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Abstract
The intensification of efforts by state and nonstate actors to address issues affecting global health has produced a patchwork of transnational regulatory governance. Within this field, nongovernmental organizations (NGOs) are expected to perform authoritative roles in holding business actors to account and enhance the democratic legitimacy of institutions via their participation in governance processes. While there exists a large body of conceptual and empirical research on global business regulation and private authority, we surprisingly know little about the governance functions of NGOs engaged in influencing the practices of corporations that produce health-harming commodities. This knowledge gap is especially pronounced in the issue area of noncommunicable diseases. This article begins to address this gap by mapping the networks of NGOs that engage in regulatory activities (rule-setting, monitoring, and enforcement) related to the (ultra)processed food and alcohol industries. We identify the networks of NGOs involved in global policy making across health, regulatory standards, and multistakeholder initiatives using nonstate actor submissions to consultations held by World Health Organization, UN Codex Alimentarius Commission (Codex), and the UN Global Compact. This paper examines NGO governance functions and their patterns of engagement and participation across institutional spheres. Overall, the article makes a twofold contribution to existing debates. First, we identify the governance functions through which NGOs attempt to hold corporations to account, contrasting their "watchdog" function with other governance functions. Second, we examine the representation of NGOs, highlighting asymmetries in participation of NGOs in the Global North and South.