Fruit and Vegetables Aid Scheme in Scotland: consultation analysis

2. Response Analysis (A): Proposals for immediate changes to legislation

The following section presents an analysis of responses received to questions on Section A:

Q1. Do you agree that aid provided by the Scottish Government should be based on production grown only in Scotland?

Support for aid being based on production grown only in Scotland was high, with 83% of respondents (15 out of 18) agreeing that this should be the case.

6% of the respondents (1 out of 18) did not agree.

11% (2 out of 18) did not answer the question.

Q2. Do you have a preference on approach, either (a) funding producer organisations with only Scottish growers, or (b) still allowing producer organisations with members based in other parts of the UK to be funded, but not including their value in the calculation determining aid that would be provided.

The most preferred response was option (b), allowing members based in other parts of the UK to be part of Scottish producer organisation, but not including their value in the calculation determining the level of finance that would be provided.

44% of respondents (8 out of 18) stated that they preferred option (b).

22% of respondents (4 out of 18) stated that they preferred option (a).

The remaining respondents did not state a preference.

Key themes identified were as follows:

UK Cooperation

• Respondents supporting option (b) emphasised the strategic value of UK-wide collaboration.
• They noted that supply chains and production areas do not follow national boundaries, and that cross-border cooperation strengthens market access, especially with supermarkets.
• Some highlighted that excluding non-Scottish members entirely could undermine existing cooperative structures and shared infrastructure.

Good Food Nation

• Several responses linked option (b) to the Good Food Nation (Scotland) Act 2022, arguing that POs play a key role in delivering its objectives.
• POs help facilitate supply chains for public procurement, retail, and food service, aligning with the Act’s goals of improving access to healthy, local food.
• The scheme was seen as a tool to support Scotland’s broader food strategy, even if some members are based outside Scotland.
• Some responses linked to option (a) also referred the Good Food Nation. They stressed that supporting Scottish-based producers directly contributes to national food security and sustainability.

Food System

• Respondents supporting option (b) described POs as integral to a resilient and sustainable food system.
• They contribute to employment, processing, packing, and distribution, especially in rural areas.
• The responses stressed that excluding cross-border members could fragment supply chains, reducing efficiency and competitiveness.

Sustainable Production

• The Fruit and Vegetables Aid Scheme was praised for encouraging balanced investment in sustainable production.
• Respondents noted that option (b) allows continued support for environmentally responsible practices, while still ensuring Scottish-grown produce is prioritised.
• There was a call for pragmatism by supporting Scottish growers without undermining operational benefits of operating across wider geographical areas.

Eligibility

• While option (b) was preferred, some respondents acknowledged that current eligibility rules exclude smaller producers and called for a broader definition of a producer organisation.
• There was support for ring-fencing funding for Scottish growers, but also a desire to avoid unintentionally excluding collaborative or lower-turnover producers.
• Some responses called for revisiting eligibility criteria to include market gardens and community supported agriculture.
• Responses emphasised that financial metrics alone do not reflect the public goods these producers deliver, such as biodiversity and community wellbeing.

Scottish Interests

• There was an emphasis from respondents supporting option (a) on ensuring Scottish Government funds benefit Scottish producers exclusively.
• Several responses framed this as a strategic opportunity to build a uniquely Scottish agricultural support model, aligned with Scotland’s climate, land, and policy goals.

Rest of UK

• There were concerns from respondents supporting option (a) that continuing to fund cross-border or mixed POs risks subsidising producers in other UK nations.
• Some respondents argued that Scotland should not continue supporting producers in jurisdictions with different political and economic priorities.
• A few acknowledged transitional arrangements might be necessary but called for strict safeguards.

Other observations

• Independent Growers: one respondent queried support for independent growers supplying directly to consumers.
• No Change: another grower highlighted their preference to retain the current system.
• Specific subsidies: another grower stressed that specific subsidies are needed, making comparison with Less Favoured Area Support.

Q3. What, if any, are the benefits to your producer organisation of having members based in other parts of the UK?

Key themes identified were as follows:

Commercial Benefits

• Access to more land and growers: Cross-border membership provides access to high-quality arable land and professional growers near processing facilities, improving cost efficiency and operational success.
• Proximity to processing sites: For example, Scottish Borders Produce benefits from English land within 90 minutes of Eyemouth processing site, ensuring timely harvest and freezing.
• Maintaining viable scale: Combining land from Scotland and England helps achieve commercial scale and crop rotation, reducing disease risk.
• Improved bargaining power: Larger, UK-wide groups negotiate better with supermarkets and gain improved market access.
• Integrated supply chains: Supermarkets prefer geographically spread supply to reduce risk, making cross-border membership advantageous.

Collaboration

• Some respondents are not part of a PO or not eligible under current schemes but see potential benefits in collaboration.

Investment

• Attracting capital: Larger scale encourages investment in sustainability, R&D, and advanced technologies.
• Knowledge exchange: Broader membership supports technical advice and early adoption of innovations.

Resilience

• Extended production curve: Access to different soil types and climates allows staggered planting/harvesting, smoothing peak demand and extending the season.
• Reduced reliance on imports: Southern UK growers enable supply outside the Scottish season, replacing imports (e.g., Dutch broccoli).
• Climate resilience: Good for exploiting different climatic opportunities.

The following disadvantages/observations were also highlighted:

• Risks: Some respondents argue cross-border membership risks legal complications, diverts funds from Scotland, and undermines devolved policy goals. They advocate for Scotland-only POs aligned with independence and local priorities.
• Eligibility issues: Current scheme criteria exclude some groups of growers and independent producers. Respondents call for a new scheme reflecting market changes and supporting different models.

Q4. Do you agree that Scottish Ministers should have discretion over the total budget for Fruit and Vegetables Aid Scheme in Scotland?

The majority of respondents agreed that Ministers should have discretion over the Fruit and Vegetables Aid Scheme budget.

72% of respondents (13 out of 18) agreed.

17% of respondents (3 out of 18) disagreed.

The remaining 11% (2 out of 18 respondents) did not answer the question.

Q5. Do you support the potential approach of the funding cap being set at a percentage, determined by Scottish Ministers, of a Producer Organisations Value of Marketed Production (VMP)?

The majority of respondents supported setting a funding cap as a percentage of Value of Marketed Production (VMP), for the following reasons:

• Budgetary Control: Allowing Scottish Ministers discretion ensures strategic allocation and responsiveness to national priorities.
• Proportionality: This approach supports a balanced and proportionate funding model.
• Certainty: This funding model has been effective and gives a degree of certainty. One respondent stressed that maintaining the 4.1% rate would provide stability for long-term planning and investment.
• Resilience: Discretion could help support Scotland’s food economy.

Some alternative views were also proposed:

• Tiered funding: Several respondents suggested that a flat percentage risks disadvantaging smaller growers and suggested a higher percentage for smaller/remote producers or a minimum grant level to ensure fairness.
• Call for New Scheme: Some respondents said the existing model is outdated and irrelevant. They advocated for a new scheme and broader support, particularly for small growers (e.g. market gardens).

Q6. Is it important that Producer Organisations are made aware of what the funding cap would be set at in advance of submitting an operational programme?

The majority of responses consider it very important that Producer Organisations are made aware of the funding cap before submitting an operational programme. The main reasons given included: planning certainty, sustainable investment and avoiding wasting effort.

Most responses recommended a minimum of six months before submitting new applications.

Q7. Do you have other suggestions that would enable a fair and sustainable way for the Fruit and Vegetables Aid Scheme to be funded in Scotland?

Key themes identified are as follows:

Support for the current model

• Responses included a strong emphasis on maintaining the current funding model in terms of retaining funding based on value of marketed production (VMP) and keeping the scheme focused on producer organisations or cooperatives rather than individual growers.
• It was highlighted that a benefit of having funding based on a percentage of value of marketed production is that it rewards expansion and increases productivity.
• It was stressed that a shift towards supporting individuals rather than producer organisations risks diluting collective benefits and efficiencies achieved through cooperative models ultimately to the detriment of primary producers.
• The importance and effectiveness of the existing scheme, in terms of budget efficiency, farm productivity, sustainable land management, health, food security and rural economies, was noted.

Support smaller growers and market gardens

• Some respondents indicated there should be support for smaller growers who do not meet the criteria to access funding through the Fruit and Vegetables Aid Scheme.
• It was noted that small growers contribute to local food security and resilience, healthy diets and biodiversity but do not have the security of government support.
• It was suggested that a dedicated support scheme for market gardens be developed.

It should be noted that changes in criteria, to be recognised as a producer organisation, in order to access funding via the Fruit and Vegetables Aid Scheme, are not being considered at this time. This is because on the UK’s exit from the EU, the legislative powers in assimilated regulations relating to recognition were transferred to the Secretary of State. Any changes would need to be developed with due regard to the legal framework.

Funding

• A high number of respondents stressed that budget support for fruit and vegetable producers should be increased or enhanced. Suggestions included:
  • Allocate more of the rural development budget to market-focused measures that strengthen supply chains and production efficiency.
  • Well-funded accessible measures in the Agriculture Reform Programme.
  • The importance of the scheme should be reflected through increased funding.
  • Introduce enhancement payments for environmental spending.
  • A tired funding system
  • A minimum grant
• One response said that basing funding on a fixed percentage of value of marketed production is preferable.
• Some responses noted that the current annual spend is inadequate compared to other sectors.

Other observations/suggestions

• One response suggested that schools should be funded directly on the condition they source produce from local growers to reduce processed food consumption and tackle obesity.
• Another response suggested that the scheme should move away from production-based funding and reward behaviours and investments such as creating jobs, or reducing food miles.
• There was also a suggestion to introduce a ‘Scottish Food Security Dividend’ for organisations supporting local economy and net-zero goals.
• One response argued Scottish Producer Organisations (POs) must be empowered to operate on a level playing field with their European counterparts.
• Some respondents see the scheme as unfair and outdated.

Q8. Are there other factors that Scottish Ministers should take into consideration when determining how discretion should be applied?

The main themes identified include:

Operation of existing scheme

• There was support for keeping the current scheme model as it has worked well, enabled investment in the sector and delivered a wide range of sustainability outcomes.

Funding

• There was strong support for keeping the funding level at 4.1% of the value of marketed production (VMP).
• There was also a call to increase funding for the fruit and vegetables sector to 4% of the total farm support budget.
• Responses included calls for a level playing field with the EU, in terms of the aid scheme and also other factors, such as cheap labour.
• One response suggested that supporting growers supplying to multiples push prices down, negating any funding support.
• There was a call for Scottish Ministers to support smaller and Community Supported Agriculture (CSA) farms and cooperatives.

Alignment with other policy goals

• A number of respondents considered that funding decisions should reflect Scotland’s broader goals, including:
  • Environmental benefits
  • Social outcomes, including employment
  • Good Food Nation
  • Local Food Strategy
  • Agriculture and Rural Communities Act
  • Just Transition Plan
  • Health
• Some respondents highlighted the important role the Fruit and Vegetables Aid Scheme has already had in these areas.
• There was a suggestion that criteria to access funding should go beyond turnover and align with wider food and farming objectives.

It should be noted that changes in criteria, to be recognised as a producer organisation, in order to access funding via the Fruit and Vegetables Aid Scheme, are not being considered at this time. This is because on the UK’s exit from the EU, the legislative powers in assimilated regulations relating to recognition were transferred to the Secretary of State. Any changes would need to be developed with due regard to the legal framework.

Other comments

• One respondent indicated that changes to the scheme should protect or positively enhance the existing scheme to provide certainty to the sector and enable it to be competitive.
• Another respondent said that the scheme should have long term objectives and rates, and that short term changes to the scheme will undermine confidence in Scottish growers.

Q9. Would restricting applications for new operational programmes to every three years have an impact on your business?

44% of respondents (8 out of 18) indicated that restricting application to every three years would have an impact on their businesses. However the majority of these responses are from respondents who do not currently receive funding from the scheme.

22% (4 out of 18) of respondents said it would have no impact.

The remaining respondents either didn’t answer the question or didn’t specify a view.

Responses indicating an impact (Yes)

• Several respondents stressed the need for exceptions or shorter-term options for smaller producers or emerging groups.
• Some respondents suggested the proposal would be counterproductive to other policy goals such as food security, land reform, and regenerative farming.
• One respondent disagreed with the restriction as a group of smaller producers would like to form a new producer organisation, however this would require a change in eligibility criteria.

It should be noted that changes in criteria, to be recognised as a producer organisation, in order to access funding via the Fruit and Vegetables Aid Scheme, are not being considered at this time. This is because on the UK’s exit from the EU, the legislative powers in assimilated regulations relating to recognition were transferred to the Secretary of State. Any changes would need to be developed with due regard to the legal framework.

Responses indicating no impact (No)

• One response supported the 3-year restriction for planning and alignment, suggesting it provides certainty and continuity.
• One respondent suggested a longer cycle.

Q10. Do you, or the organisation you represent, intend to apply for funding through the Fruit and Vegetables Aid Scheme in the future?

61% (10 out of 18) of respondents indicated yes, suggesting strong interest in applying for funding. 17% (3 out of 18) said they do not plan to apply for the scheme.

22% (5 out of 18) did not provide an answer, which could imply uncertainty or lack of decision.

Q11. Would a transitional provision be beneficial to you/your organisation?

39% of respondents (7 out of 18) indicated that a transitional provision would be beneficial to their organisations. However 4 of those responses are not eligible to receive support under the current scheme and an additional one states that a transitional provision would be beneficial if moving from one system to another, which is not being proposed at this time.

17% of respondents (3 out of 18) said that a transitional provision would not be beneficial.

The remaining respondents (44%; 8 out of 18) either didn’t answer the question or could not comment directly.

Respondents supporting a transitional provision, cited benefits such as:

• Preventing exclusion of new applicants due to timing.
• Allowing smaller or new groups time to meet operational requirements.
• Facilitating formation of Producer Organisations for small-scale growers.

One respondent said a transitional provision would not directly benefit them but acknowledged value for others.

Some respondents stated “No” or “Probably not”, as they are already aligned with the proposed funding cycle.