The National Good Food Nation Plan - Accompanying Statement

Health, Social Care and Sport Committee

61. The HSCS Committee made the following recommendations, the Scottish Government response is provided for each.

Recommendation: The Committee highlights concerns raised in oral and written evidence that the Plan remains "quite siloed" in its approach and lacks the necessary detail concerning mechanisms that will foster the level of cross-sector and cross-portfolio collaboration necessary to deliver its outcomes. The Committee concludes that the Plan should demonstrate more clearly how the Scottish Government will lead this work.

62. Developing a more coherent and collaborative approach to food policy is one of the main aims of the Act. This is a challenging ambition, and the national Plan sets out the baseline for what we are doing already. It will support the change to a systems approach to food policy.

63. The document has been drafted to balance the needs of different audiences. The national Plan needs to ensure that the Outcomes the Scottish Ministers are working towards are made clear to a general audience, whilst also ensuring that the format of the national Plan enables the Scottish Ministers to meet their “have regard” duties.

64. One of the main purposes behind structuring the national Plan the way we have is to move away from a siloed approach. The current structure of the national Plan has been developed in close collaboration with a range of different policy areas across the Scottish Government. Input from different areas ensured that the structure was able to support policy officials to easily identify the Good Food Nation Outcome(s) that relates to their policy area, while also providing information on other policy areas that support those same Outcomes.

65. The national Plan contains details on embedding a joined-up approach to policy making and references the mechanisms that will be used to support a cross-policy and cross-portfolio approach, for example, by utilising the Official and Ministerial working groups. It also explains how the statutory duty on the Scottish Ministers to have regard to the national Plan is the mechanism by which the national Plan takes practical effect.

66. The wording in the national Plan has been edited to make it clearer how these mechanisms will support collaboration across a range of policy areas and ministerial portfolios.

Recommendation: The Committee highlights stakeholder concerns about the potential for conflict between national outcomes and priorities as set out in this Plan and those outcomes and priorities to be subsequently developed in local (local authority and health board) plans, informed by local circumstances. It further highlights the need for further collaboration and dialogue between the Scottish Government and those responsible for developing local plans to ensure proper coordination of national and local priorities and to avoid the risk of national and local plans conflicting with one another.

67. We recognise stakeholder concerns raised by the Committee about the potential for conflict between Outcomes and priorities within the national Plan and the development of the local Plans.

68. We are engaging with relevant authorities to understand what support will be most useful in the development of their local Plans. We will continue to consider how we can support relevant authorities in sharing of best practice.

69. The Act sets out legislative requirements that the relevant authorities need to fulfil when developing their own local Plans. This includes that they must have regard to the national Plan when developing their own local Plans. The Act also includes a list of matters and principles that the Scottish Ministers and relevant authorities must have regard to when developing their Plans.

70. These legislative requirements will ensure there is a minimum baseline that all relevant authorities should meet – the core aspects of what the national and local Plans must contain are very similar. This means there will be a common thread throughout all the Good Food Nation Plans, as they must consider these same aspects. We have published guidance for relevant authorities on the legislative requirements for their local Plans. We have run a workshop on those requirements to further support the relevant authorities in their planning and preparation for drafting their own local Plans. This reduces the risk of conflict between the national Plan and the local Plans, and also between the different local Plans. We believe it is right for the Scottish Government to provide relevant authorities with the autonomy to decide themselves how best to carry out those duties, appreciating that a one size fits all approach does not always work. This approach allows for a level of flexibility to better suit individual local requirements.

71. We will continue to engage with relevant authorities and we will be guided by their needs when determining the types of support they might find useful.

Recommendation: The Committee calls on the Scottish Government to set out what mechanisms it will put in place to ensure competing priorities in different areas, as highlighted in written and oral evidence, do not result in policy inertia or inhibit realisation of the Plan's stated outcomes.

72. We recognise that one of the challenges in transforming food policy is to achieve greater consistency in priorities across portfolios. This is one of the key aims of the Act, which has a mechanism built into it to ensure that the Scottish Ministers and relevant authorities will have regard to the national Plan when exercising specified functions or functions falling within specified descriptions.

73. This statutory duty ensures that even where there are competing priorities in different areas the need for the Scottish Ministers to have regard to the national Plan when carrying out a wide range of food related functions will ensure there is a co-ordinated and joined up approach.

74. The specified functions or functions falling within specified descriptions will be set out in secondary legislation.

75. These mechanisms are underpinned by a systems approach i.e. a method of solving problems and advancing solutions that considers the interconnections within and between systems to achieve sustained, systemic change at scale^[2]. This takes time but helps us in the long run to build a better food system.

Recommendation: The Committee highlights stakeholder concerns that the Plan's focus on tackling obesity and overweight, and how this is measured, needs to be carefully considered in the context of many individuals, particularly in older demographics, who may be suffering from malnutrition. It calls on the Scottish Government, in finalising the Plan, to make every effort to ensure that its primary focus remains on addressing the whole food environment rather than placing the onus on individual behaviour.

76. We recognise the importance of supporting the Scottish population to achieve and maintain a healthy weight. This is reflected in the Good Food Nation Outcomes, in particular Outcome 3: ‘Scotland’s food environment and wider food system enables and promotes a physically and mentally healthy population. This leads to the prevention of, and a reduction in, diet-related conditions.’

77. The emphasis of this Outcome wording has been strengthened following the public consultation to put the food environment centre stage. We agree with the Committee that focus needs to be on addressing the food environment rather than individual action.

78. We recognise that particular subgroups may have particular needs in relation to achieving and/or maintaining a healthy weight. We have added a new specific reference to malnutrition in the national Plan to make it clear that we recognise that malnutrition is an equally important issue to address when achieving and maintaining a healthy weight. Actions on malnutrition will be set out in our upcoming Diet and Healthy Weight implementation plan, due to be published in 2026.

79. In relation to indicators set out in Part 3 of the Plan, we will monitor healthy weight at a population level. Disaggregated data by sex and age is available separately on the Scottish Health Survey dashboard. The analytical publication that accompanies the national Plan also provides an explanation for the choice of each individual indicator.

Recommendation: The Committee highlights the important responsibilities the food industry has in contributing actively to the delivery of health and sustainability Outcomes.

80. We note the important responsibilities the food industry has in contributing to delivering health and sustainability outcomes, highlighted by the Committee. We recognise the importance of all actors if the food system in playing a role in delivering the Good Food Nation ambition, including the food industry and third sector. The Act places no legal duty on the food industry, however we have met the legal requirement set out in the Act to ensure that the implementation of the policies set out in the national Plan are informed by the views of the food business sector (as defined in section 2 of the Act).

81. In terms of the food industry actively contributing towards delivery of health and sustainability Outcomes, leading the way in environmental sustainability is one of the main missions of Scotland’s national food and drink industry-led strategy, “Sustaining Scotland, Supplying the World”. Additionally, the Scotland Food & Drink Partnership’s Net Zero Commitment is providing the resources and mechanisms to tackle shared challenges across the supply chain. This includes development of a climate transition plan, sustainability benchmarking and carbon literacy training and support for businesses.

82. In addition, we have provided funding to Food and Drink Federation Scotland (FDFS) since 2019 to deliver the Reformulation for Health Programme. The programme is playing an important role in improving dietary health by removing hundreds of millions of calories from Scottish food and drink products. We recognise the progress that manufacturers have made to reduce the amount of fat, sugar or salt in their products. Having a range of increasingly healthier products available in our supermarkets and in our out of home settings is helping to improve our food environment and supporting people to make positive changes to their diet.

Recommendation: The Committee draws attention to calls from stakeholders for the Plan to shift its focus on the role of the food industry in delivering a Good Food Nation from one that primarily emphasises the industry's economic contribution towards one that emphasises its contribution towards delivering health and sustainability outcomes. The Committee calls on the Scottish Government, in responding to this report, to address these concerns directly.

83. We recognise that the food business sector has a vital role to play in achieving food system transformation. Our Good Food Nation Outcomes recognise this: in particular Outcome 2 envisions a sustainable food system. The wording of this Outcome applies to the entire system and not just parts of the system. While Outcome 4 has a particular economy focus, it should be considered alongside other Outcomes.

84. We encourage everyone who is required to have regard to the national Plan to consider the Outcomes as a set of six, rather than individually and this approach will be reiterated by Good Food Nation officials throughout our engagement with colleagues and stakeholders.

85. We have updated wording in the national Plan to make it clearer that the Outcomes need to be considered as a consistent set.

Recommendation: The Committee highlights the need for greater consistency in the use of indicators across multiple policy frameworks, notably the Plan currently under scrutiny and the Population Health Framework. It believes this will help to ensure a unity of purpose towards creating a Good Food Nation across these different frameworks, as well as reducing unnecessary administrative burden on those responsible for monitoring progress.

86. We recognise the importance of a consistent approach to the use of indicators. This is why we have focused on data that is already available and used in other parts of the public sector.

87. Where the interests of the Population Health Framework and Good Food Nation overlap we make use of the same data from the Scottish Health Survey. In response to the Committee’s comments, we have made the decision to change the indicator in the final national Plan which monitors progress on adult weight from average/mean BMI (body mass index) to the percentage of adults with a healthy weight, to align with the Population Health Framework. We use percentage at healthy weight for children which is the same as for the Population Health Framework.

88. We have taken care to ensure the indicators used remain relevant to each programme of work, for example some indicators used by the Population Health Framework focus on wider population health, which we consider too far removed to be of relevance to measuring progress against Good Food Nation Outcomes. In contrast, indicators on other parts of the food system are included in the Good Food Nation indicator framework but these are of limited relevance to the Population Health Framework.

89. We will keep this under review as the monitoring framework for the Population Health Framework is developed further and will consider aligning, at appropriate points in our review and revision cycle, if new indicators of relevance are added.

Recommendation: The Committee acknowledges a range of views on the issue of food education. It further acknowledges the concerns expressed by certain witnesses in oral evidence that placing an undue focus on developing cooking skills risks shifting the onus of the Plan from tackling the wider food environment towards an emphasis on addressing individual behaviour. At the same time, the Committee firmly believes there is an important role for education in shifting broader attitudes to food and food culture and that this must be seen in the context of addressing wider barriers to healthy, sustainable, affordable and convenient food choices.

90. The evidence provided to the HSCS Committee demonstrated the varying opinions on the issue of food education. As was highlighted in the Committee session, education does have an important role to play but it cannot be considered in isolation, rather as one aspect of the food environment. There is research ^{e.g. [3],[4],[5]} that demonstrates food education alone may not have the effect of shifting broader attitudes to food and food culture.

91. However, there is a role for learning about food through the Curriculum for Excellence and the proposed Plan sets out the key aspects that are currently included in the education of children aged 3 to 18 in Scotland, which includes learning about food choices and sustainability. This includes learning practical cookery skills and being aware of where the food they are cooking comes from. The proposed Plan also notes the support that is provided to fund various education initiatives, such as farm visits for schools and food and hygiene courses offered via the Royal Environmental Health Institute for Scotland Schools Initiative.

92. All these different strands contribute to a range of food education and demonstrate one of the main aims of the national Plan – to ensure more joined up policymaking. Taking a cross-cutting systems approach to food education will help address the wider barriers that the Committee point to in their recommendation. This will mean that the onus is not only on individuals but rather the issue will be tackled in a way that considers the food system as a whole.

Recommendation: The Committee recognises the importance of convenience in modern society and the need, in that context, for healthy and sustainable food options to be convenient for the vision of a Good Food Nation to be successfully realised in Scotland. It has therefore been particularly interested to learn of examples of the development of community diners as a means of giving people easier and more convenient access to affordable, locally sourced, healthy and sustainable food. The Committee recognises ongoing work to explore the development of similar schemes in Scotland and calls on the Scottish Government to commit the resources necessary to support their more strategic and systematic implementation as part of the Plan.

93. We note the interest from the Committee in the development of community diners. We will continue to follow the development of public dining spaces with interest.

94. We will also be interested in seeing the outcomes of the UK Research and Innovation (UKRI) funded study of public diners, which includes a pilot in Dundee. This will be helpful in building the evidence base on public diners and to inform future consideration of this issue.

Recommendation: The Committee is firmly of the view that, for a Good Food Nation to be successfully realised, the health and social care sectors will need to be involved as equal partners in the development and delivery of national and local plans, both as procurers of food for patients and residents, but also with respect to addressing wider public health concerns.

95. We note the view of the Committee regarding the importance of health and social care sectors delivering at a local and national level on the Good Food Nation ambition.

96. The Act sets out that when determining the content of the Plans (both national and local), Scottish Ministers and relevant authorities must have regard to the scope for food-related issues to affect Outcomes in relation to a range of issues. These issues include health and physical and mental wellbeing (including in particular through the provision of health and social care services). The important links between the health and social care sector are therefore already embedded in the legislation and consequently the development of the Plans at both the national and local levels.

Recommendation: The Committee recognises the pivotal role of schools in fostering healthy eating at an early age and in delivering a Good Food Nation. In this context, it notes widespread support in oral and written evidence for the wider roll-out of universal free school meals. It also recognises that planning policy, collaboration with food outlets located in the vicinity of schools and making staying in school over lunchtime a more attractive option all have a role to play in improving children's nutritional health.

97. We agree that schools play an important role in a Good Food Nation. While the expansion of the Free School Meal programme universally in primary is on hold, we are currently focused on delivering the latest phase of our free school meal expansion programme, taking a targeted approach to support those children most in need in Primary 6 and 7 whose families are in receipt of the Scottish Child Payment.

98. This phase began in February 2025 and we estimate it will benefit an additional 25,000 pupils. It is expected that once this phase is completed 84% of all primary children will benefit from the opportunity to take free school meals.

99. In addition, we established a test of change offering free school meals to pupils in secondaries 1 to 3 whose families receive the Scottish Child Payment in August 2025. It will run at selected schools across 8 local authority areas to July 2026 and we expect it to benefit around 6,100 pupils.

100. We review the eligibility criteria for free school meals annually to take account of changes to the national living wage. The criteria was last updated in April 2025.

101. In relation to the Committee’s point on planning policy, we want to highlight that the National Planning Framework 4 policy sets out that development proposals for non-retail uses will not be supported if further provision of these services will undermine the character and amenity of the area or the health and wellbeing of communities, particularly in disadvantaged areas. Scotland’s planning system works under the general principle that decisions are taken at the local administrative level/local planning authority in the first instance.

Recommendation: The Committee highlights stakeholder calls for the Plan to place a greater emphasis on a 'One health' approach towards creating a Good Food Nation. It further notes evidence that, for this to be achieved, there will be a need for a wide range of policy areas, and particularly food production, to be better aligned towards collectively meeting the goals that underpin a 'One health' approach.

102. We note the views expressed in relation to the One Health approach. Although the national Plan does not explicitly mention the One Health approach, our aim of having a whole systems approach to food policy, for example within our Good Food Nation and Population Health Framework, closely tracks the overall purpose of this approach. Our aim is to have more joined-up and coherent food policy and this will mean working across related policy areas.

Recommendation: The Committee also notes the Plan does not yet address some of the inherent problematic issues arising from the food and drink industry. It calls on the Scottish Government to respond to evidence it has heard about the potential public health impact of health-harming products such as alcohol, and levels of consumption of red and processed meats.

103. We note the Committee’s view on this issue. The legal definition of food includes drink. Just as we must consider the health harms associated with our diets, we must do the same in relation to the harms associated with alcohol. Our work to increase the minimum unit price of alcohol is an example of our approach to take concrete action to reduce alcohol harms. We have updated the national Plan to reflect what we are doing to prevent harm associated with alcohol consumption.

104. It is also important to recognise that the alcohol industry in Scotland features businesses of every possible size and structure, provides skilled employment in some of the most rural communities, attracts significant tourism, and connects Scotland to the world.

105. The Scottish Government does not work with the alcohol industry on the development of health policy but engages with the industry on the potential impacts, effects and implementation of alcohol harm prevention policy, where appropriate. This is set out in the 2018 Alcohol Harm Prevention Framework. Work is currently underway to develop a refreshed Alcohol and Drugs Strategic plan which will sit alongside the Population Health Framework, published earlier this year.

106. Crucially, prevention does not sit within a single policy area. It requires coordinated action across education, transport, housing, economy, and health. This whole-system, cross-government approach is exactly what the Population Health Framework is designed to deliver in the context of population health and Good Food Nation in the context of the food system.

107. In the national Plan we have set out that the Scottish Dietary Goals and the Eatwell Guide are at the foundations of a healthy and balanced diet in Scotland, including adequate consumption of specific food groups. This includes recommendations around levels of consumption of red and red processed meat.

108. Whilst Scotland already meets the Scottish Dietary Goal for red and red processed meat consumption at population level, around a third of the population currently exceed this. There would be significant national health benefits (e.g. reductions in incidence of colo-rectal cancer and type 2 diabetes) if each and every person met the recommended Scottish Dietary Goal of an average intake between 0g and 70g per day.

Recommendation: The Committee is firmly of the view that, in light of emerging evidence of their negative impact, a clear and comprehensive definition of ultra high-processed foods and ultra processed foods is urgently needed. It further believes that policy development in this area needs to be led by public health interest rather than the economic interests of the food industry. In this context, it calls on the Scottish Government to keep this area under active review and to be ready to incorporate any agreed policy response into future iterations of the Plan.

109. We note the concern of the Committee in relation to ultra processed foods. We are engaging regularly with Public Health Nutrition colleagues at Food Standards Scotland who continue to monitor the latest evidence relating to ultra processed foods.

Recommendation: The Committee recognises the critical importance of delivering equity of access to nutritious food across the Scottish population as a fundamental prerequisite for achieving a Good Food Nation. In this context, it highlights stakeholder views that the Plan should place greater emphasis on monitoring levels of food insecurity as a mechanism for measuring the Plan's success in overcoming unequal access to nutritious food.

110. We agree that access to good food for all is key to achieving a Good Food Nation, this is why it is an integral part of our Outcome 1: ‘The food environment in Scotland enables people to eat well. Everyone benefits from reliable and dignified access to safe, nutritious, affordable, enjoyable, sustainable and age-appropriate food.’

111. To monitor access to food, we have included an indicator on the level of food insecurity concern among the Scottish population. This indicator can be used to assess general progress in this area.

112. We explored including other measures, such as the scale and scope of food bank provision in Scotland. However, while one-off studies exist there is no regular data gathering in place. Data is available from individual providers such as the Trussell Trust, who measure the number of food parcels they distribute. This data did not meet the criteria we have identified for inclusion as full indicators, but detailed information on this additional data is available in the separate analytical publication. We will keep the available data under review and explore any possible additions to our indicator framework as part of our progress reporting and review and revision process.

Recommendation: The Committee highlights stakeholder evidence in favour of creating clear guidance for public bodies to ensure Good Food Nation principles are effectively embedded into food procurement practices. It calls on the Scottish Government to provide a commitment that this will be a core component of the Plan's implementation.

113. As noted above in the responses to the LGHP Committee we remain committed to providing good quality support and training and have an ongoing process of reviewing and improving our offer. We frequently meet with organisations to understand the barriers they face, and to raise awareness of our tools, guidance and initiatives to make it as easy as possible for them to bid for and win public contracts. A summary of these resources will be set out in an Annex to the national Plan alongside an outline of guidance and support available for public sector buyers.

Recommendation: The Committee recognises the critical role third sector organisations play in delivering many successful community initiatives to promote access to, and growing of affordable, locally sourced, healthy and sustainable food. It further recognises calls in evidence for a commitment to fair funding to give these organisations the confidence to plan and invest long-term in the continued delivery of these initiatives.

114. We note the Committee’s recognition of the critical role third sector organisations play in delivering the Good Food Nation ambition, including community and voluntary organisations. The third sector is hugely diverse and works alongside the public and private sectors across all services and industries, often providing lifeline services in our most vulnerable communities.

115. We acknowledge that the cumulative impact of rising costs and increased service demand since the pandemic mean that third sector budgets continue to be under similar pressures to those facing the public sector. Understandably, there are calls being made on the Scottish Government for more support. We will continue to respond as positively and comprehensively as we can.

116. We recognise that the third sector needs support, stability and the opportunity for longer term planning and development. We have committed to delivering a Fairer Funding Pilot that provides multi-year funding to third sector organisations, prioritising those that deliver frontline services and tackle child poverty. The Pilot consists of government grants to third sector organisations totalling over £130 million over 2025-26 and 2026-27. This will support projects in areas including health, education, justice, poverty and culture.

117. This Pilot is the first step towards mainstreaming multi-year funding agreements across the third sector, and balances our ambitions against the challenging financial situation. Our commitment to increasing multi-year funding has been welcomed by participating third sector organisations and the Scottish Council for Voluntary Organisations. We will be undertaking a robust evaluation of the Pilot, and are committed to delivering an interim assessment by May 2026. This work will help us to identify any impacts, and build the case for further multi-year funding arrangements.

Recommendation: The Committee recognises the huge potential for improvements to Scotland's food environment to have significant benefits to our mental health. It highlights stakeholder evidence arguing for a greater emphasis in the Plan on indicators related to mental health as an important measure of its successful implementation. It further notes that the positive mental health impacts of access to good food, eating together and growing food are well-evidenced.

118. We agree with the Committee’s assessment that the food system and mental health are closely linked and we will keep this area under review. However, at this point in time we are unable to include a robust data indicator in the national Plan. In the accompanying analytical publication that was published alongside the national Plan, we set out some of the complexity in linking food and mental health outcomes, whilst also acknowledging the evidence linking good mental health outcomes and activities such as communal eating and growing your own food.

Recommendation: The Committee highlights widespread evidence calling for greater clarity concerning the purpose and role of the proposed Scottish Food Commission, including in relation to monitoring and data, capacity and resourcing, lines of accountability, and how it will collaborate and interact with other bodies and decision-makers to achieve effective delivery of the Plan.

119. The functions of the Scottish Food Commission are clearly set out in the Act .

120. As an executive non-departmental public body, the Scottish Food Commission also has clearly defined lines of accountability. The chair and members of the Scottish Food Commission are accountable to the Scottish Ministers. The Chief Executive is the accountable officer of the organisation, and the members of the Commission will hold them to account.

121. Once a Chief Executive has taken up post the roles, responsibilities, and relationship between the Scottish Food Commission and Scottish Ministers will be set out in a framework document.

122. The Scottish Food Commission has independence over how it will exercise its functions and once a senior management team is in place this will be set out in a corporate plan. The Scottish Food Commission will also be able to develop its own relationships with other public bodies.

Recommendation: The Committee draws its recommendations to the attention of the Scottish Government and calls on it to ensure these are suitably addressed in its preparation of the finalised national Good Food Nation Plan.

123. The Scottish Government thank the Committee for the time taken to scrutinise the proposed Plan. A response is provided against each recommendation as to how it has been addressed and where updates have been made to the Plan this has been noted.