the major NCDs (cardiovascular diseases, cancers, diabetes, chronic respiratory disease), taking into account the following:
- mental health
- air pollution
- oral health
We recognise the importance of comprehensive, timely and accelerated, as appropriate, actions addressing unhealthy and unsustainable lifestyles and environments, in particular in the context of the prevention and control of NCDs and their underlying risk factors.
In particular, EuroHealthNet welcomes the second draft adding a cost-effectiveness analysis to the intervention on unhealthy food marketing restrictions for children, and on sugar-sweetened beverage taxation (EuroHealthNet, 2022c). We welcome that the draft recognises the fact that the absence of a cost-effectiveness analysis does not undermine interventions’ cost-effectiveness, neither their affordability and feasibility, pressing for periodic revision as data becomes available.
While welcoming the strengths of the document, and bringing in its input towards other either EU or global NCD-related consultations and processes, EuroHealthNet further proposes to consider better linking the NCDs “Best Buys” to global, regional and national resilience and recovery agenda, the role of public legislation and regulation in this regard, as well as considering to broaden this approach to include cost-effective interventions in the field of mental health as one of key NCDs.
Last but not least, EuroHealthNet urges the document to consider listing cost-effective interventions linked to environmental and climate change-related NCDs, in particular if evidence shows strong relationships with other NCDs risk factors (mental health, CVDs, cancers) and patterns of inequalities. Global, regional and national efforts towards green and sustainable transitions should be maximised to this effect.