National Good Food Nation Plan: Child Rights and Wellbeing Impact Assessment

Child Rights and Wellbeing Impact Assessment Template

1. Brief Summary

Type of proposal:

• Decision of a strategic nature relating to the rights and wellbeing of children

Name the proposal and describe its overall aims and intended purpose.

The Good Food Nation (Scotland) Act 2022 (“the Act”) places a duty on Scottish Ministers to produce a national good food nation plan which must set out the main outcomes in relation to food-related issues which the Scottish Ministers want to be achieved in relation to Scotland. The plan must also set out the policies that the Scottish Ministers intend to pursue in order to achieve these outcomes and the measures and indicators that will be used to assess progress.

This CRWIA covers the first iteration of the national Good Food Nation Plan. The Plan introduces six new overarching Outcomes which indicate key areas of focus that enable us to further develop our status as a Good Food Nation. Other than these Outcomes, the Plan is primarily a collection of existing policies, indicators and targets that relate to food. The Plan brings these together in one place for the first time to facilitate a joined up and coherent approach to food policy, but the policies themselves are not new.

Start date of proposal’s development: August 2022 (Royal Assent of Good Food Nation (Scotland) Act 2022)

Start date of CRWIA process: August 2022

2. With reference given to the requirements of the UNCRC (Incorporation) (Scotland) Act 2024, which aspects of the proposal are relevant to/impact upon children’s rights?

The national Good Food Nation Plan sets out six over-arching Outcomes for a Good Food Nation. The Act requires that the Scottish Ministers have regard to the Plan, and therefore the Outcomes within it, when exercising certain functions. These functions will be specified in secondary legislation which is still being developed and will be subject to its own CRWIA. The Plan will therefore have indirect effects on everyone in Scotland, including children and young people.

It is difficult to establish exactly what impact the first iteration of the Good Food Nation Plan might have upon children’s rights. If the food systems approach to a joined-up development of policy to achieve the Outcomes is achieved, then this would have a positive impact on a number of children’s rights, potentially including the following articles set out in the UN Convention on the Rights of the Child:

Article 3 (Best interests of the child): this article references wellbeing of which food is an important part.

Article 6 (Life, survival and development): food is fundamental to all these needs.

Article 23 (Children with a disability): ensuring food provision is undertaken in a way that accounts for a disability is an important part of realising this right.

Article 24 (Health and health services): this Article makes reference to the provision of adequate nutritious food. The Plan has been prepared with regard specifically to Article 24(2)(c) so far as it concerns the provision of adequate nutritious foods. Aims to improve nutrition and access to nutritious food to promote a physically and mentally healthy population are reflected in Outcomes 1 and 3 set out in the Plan.

Article 26 (Social security): social security can involve provision of food or access to food and this is reflected in the aims of the Outcomes set out in the Plan.

Article 27 (Adequate standard of living): this Article provides for the right of every child to an adequate standard of living, which includes nutrition. When preparing the Plan, the Scottish Ministers were required to have regard to article 27(1) and (3) so far as it relates to nutrition. Ensuring everyone has access to nutritious food is key to the Plan, specifically Outcome 1. Food could potentially also contribute more generally to the aims of this article and food policies are often interlinked to other policies in terms of ensuring an adequate standard of living.

Article 29 (Goals of education) provides that education of the child shall be directed to, amongst other things, the development of the child’s mental and physical abilities and the development of respect for the natural environment. Outcome 5 provides that Scotland has a population who are educated about good and sustainable food, the achievement of which would contribute to the realisation of this Article.

Article 31 (Leisure, play and culture), food touches on all these aspects e.g. learning about gardening and growing food as well as the importance of food culture for children.

However, the Outcomes will not be achieved by the first Plan; rather the intention is that progress will be made towards achieving them.

The Plan is given legal effect by a ‘have regard’ duty in the Act. This requires the Scottish Ministers to have regard to the Plan when exercising functions specified in secondary legislation. Therefore, whilst the intention is that progress will be made towards achieving the Outcomes, the ‘have regard’ duty does not mandate this.

The primary goal of this first national Good Food Nation Plan is to embed new working practices in relation to the development of food policy within Scottish Government and to set out broad overarching aims. Food policy touches on a wide range of policy areas and will therefore also be of relevance to a wide range of the Articles set out in the UN Convention on the Rights of the Child.

3. Please provide a summary of the evidence gathered which will be used to inform your decision-making and the content of the proposal

We have gathered the following data from key relevant publications. They highlight that children’s experience of the food system is strongly impacted by the socio-economic status of their families.

Children (aged 2-15) living in the most deprived areas of Scotland are at greater risk of being overweight then children from the least deprived areas. In 2021, less than half of children in the most deprived communities in Scotland have a healthy weight (48%), compared to 72% in the least deprived communities.^[1]

Recent statistics from Public Health Scotland^[2] on the weight of children at Primary 1 highlight that:

• In 2023/24, children living in more deprived areas were less likely to have a healthy weight. Among children living in the most deprived fifth of areas 72.0% had a healthy weight, compared to 82.0% in the least deprived areas.
• Children living in more deprived areas were more than twice as likely to be at risk of obesity (14.0%) than children living in the least deprived areas (6.4%), and were also more likely to be at risk of overweight (12.7% in the most deprived areas, compared to 10.5% in the least deprived areas).

The Family Resources Survey^[3] run by the Department of Work and Pension also highlights that households with children are less likely to be food secure than households with only adults.

Tooth decay in children is a good indicator for the quality of children’s diet in particular the inclusion of sugars. Child oral health has improved over recent decades. In 2024, 73.2% of Primary 1 children examined showed no obvious decay experience. Child oral health inequalities remain with 60.1% of children living in the most deprived areas having no obvious decay experience, compared to 83.6% in the least deprived areas^[4]

Statistics on fruit and vegetable consumption by children demonstrate that mean fruit and vegetable consumption by children in 2023 has improved since 2019, with mean values indicating slightly more than 3 portions consumed per day (3.1 in 2023).^[5]

18% of all children consume 5 portions per day but fewer children living in most deprived areas consume 5 portions per day (15%) than in the least deprived areas (21%).^[6]

Food provided in schools can make a valuable contribution to improving the nutritional quality of diets and promoting consistent messages about healthy eating. The overall uptake rate for Free School Meals (FSM) across all school types was 71.0% in 2024. This was down from 76.2% in 2020, and also below the series peak of 85.0% in 2014.^[7]

In addition to gathering relevant statistical evidence, we also undertook targeted engagement with children and young people (“CYP”) via schools as part of a public consultation on a draft of the national Good Food Nation Plan between January and April 2024.

A Good Food Nation Sample Session Plan was distributed to schools, with the aim of providing a resource to guide a discussion around the draft Plan. This included a Microsoft form which asked questions about the Outcomes in Easy Read format. Teachers and pupils were encouraged to participate and offer their views. The Session Plan was developed using children’s rights as the lens, as we knew children would be familiar with the concept of rights already.

A total of 883 responses were received from CYP aged 13 or older. A further 202 responses were received from teachers who responded on behalf of children aged under 13: for data protection reasons younger children were not able to respond individually.

The survey asked:

• Q1: What in your view would be different about children's lives in a Good Food Nation compared to now?
• The most mentioned theme, cited by a significant minority, was that children would have access to, or be eating more, healthier food. Healthier food was described as that which is more nutritious, contains vitamins and proteins, is organic or is food appropriate regarding age or body type. It was also envisaged that these types of foods would be as at least as cheap as unhealthy food. Allied to this were a significant minority who foresaw that children would have a better diet.
• A second main theme (also from a significant minority) thought that food in general would be cheaper and more affordable, citing free school meals as an example. This would have the positive impact of making more money available for other things. Smaller minorities foresaw less hunger or less food poverty (e.g. less need for food banks and fewer homeless people). Associated with this, a significant minority predicted that every child would have full and equal access to food.
• The final main theme from answers (more so from the teacher-led category than the 13+ group) was that children (and other people) would be healthier.
• Q2: The Scottish Government thinks that every child in a Good Food Nation should: get and enjoy healthy food that is right for their age; have many chances to learn about food; and never experience hunger. Is there anything you would like to add or change?
• A majority agreed with the list and had nothing to add. Most other answers expanded on the topics of the three statements.
• Food affordability was the most mentioned theme, albeit only mentioned by a small minority. Children reinforced that there should always be affordable options. Smaller numbers wanted to ensure equity of access of food for all.
• Better access in terms of food choice was urged by similar numbers. It was intimated this would encourage children to make healthy choices. Suitable food choices for those from different cultures and with dietary needs (e.g. because of allergies) was also requested.
• Slightly smaller numbers reinforced that children should have access to healthier, better quality, sufficiently nutritious food. Improvements to school food, fresher food and clean drinking water access were all mentioned in relation to this. Further requests were about having food that is enjoyable and looks and tastes good rather than bland and unappealing food.
• A small minority reinforced the importance of learning opportunities about food, with a few saying this should be from a young age. Many of these responses focused on children having the chance to cook or make healthy food in school. Further mentions concerned having the chance to grow food or to enhance home economics by making this more frequent or compulsory. A few responses referred to learning about environmental benefits and impacts.
• Q3-Q8 asked for comments on the six Good Food Nation Outcomes, in their Easy Read forms. Children and young people were asked if they thought each Outcome was a right one for a Good Food Nation.
• Outcome 1: Everyone in Scotland eats well. They can easily get safe, healthy, affordable, environmentally friendly food that suits their age and culture. A large majority agreed with this Outcome. The main reason for supporting the Outcome (from a significant minority) was that everyone will be treated fairly and equally in term of food access so that it helps everyone. A small minority disagreed with the Outcome, in the main expressing doubts that everyone can eat well, citing affordability concerns regarding healthy food. There was also concern about whether the Outcome can be achieved due to the amount of government support needed and due to some people preferring unhealthy food to healthy food.
• Outcome 2: Scotland’s food system is good for the natural environment, the climate, wildlife, and animal welfare. A large majority agreed with this Outcome, citing a variety of reasons such as the importance of better outcomes for animal welfare, the climate, nature and the environment. A small minority disagreed with Outcome 2. The main concerns were over the use of, and pollution caused by, chemicals and additives used in food processing, and over animal welfare. In the latter case, there were a few concerns over animals’ diets being impacted by harmful waste and fertilisers.
• Outcome 3: Scotland’s food system helps everyone to have good physical and mental health. A large majority again cited general agreement with this Outcome. The largest numbers – a significant minority of respondents – believed this Outcome would be helpful for improved mental health, particularly with respect to better sleep and concentration. Slightly fewer thought this would be beneficial for physical health. A significant minority added the caveat that the Outcome was right as long as everyone has access to and consumed healthy nutritious food. There were also a few comments about eating less unhealthy food. A small minority disagreed that Outcome 3 is a right Outcome. Concerns were expressed about Scotland’s food currently being too unhealthy to help due to the prevalence and ease of purchasing junk food and sweets, for example. There was also some worry about not being able to eat the food people want to or need to because of dietary requirements. Similarly, a few respondents were unsure that good food would help with mental health, especially if it meant people could no longer eat their favourite foods.
• Outcome 4: Scotland is known around the world for high-quality food. Our food and drink industry is successful and forward-thinking. It is an important part of the national and local economy. It supports and creates good jobs. A large majority cited general agreement with the Outcome. The largest numbers – albeit a small minority – agreed the Outcome would support jobs, citing increased job creation and choices. There was also some mention of increased employment helping with food affordability as this was perceived to help people provide for themselves and their families. Advantages were also foreseen in terms of fair pay and fair producer pricing within the food industry. A small minority disagreed that this was a right Outcome. Concerns were again raised about the costs and affordability of good food. There was also some disagreement that Scotland is known for high-quality food.
• Outcome 5: Scotland has a good food culture. Scottish people are interested in and educated about good and sustainable food. A large majority again cited general agreement that this was a right Outcome. The main response, cited by a significant minority, recognised the importance of everyone being more educated about food. This included food choices and explanations about a healthy and balanced diet, nutrients, traditional foods and other food cultures. Amongst the small minority who disagreed that Outcome 5 is a right Outcome, there were some perceptions that many people are not interested in learning about food and that more interesting ways need to be found to educate people about food. A few responses disagreed that Scotland has a good food culture.
• Outcome 6: Decisions we make in Scotland are good for food systems here and around the world. We share and learn from what other countries are doing. A large majority again cited general agreement that this was a right Outcome. The main theme, cited by a significant minority, was that it was good to share ideas and information about food systems to see how we can learn from other countries to make Scotland’s food better. Benefits were foreseen such as widening food choice, broadening inclusivity and helping to stop global malnutrition. Other perceived spin-off benefits were improved health, better environmental health and in aiding good relations with other countries. Among the small minority who saw drawbacks with Outcome 6, it was perceived that some countries’ foods are less healthy than Scotland’s, or that Scotland’s food was not good quality and therefore it was not right to share it. Other responses referred to difficulties in sharing food experiences effectively (e.g. because of differing climates) or a preference to use local foods rather than imports.
• Q9: Is there anything missing from the set of 6 Outcomes that you think is important in a Good Food Nation?
• A large majority said that nothing needed to be added, agreeing the Outcomes covered everything important to become a Good Food Nation. Most other responses reiterated views expressed about the individual Outcomes.
• Q10: Do you have any suggestions for what the Scottish Government could do to help Scotland become a Good Food Nation?
• A majority said they had no suggestions, with a small minority approving of the current proposals. By far the most suggestions (from a significant minority overall) again referred to help with food costs, with requests to make food more affordable for all.

4. Further to the evidence described at ‘3’ have you identified any 'gaps' in evidence which may prevent determination of impact? If yes, please provide an explanation of how they will be addressed

The consultation provided us with helpful evidence of how children and young people view the concept of Good Food Nation. However, it did not provide a great deal of evidence about how specific actions to achieve the Outcomes might impact upon children’s rights. The aim is that the Outcomes will be achieved by pursuing the wide range of policies set out in the Plan, which have or will be independently impact assessed and also through the requirement for the Scottish Ministers to have regard to the Plan when exercising specified functions. It is the action taken to achieve the Outcomes that will have an impact on children’s rights, rather than the Outcomes themselves. The primary goal of this first iteration of the Good Food Nation Plan is to embed new working practices across the Scottish Government and ensure that future food policy is created in a cohesive manner.

5. Analysis of Evidence

The evidence gathered suggests that children are experiencing inequalities in the food system, in particular in the context of the socio-economic status of their families. This is particularly evident in relation to:

• Food insecurity
• Healthy Diet
• Healthy Weight

The main inequalities identified are also reflected in the wording of Good Food Nation Outcomes.

The evidence we gathered during the consultation suggests that children generally agree with the overall wording of the Outcomes. They also highlighted concerns that align with the main areas of inequalities highlighted in statistical evidence. Children and young people are aware of the concept of a Good Food Nation, and appreciate it’s importance, but they do not readily identify any direct impacts on their own rights from the proposals in the current Plan. As set out above, this is understandable given that it will be the action taken to achieve the Outcomes that will have an impact, rather than the Outcomes themselves. At this stage it is not possible to identify any specific impacts on children rights and wellbeing that would be generated as a direct result of the national Good Food Nation Plan. However, we envisage that as the policies in the Plan continue to be implemented and delivered, and regard is had to the Plan when Scottish Ministers exercise their specified functions, this will have a positive impact on children's health, nutrition and access to food and food education which will in turn have a positive impact on children's rights and wellbeing.

6. What changes (if any) have been made to the proposal as a result of this assessment?

Responses of children and young people, broadly aligned with the topics raised in the general consultation. In particular, changes have been made to the wording of the Outcomes, the structure of the Plan and how existing policies are presented. In addition, we also included specific indicators on children in the plan, that are reflective of the key challenges in the food system. These indicators are:

• Uptake of Free School Meal Provision in Primary and Secondary Schools
• Mean portions of fruit and vegetables consumed by children
• The proportion of children with a healthy weight (as measured by BMI)
• The difference in the proportion of children with a healthy weight (as measured by BMI) in the most and least deprived quintiles
• Percentage of Primary 1 children with no obvious tooth decay

We also asked children and young people for their views on what a Good Food Nation should look like for children. We have incorporated this feedback into a new section of the national Good Food Nation Plan called “Life in a Good Food Nation- The Vision”. This section consists of a series of short narratives that follow describe in greater depth how the Good Food Nation vision might look in practice for different groups of society.