The Industry Complex (Part 4): Finding the Pieces to the Policy Puzzle

German and French translations

I feel like Brussels is a puzzle where the pieces keep changing. The best way to start a puzzle is by lining up the edge pieces, but there are none. The size of the challenge is unknown. I like puzzles and I like trying to solve problems, but the first point is: “Where to start?”. What can industry do to solve the problems facing their “Complex”?

It is patently clear industry actors in Brussels cannot continue to do what they have been doing. Brussels has far too many activists with special interests solely dedicated to seeing industry and capitalism fail. They have money, passion and limited ethical constraints as they execute their objectives with missionary zeal. This series on the Industry Complex has tried to show how anti-industry militants have worked to destroy trust in all industries (excluding them from the policy process and equating the word “industry” with some immoral interpretation of lobbying) and using the same tactics that worked with the decline of the tobacco industry. Using the emerging communications tools to create an atmosphere of fear and hate, these activists have successfully generated a narrative that the only solution to our problems is to remove industry, their innovations and their technologies. And their solutions are getting even more extreme (with, for example, 6000 environmental militants recently attacking an irrigation pond project on a farm in France for being too “industrial”). Policymakers, perceiving these loud voices as representative, have adopted the path of virtue politics rather than Realpolitik (of policy by aspiration and ideology rather than practical solutions relying on the best available evidence).

So what can industry do?

I have argued in this series that being the second slowest zebra with short-term objectives is no solution. I also feel that continuing to bow and tolerate the hateful campaigns is a sign of weakness. Playing for limited losses (eg, keeping your substance on the market for three more years before letting your lawyers do the derogation dance) is not a winning strategy. Industry trade associations in Brussels used to be about product stewardship and proactive benefits communications campaigns; now they seem to be solely concentrating on reactive product protection in the face of relentless regulatory threats, preventing further erosion of trust and minimising their loss of membership. They don’t even have time to see how the policy landscape has changed with anti-innovation tools like the precautionary principle and the hazard-based approach making their involvement in policy debates merely symbolic.

What is needed now for industry to return to a winning strategy in the policy arena?

A) Leadership

Where are the leaders in industry? Corporate CEOs only make the trip to Brussels when the European Commission or Parliament call them in for a good talking to, punitive fines or inquisitional demands to do more for less. Even during the COVID-19 pandemic, where companies were developing innovative solutions that saved millions of lives (from the pharmaceutical industries, to chemicals, plastics, food and textile manufacturers to technology companies providing solutions for business, entertainment and retail), industry was unable to use their leadership role to improve their relationship with policymakers. The attacks on AstraZeneca was the low point. Any industry good will was not rewarded in the policy arena (where government COVID risk management had proven to be pathetic).

Western leaders have been more eager to sit next to an insult-prone Swedish teenager than the head of a large research company providing innovative solutions and investment. Why is that? It is not that the industry leader was seen to be money-driven, power hungry and beholden to the capitalist system – everyone has interests. People were inspired by this teenager’s courage to stand up and speak out.

There are many more people outside of the loud activist minority who don’t accept the narrative that capitalism has destroyed humanity and the planet. There are many more people who appreciate how technologies have made our lives better, how we are living longer and healthier lives, how wealth has expanded and poverty and underdevelopment have declined. But who has the courage to stand up and speak for these people.

I don’t see charismatic industry leaders like that in Brussels.

B) Inspiration

What is your vision for the future?

I used to confuse students when I got them to agree that they would never date someone who didn’t have a vision. (The confusing part came when I then asked them what their vision was.) So what is your industry’s vision? How are you going to make an impact in the next ten years? And how are you communicating that to stakeholders who have an interest in you? Is it resonating?

Companies with clear visions have no problem recruiting the best and the brightest. A clear vision inspires, creates followers, makes you or your organisation attractive. Brands have visions for which consumers line up and willingly pay more. With only a few exceptions, I have rarely been attracted to visions put forward by industries. Time was industry groups rallied around voluntary commitments to express their long-term visions. When I was active in the field, the Vinyl 2000 strategy effectively kept PVC on the market despite feral activist outrage. That was almost three decades ago.

The case study I have often referred to as an exception to the norm, where a vision-oriented industry resisted a coordinated precautionary onslaught, would be the mobile phone industry. In the early 2000s, there was a lot of fear about cancer from EMF exposures from mobile phones and masts (and not enough research data). Granted the first generation mobile phones could pop popcorn kernels so I suspect the industry was guilty as charged and even the UK’s Stewart Report, in 2000, had a hard time justifying the continued use of the emerging mobile technology (especially by teenagers). But the mobile phone industry did not spend their time playing the regulatory denial game. They took the challenge to innovate, create wider benefits for consumers and clearly present their vision of a connected world centred around mobile devices. Any health or environment threats were met with targets to reduce exposures. Nobody dared to hammer the precautionary spikes into this technology since their clearly articulated vision inspired a generation. Then again, if the mobile industry had been up against today’s rigid use of the precautionary principle, we would all still be using landlines.

An attractive vision engages audiences and leads to greater trust. Precaution comes about when there is a trust deficiency (ie, no attractive vision to inspire populations). Spending your time in Brussels denying that your product is a carcinogen, an ecological threat, a source of waste, an endocrine disruptor… is time wasted from putting your product forward as a solution, innovative and future-driven. If you are fighting over getting your historic data accepted then you are not getting your future exposure reduction goals integrated. You are not inspiring and thus you are not attractive to those controlling the narrative. Just go home.

Meanwhile the NGOs that are making you spin your wheels in the mud don’t sell any products or invest in any infrastructure. They spend all of their abundant resources creating and propagating their visions, inspiring vulnerable people to think otherwise, stand up and take action to save the world (ie, to get rid of you). It is much easier for decision-makers to sit next to that Swedish teenager and nod during her incessant rants.

If your vision is merely fighting for three more good years on the market, not only are you not attractive in the policy arena (and easily prone to suffer abuse), but I don’t expect your downstream value chain to be too excited by what you have to offer.

C) Courage

There are a lot of bullies in Brussels – zealots who have honed their skills at beating up industry and destroying trust in them and their technologies. But bullies can only bully if people let them. The righteous zealot will personally insult you and do everything to hurt you professionally. … OK … and then what will they do? Activists who try to isolate and intimidate opposing views will only succeed if we let them – if we run away when they shout.

OK, fine … Mr Monger, you yourself can stand up to them because you don’t have anything valuable they can destroy. I have my company or my organisation to protect.

Indeed, this is perhaps the main reason to explain why industry actors have decided to curl up into a ball and do nothing as activists rip into the public trust of their industries, their products and their markets. Also, most companies and trade associations are guided by ethical codes of conduct (unlike most NGOs) that would restrict them from behaving negatively toward others. So as long as NGO campaigns are more savage on another industry or company, doing nothing seems like a rational approach. I referred to this as being the second slowest zebra in the herd. As the carcass next to you is being torn apart in an activist feeding frenzy, at what point will your industry get the courage to stand up and demand that something should be done?

(Editor’s note: The Risk-Monger did lose a teaching position due to his involvement in the glyphosate campaign, but academic administrators have shown even less courage than industry lately.)

The herd has to plan for tomorrow, today. Maybe they need a deterrent, other allies or a change of landscape. They need first of all to get out of their protective curled-up ball and have the courage to stand up and speak out… together.

D) Single Voice

Mostly carbon emission traders and wind and solar executives. Nobody read their list. With 1000s of NGO climate activists at COP27, why should this become the main issue?

Industry needs to stick together and resist the relentless activist campaigns against them. Most recently, the fossil fuel industry was attacked for being involved in the COP27 Summit (by a bizarre group of NGOs funded by the German government … whose head of delegation to COP27, Jennifer Morgan, was the International Executive Director of Greenpeace). Nobody stood up to defend the need for all stakeholders to be engaged in finding solutions. In a democratic process, all interests need to be heard at the table, not just those deemed by some smarmy self-appointed collective of activist groups to be morally fragrant.

So who will be next? Will we be OK if the WHO excludes Big Pharma from their conferences (IARC did not invite a single person from the pharmaceutical industry to their 50th anniversary conference)? When all industry is treated like tobacco industry piñatas, don’t be surprised if you get a little bruised. When activists are openly using their tobacconising strategy on all industry groups, maybe you should regret not having stood up earlier to protest unfair consultation restrictions.

The NGO community has learnt to stand together and speak with a single voice. Even if some of the groups (like Corporate Europe Observatory, Extinction Rebellion or SumOfUs) break the rules or behave despicably, NGOs will never break ranks or speak off script. Industry needs to speak out with one loud voice against the bullying, against the exclusionary tactics and against the nonsense.

The problem is that industry lobbyists have been trained to respect anti-trust restrictions (I used to read the “morning prayer” at Cefic meetings) but this is not about competition regulations. This is about having a voice and being heard in the policy process. Post-pandemic, the Risk-Monger has been speaking at many different industry association meetings and the mood is almost always dark. These different groups are all facing the same issues implemented by the same small band of clever activists using the same tobacconising techniques. Each industry group is struggling on their own, but as some of the zebras are slower than the others, there are varying degrees of urgency.

The lions, though, are insatiable.

The herd needs to be kept tight and protect all members. Why is it that EU officials are not allowed to interact with industry leaders (outside of trade associations) but NGO lobbyists are free to meet and greet whomever they want? How is this a fair lobbying standard? Stand up and be heard.

Stand up and Leave the Room

Perhaps the most courageous thing industry could do is recognise the impossible situation in the policy process and stand up and leave the room. While this is exactly what the activists have been campaigning for, European policy, since the White Paper on Governance, has sought open consultation and stakeholder dialogue as the key to policy legitimacy. When the NGOs got up and left the dialogue process in the mid-2000s, the European Commission begged them back with promises of funding mechanisms and a wider use of policy tools like precaution and the hazard-based approach.

I believe industry will continue to lose, and lose badly, unless they can rectify the unfair European policy landscape. If all companies and trade associations in a particular issue were to boycott the consultation process until the European Commission levels the playing field, you would see a flurry of corrective actions. I still cannot believe that the precautionary principle is routinely being applied (within a hazard-based policy approach) without any clear guidance of how it should fit within the risk management process. Does this European Commission even have a risk management process? Or is it simply a series of risk aversion solutions?

If all industries circled the wagons and demanded a White Paper on Risk Management before they continue to engage, suddenly the policy landscape would change. Of course trade associations were created to be their industry’s voice in Brussels so they may be reluctant to leave the room they have been paid to be in (unless their members have the courage to speak up, stand up and leave on their behalf). Give these associations six months to concentrate on developing vision statements and voluntary commitments. Otherwise, you are merely charging your trade association with the task of managing your gradual decline and slow death.

Realism over Idealism

I set the seeds for a solution in this series with the call for a return to Realpolitik in the policy arena. Virtue politics can only succeed at a time of prosperity with an affluent audience demanding perfection (zero risk and unlimited resources to pay for the consequences). Policymakers can only play the virtuous leader if they have the means to give people what they want (and find others to pay for it). Brussels is in a sorry state now where long-term policy aspirations have been confused with the regulatory process. They have confused policy ideals and long-term goals with the reality on the ground.

Looking at the Green Deal strategy that the European Commission’s leading ideologues put forward to stake their claim as virtue politicians, there is no rational justification to implement most of their aspirational objectives (especially not by 2030). But this is the strategy that careerists like Frans Timmermans and Ursula von der Leyen have staked their legacy on. They relentlessly pushed this strategy through a pandemic (even raising more funds for it) and will continue to feed their idealism through a major recession brought about by food and energy inflation, in a large part due to their own making.

Why?  Because nobody is standing up to them or shaking them out of their aspirational slumber.

I looked on in disbelief as industry groups, one after another, all raised their glasses on the day of the announcement of the great European Green Deal, committing to work together with Frans and Ursula to save the world. Behind the scenes there was panic that this would completely destroy European industry, but no one was speaking up. The research community looked on as the best technologies were arbitrarily put on a banned list (they were not natural or they emitted CO2), curious about the funding to find solutions once the substance and product phase-outs took place. The Risk-Monger felt lonely running around ridiculing the sheer stupidity of the Green Deal targets and ideals, spinning expressions like Farm2Famine or Farm2Fucked, but I might as well have been chasing my own tail – no industry leaders have had the courage to tell these leaders that their dreams are facing a harsh reality (except scientists in the JRC but European Commissioners are very good at ignoring them). The Commission even suggested agroecology as the means to avoid global famine … no one blinked.

Strong leaders should wake up when reality conflicts with their idealism and seek pragmatic solutions. Industry leaders need to wake up their political counterparts, let them know what is possible and what could be expected, and then work together to find the best policy solutions (this is called risk management). Realpolitik arises when not everyone can get what they want but where the greatest good can be achieved. The European Green Deal will offer the least good at the greatest price. But as long as industry continues to blithely congratulate policymakers when what they need is a good kick in the butt for their sheer folly and stupidity, then don’t be surprised if aspirational goals soon become regulatory requirements (that you won’t be able to meet).

Whatever happened to impact assessments?

Science over Faith

Scientific evidence has taken a back seat in the Brussels policy arena since a band of NGOs demanded the removal of the post of Chief Scientific Adviser to the President of the European Commission (Anne Glover made the fatal mistake of defending the scientific data on the safety of GMOs). So where is the European Union getting their scientific evidence and who is helping these generalists to interpret it?

Every decision that we make is assumed to be based on sound reasoning on the best available data presented to us. In the case of decisions that affect others (eg, policy decisions), it is imperative that we have access to the highest quality research. Of course there are other factors that influence how we value and interpret this evidence (eg, politics, our belief systems and the questions we ask … shaped by our social and cultural narratives).

When a company invests millions on a technology, they have to ensure that the science is accurate. They have employed a vast array of scientists and have developed research centres that rival the greatest academic institutes to get the best return on their investments. They take the best scientists out of the best schools (often before their PhDs are defended) and put them on innovative projects that sometimes are decades in development. Some of the new battery technologies coming on the market now, for example, were being tested in the 1990s (when I worked in a corporate research centre). In some fields of specialised research, like food additive science, there is a shortage of expertise so anyone trained in this domain will have had industry experience.

The activists who dream of a better world use Google to find the data they think they can use to justify their campaigns. Science, by its nature, is always being challenged and the Internet provides free access to any disagreements from anyone. They simply need to provide enough contrarian views, from any source, to create an image of uncertainty on “the science”. (The irony is that this is the same tactic they accuse the tobacco and petroleum industries of doing – see Doubt is their Product). NGOs also demand that only research published in peer reviewed journals should be accepted for risk assessments (knowing that internal industry research data is often proprietary and confidential).

Recognising their weakness on the evidence front, NGO activists then try to discredit industry science and work to ensure that no researcher or expert with any industry background be allowed to advise or participate in EU policy discussions. In the case of glyphosate, for example, NGOs have been working to have policymakers ignore any conclusions provided by EFSA or ECHA (or any other national regulatory science agency) because they included industry-funded research or used industry data in their risk assessments. Meanwhile activist researchers raising these doubts on glyphosate are funded by organic food industry foundations or US tort law firms that will profit from the thousands of ongoing litigations. And no one is speaking up.


This introduces the last piece of the puzzle to the Industry Complex. How to get high quality research to be considered regardless of the source; how to give policymakers a proper capacity to interpret the best evidence; how to return evidence to a central role in the policy process; and how to put activist science into context. That will be the challenge for Part 5 of this series.

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