Researchers apply the tobacco playbook framework to the wellness industry
A Milbank Quarterly analysis argues wellness companies use the political strategies of harmful commodities industries. A separate review puts the downstream cost of low-value wellness testing above $100 billion a year.
The analytical framework known as the commercial determinants of health was built to study tobacco, alcohol, and ultra-processed food — industries whose products damage health and whose political activity is directed at preventing regulation of that damage. A paper published in The Milbank Quarterly on 4 May applies the same framework to wellness, and reports that the strategies look familiar [s1].
What the analysis did
The authors drew on commercial determinants of health and corporate political activity frameworks to analyse the strategies, structures and discourses of the wellness industry, examining academic literature, regulatory documents, industry data, and media and policy sources [s1]. The stated purpose was to map the industry's characteristics, regulatory environment and political dimensions, including its role in shaping US public health policy through the Make America Healthy Again movement [s1].
The scale claim is the paper's opening premise: wellness has grown into a multi-trillion-dollar industry encompassing a large number of products and practices that affect health and well-being [s1].
The finding
The paper reports that the wellness industry deploys political strategies closely resembling those of other harmful commodities industries, specifically naming three: undermining scientists and policymakers, promoting personal empowerment, and lobbying against regulation [s1].
The second of those is the one that distinguishes wellness from tobacco. "Promoting personal empowerment" is not a defensive manoeuvre; it is the product. The framing that health is the outcome of individual choices, correctly made, is simultaneously the industry's marketing message and its argument against being regulated. If health is a matter of personal responsibility, then selling people tools for exercising that responsibility is a service, and regulating those tools is paternalism.
The paper situates this against the conditions that created demand. Wellness products and practices are often framed as a response to the erosion of institutional trust and to health care systems' failure to address persistent health inequities — but the authors argue their promotion may deepen rather than alleviate those problems [s1].
The policy dimension
The analysis treats the Make America Healthy Again movement as a case study in how wellness logics become embedded in policymaking, platforming individualised wellness while falling short of addressing the systemic drivers of ill health and inequity [s1]. The authors also identify the global digital revolution as having fuelled both the growth of the industry and the spread of health misinformation, posing regulatory, social and political challenges [s1].
Their recommendations are three: stronger regulatory oversight of health claims, demonetisation of harmful online health misinformation, and structural investment in equitable health care systems [s1]. They describe further research as merited to document industry practices across national contexts and to investigate links between wellness discourse, health inequalities and political polarisation [s1].
Putting a number on the downstream cost
The Milbank paper is a structural analysis and does not quantify harm. A narrative review published in the Journal of General Internal Medicine on 5 January 2026 does, for one slice of the market: wellness testing [s2].
That review describes a marketplace of direct-to-consumer genomics, broad laboratory panels, wearable sensors and whole-body imaging that outpaces the evidence supporting it, and reports that in the United States such low-value diagnostics account for over $100 billion in annual downstream costs [s2]. The mechanism it names is not the price of the test. It is what follows one: exposure to false-positive cascades, anxiety, and bias [s2].
The review proposes a three-tier precision health framework, using AI-based population assessment with high-value testing selected on pre-test probability — Tier 1 high-sensitivity screens, Tier 2 targeted confirmation, Tier 3 precision interventions — and argues that adopting it could markedly reduce unnecessary medical exams and redirect resources toward proven preventive measures [s2].
What these two papers are
Both are argument rather than measurement, and should be read as such. The Milbank paper is a qualitative synthesis applying an existing analytical framework to a new industry; it does not report an experiment or a quantitative test of its claims [s1]. The JGIM paper is a narrative review, not a systematic one, and its $100 billion figure is a synthesis of existing cost literature rather than a new estimate produced by the authors [s2].
What they share is a specific diagnosis: that the wellness market is structured so that the absence of evidence is not a commercial problem. A supplement, a test panel or a scan does not have to demonstrate benefit to be sold, and the costs of the resulting cascade fall somewhere other than on the seller.
What to watch
The Milbank authors' first recommendation — stronger regulatory oversight of health claims — is the one with a visible policy surface. Watch whether claim-substantiation requirements for wellness products and consumer tests change, whether platform demonetisation policies for health misinformation are extended or rolled back, and whether any payer or health system publishes its own accounting of downstream costs generated by patient-initiated wellness testing.
Sources
- [s1] The Political Economy of Wellness: Commercial Determinants of a Burgeoning Industry. The Milbank Quarterly, published online 4 May 2026. https://doi.org/10.1111/1468-0009.70088
- [s2] Critically Appraising the Wellness Movement: Cost Without Value, A Narrative Review. Journal of General Internal Medicine, published online 5 January 2026. https://doi.org/10.1007/s11606-025-10099-3
Sources
- The Political Economy of Wellness: Commercial Determinants of a Burgeoning Industry — The Milbank Quarterly , May 4, 2026
- Critically Appraising the Wellness Movement: Cost Without Value, A Narrative Review — Journal of General Internal Medicine , January 5, 2026
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