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Health inequalities researchers have long advocated for governments to adopt policy instruments that address structural determinants of health rather than targeting individual behaviours. The assumption behind this position is that such instruments might challenge a core neoliberal principle of individualism embedded in the prevailing health policy paradigm. We critique this assumption by highlighting the discursive construction of policy instruments, and their discursive effects. Using the UK's Tackling Obesity policy as a case study, we demonstrate how instruments designed to target structural determinants of health (such as food advertisement regulation) can actively sustain – rather than challenge, the dominant policy paradigm. We call this phenomenon 'upstream individualism', exploring how it relates to tensions in the research-policy relationship, and its relevance beyond health policy. We argue that instruments can shape policy change and continuity, including at a paradigm level, and that 'upstream individualism' provides a useful basis for theorising these power dynamics. This article contributes to the constructivist public policy literature by noting how policy instruments meant to challenge the discursive construction of individualism within public health can ultimately reinforce it.

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.