Good Food Nation proposals for legislation: analysis of consultation responses

Analysis of responses to the Good Food Nation Proposals for Legislation consultation.

Oversight of the Good Food Nation policy area

74. This section of the consultation paper noted the need for strong accountability and the importance of ensuring appropriate accountability for the performance of statutory functions that might be placed on Scottish Ministers and specified public authorities. The consultation paper proposed that Scottish Ministers and specified public authorities would be required to publish a statement of policy. Scottish Ministers would publish and lay their statement before the Scottish Parliament and specified public authorities would submit their statements to Scottish Ministers. They would be required to report every two years on implementation of the policy.

75. The consultation paper also noted that Scottish Ministers have a presumption against the establishment of new statutory bodies in all but exceptional cases and there was not seen to be value in establishing an independent statutory body for the purpose of overseeing the Good Food Nation policy. It was considered the establishment of a new body would be unnecessary as well as attracting increased costs and bureaucracy.

76. The third question asked,

Q3: To what extent do you agree with the proposed approach to accountability of Scottish Ministers and specified public authorities?

77. As shown in the following table, a total of 698 respondents answered this question. The highest level of agreement with the proposed approach came from 44% of local authorities; disagreement came from most other types of organisation (66%) (campaigning / advocacy, community groups, education / academic / research, faith groups, NHS / health, third sector (non-food) and other). Views were relatively polarised within representative body / trade unions and food / food retail / producer / distributors and third sector (food).


  Strongly agree Agree Neither agree nor disagree Disagree Strongly disagree Not answered
Campaigning / advocacy (13) - 1 - 1 10 1
Community group (10) - - - 1 6 3
Education / Academic / Research (14) - - 4 4 6 -
Faith group (10) 2 - - 2 6 -
Food / food retail / producer / distributor (17) 4 3 3 2 5 -
NHS / Health (12) 3 - 2 1 6 -
Local authority (16) 1 6 4 2 1 2
Representative body / trade union (16) 2 3 2 4 2 3
Third sector (food) (16) - 6 - 2 6 2
Third sector (not food) (35) 2 3 2 6 15 7
Other (16) 1 3 2 4 3 3
Total organisations 15 25 19 29 66 21
Individuals 107 94 25 96 222 83
Total respondents 122 119 44 125 288 104

78. A total of 552 respondents, across all sub-groups, opted to provide commentary in support of their initial response to this question.

79. The key theme emerging at this question and mentioned by 44% of consultation respondents was that there is a need for an independent statutory body to oversee all aspects of food in Scotland. This comment came from higher proportions of consultation respondents who disagreed with this proposal than agreed; and from higher numbers of respondents within the third sector, faith groups, community groups, campaigning / advocacy groups, academic / research and those within NHS / health organisations.

80. These consultation respondents cited a range of different reasons for the setting up of a statutory body and these included a need for:

  • Accountability.
  • Independent oversight.
  • A capacity for the review and oversight of progress of public bodies and Scottish Ministers who could be held accountable for reporting and ensuring the desired outcomes are met. Overall, this would allow for the reviewing of the implementation of Good Food Nation and monitoring of performance.
  • Strong regulatory powers; an independent statutory body would ensure these powers were established and utilised to the benefit of the people of Scotland.
  • An independent panel could address concerns over food security, climate change or loss of biodiversity.

81. Allied to this point, a significant number of consultation respondents noted that any independent statutory body would need to represent all sectors of society so as to ensure that actions taken are well targeted and benefit those most in need. A wide range of sectors were cited by these respondents; they also included a wide range of stakeholder organisations, organisations affected by food insecurity such as food banks and third sector organisations, community groups, food producers or growers and those with lived with experience of food insecurity. Typical comments included;

"The Government needs to be held responsible and have input by experts. There should be a panel of experts in all fields of food production from all sectors with input from those that have lived experience of food inequality. These people can talk about the reality of food poverty. The government should report to such an independent group before the policy is made and at regular intervals afterwards to make sure that the Government is working towards the goals that it sets out and that it is reflective in its work." (Faith organisation)

"Reporting only to the Parliament and Scottish Ministers is not a strong enough way of making sure we make Scotland a Good Food Nation. It is really important for the Government's plans and reports to be read by a group of people who are not part of the Government and who – as a group – have the power to review and demand progress. This group would be an independent statutory body with a role in protecting everyone's right to food by making sure the Government keeps its promises. They would provide the expertise needed to achieve our ambitious Good Food Nation vision." (Third sector)

82. The consultation paper also noted that Scottish Ministers have a presumption against the establishment of a new body in all but exceptional circumstances. However, a small number of consultation respondents disagreed with this and felt that, given the importance of food policy and its overriding impact across a range of sectors, that this does represent an exceptional case.

83. A significant number of consultation respondents who were supportive of an independent body made suggestions as to how this could be structured, with references to the Scottish Land Commission, the Poverty and Inequality Commission or the Welsh Future Generations organisation. For example, a number of these respondents noted the benefits of the Scottish Land Commission and the Poverty and Inequality Commission and felt that a similar organisation within the food sector would be beneficial.

84. A few consultation respondents simply noted that there is a need for a Food Commission or for reinstatement of the Scottish Food Commission without making reference to any existing body. They defined the role of this organisation as providing advice to Scottish Ministers and oversight of actions taken under the Good Food Nation policy.

85. There were also some suggestions that if a new statutory body is not established, it would be possible to use an existing body such as Food Standards Scotland, Public Health Scotland, SEPA, Nourish Scotland or the Poverty and Inequality Commission to provide an independent oversight and reviewing role.

86. A minority of consultation respondents noted that food impacts across a wide range of policy sectors and on all aspects of life and identified a need to ensure that the ethos of Good Food Nation is embedded across all sectors and all public authorities, for example, by linking into poverty initiatives. A small number of consultation respondents noted that current policies in relation to food are too fragmented. There was also reference from a few organisations that the introduction of Good Food Nation implies a fundamental shift in how Scotland governs the food system and a need for policy coherence to achieve Good Food Nation status.

87. A similar proportion of consultation respondents referred to a partnership approach being essential to the success of Good Food Nation, given the wide range of organisations affected by food insecurity and food policy. There were references to the need for departmental co-operation within the Scottish Government and across public authorities.

88. However, allied to this last point, a few consultation respondents – mainly local authorities – noted the need for additional resources if greater responsibilities are to be placed upon public authorities.

89. While a number of consultation respondents focused primarily on Good Food Nation in respect to Scotland, small numbers (mainly organisations) also noted the need for coherence in food policy on an international basis. For example, one organisation in the academic / research / education sector noted a need for an integrated approach to food and a need to recognise discussions at a European level to ensure an integrated approach can be developed.

90. Other issues raised by a few consultation respondents, mostly organisations who disagreed with this proposal, included a need:

  • To include a wider range of actions, for example, recycling food waste, reducing greenhouse gas emissions from agriculture, payment of the living wage to all workers allied to the food industry, emphasising locally grown food and good quality food.
  • For a clear framework outlining duties, and providing guidance for all involved.
  • For targets, outcomes and measured indicators of success such as key performance indicators.
  • For more regular reporting, or acceptance of the suggested reporting period but with interim reports published.
  • For a greater role for Parliamentary scrutiny.
  • For data collection and research so as to build a picture of the economic, health, social and environmental impacts of food policy.
  • For education within Scottish schools to ensure that individuals understand the importance of good food from an early age to help embed good eating habits for the future.
  • To enshrine the right to food in Scottish law.
  • 91. Consultation respondents who agreed with this proposal tended to provide little by way of commentary, although some noted their support for the proposal overall. Small numbers agreed with specific elements of the proposal such as an independent body not being needed, agreement that bureaucracy should not be increased or agreement with the suggested reporting periods.
  • 92. The Trussell Trust campaign responses disagreed with this proposal and focused on the need for evaluation of measures and targets to ensure they are met, by an independent statutory body comprised of experts and people with lived experience of food poverty. The other campaigns also supported the establishment of an independent statutory body.



    Back to top