The National Good Food Nation Plan - Updated EQIA

Key Findings

Human Rights

The Act recognises the importance of human rights. Section 5 stipulates that in preparing this Plan, the Scottish Ministers must have regard to the following international human rights instruments:

• Article 11 (so far as it concerns adequate food) of the International Covenant on Economic, Social and Cultural Rights (“ICESCR”).
• Article 24(2)(c) (so far as it concerns the provision of adequate nutritious foods) of the United Nations Convention on the Rights of the Child (“UNCRC”).
• Articles 27(1) and (3) (so far as they concern nutrition) of the UNCRC.
• Article 12(2) (so far as it as concerns adequate nutrition during pregnancy and lactation) of the Convention on the Elimination of All Forms of Discrimination Against Women (“CEDAW”).

These instruments are woven into the national Good Food Nation Outcomes and therefore throughout the rest of the national Plan. We are committed to respecting, protecting and fulfilling internationally recognised human rights. The right to adequate food is a human right, as part of the right to an adequate standard of living under article 11 of the International Covenant on Economic, Social and Cultural Rights, and essential to the realisation of other human rights. The right to adequate food can only be fully guaranteed by addressing the accessibility, availability, acceptability, quality of food in an integrated and systemic manner, and by recognising the indivisible, interdependent and interrelated nature of all human rights which are underpinned by dignity.

The United Nations Committee on Economic, Social and Cultural Rights considers the key components of the right to adequate food includes:

Availability:

• Food should be culturally acceptable.
• Food must satisfy dietary needs, taking into account the individual’s age, living conditions, health, occupation etc.
• Food should be safe for human consumption.
• Food should be available from natural resources, either through the production of food by cultivating land or animal husbandry, or through other ways of obtaining food (such as fishing, hunting, or gathering).
• Food should be available for sale in markets and shops.
• Food should be available for future generations through sustainable production, considering factors such as the impact of possible climate change.

Accessibility:

• Food should be physically accessible for all, including individuals who live in very rural areas; and individuals who are physically vulnerable (such as children, people with ill health, disabled people, or older people).
• Food should be economically accessible for all. Everyone should be able to afford food for an adequate diet without compromising on any other basic needs such as heating or housing.
• The accessibility of food should be sustainable for present and future generations.

Human rights are woven into the national Plan and are an important component of the Good Food Nation Outcomes in particular. As we are making progress to embed the national Good Food Nation Outcomes into policymaking, we would expect that progress towards the realisation of human rights, in particular the human right to food, will be made.

Evidence

We identified the following relevant evidence and for the purposes of this EQIA we have organised it by protected characteristics. The evidence highlights that, where data is available, some groups experience worse outcomes in relation to healthy weight, healthy diets, diet-related health conditions and food insecurity compared to the general population. The evidence areas considered are of particular relevance for national Good Food Nation Outcomes 1 and 3. If Outcomes 1 and 3 are achieved, then inequalities in the topic areas mentioned above (healthy weight, healthy diets, diet-related health conditions and food insecurity) are likely to be reduced. We will continue to monitor how inequalities in these areas develop, as our work on Good Food Nation progresses.

1. Age

Healthy weight

• In 2023, those aged 16-24 had a significantly lower prevalence of overweight and obesity, with 38% prevalence of overweight (including obesity) and 21% prevalence of obesity (including morbid obesity). By comparison, overweight and obesity were most prevalent among those aged 55-64 (77% and 40% respectively).^[1]
• In 2023, mean BMI was 28.0 kg/m2. It was lowest for those aged 16-24 at 25.5 kg/m2 and increased across the age groups until age 55-64 (29.2 kg/m2), before decreasing slightly to 27.7 kg/m2 among those aged 75+.^[2]
• In 2023, no significant variation was recorded by age or sex in the proportion of children in the healthy weight range. In 2023, females were more likely to record a BMI within the healthy range than males (70% and 66% respectively), but this difference was not significant.^[3]

Healthy diet

• In 2021, younger adults, and young men in particular, were less likely than others to consume the recommended five portions of fruit and vegetables per day. Of adults aged 16-24, 13% met the Scottish Dietary Goal, including 9% of men and 17% of women. This proportion was highest for those aged 65-74, where 29% consumed their five-a-day (28% of men and 29% of women). (Diet data for adults was last collected in 2021).^[4]
• In 2021, mean consumption followed this same pattern, with the lowest number of fruit and vegetables on average for those aged 16-24 (2.8 portions), and the highest for those aged 65-74 (3.9 portions). (Diet data for adults was last collected in 2021).^[5]
• In 2023, 18% of all children consumed 5 portions or more of fruit and vegetables. For 2-7-year-olds this figure was 22%, and for 8-15-year-olds this figure was 15%. Of all children, most consumed either 1 portion or more but less than 2, or 2 portions or more but less than 3 (both 20%). Among 2-7-year-olds, most consumed 5 portions or more (22%), and among 8-15-year-olds, most consumed 1 portion or more but less than 2 (22%).^[6]
• Best Start Foods, which provides financial support for low-income families to access nutritious food at the point of need, was evaluated in 2022. In the evaluation, healthcare professionals raised concerns that the range of food recipients could purchase using the Best Start Foods card was restrictive and did not reflect the eating habits and cooking skills of their clients. There was a view that young recipients in particular do not have the skills or confidence to cook healthy meals from scratch, so they opt for pre-made baby food or meals.^[7]
• A Dietary Intake in Scotland’s Children (DISH) research report identified that young people aged 11-15 years tended to have less healthy diets than children aged 2-10. The report also identified that children and young people living in the most deprived areas of Scotland generally had less healthy diets than those living in the least deprived areas, with lower intakes of fibre, fruit and vegetables.^[8]
• Furthermore, the report identified that the Scottish Dietary Goal for fibre, oily fish, saturated fat and free sugars was not being met by the majority of children. An area for improvement identified was school meals – a low percentage of young people reported eating off school grounds every day.^[9]

Malnutrition in older adults

• Food Train’s ‘Eat Well Age Well’ initiative aims to support the prevention, detection, and treatment of malnutrition among older people living at home in Scotland. A report was produced on the data they have collected on malnutrition risk prevalence in Scottish communities.^[10] The report referenced the British Association for Parenteral and Enteral Nutrition’s (BAPEN) estimate that 1 in 10 people aged over 65 living in the community are at risk of or are malnourished, however the project’s data has consistently shown that the risk prevalence is higher than this.
• The project indicates that significant factors causing this high prevalence of malnutrition in older adults in Scotland include poor health, loneliness and financial difficulties.^[11]
• A joint research project between Eat Well Age Well and the University of Glasgow identified issues affecting food access and nutrition for older adults:^[12]
  • Wellbeing, motivation and control
  • Social networks and social eating
  • Stigma, changing society and loss of high street
  • Support losses
  • Cuts to statutory services
  • Maintaining meaningful social contact via food support
  • Supporting independent home-living

Food insecurity

• In 2023, of all adults aged 16 and over, 14% worried they would run out of food; 11% ate less; and 6% ran out of food.^[13] For different age groups, these proportions were as follows:
• 16-44: 20% worried they would run out of food; 15% ate less; 8% ran out of food.
• 45-64: 13% worried they would run out of food; 10% ate less; 5% ran out of food.
• 65+: 5% worried they would run out of food; 4% ate less; 2% ran out of food.
• Citizens Advice Scotland carried out a Food Insecurity Pilot in 2023 to provide short term crisis support alongside holistic advice. Clients could access the pilot through Citizens Advice Bureau (CAB) identifying them as being in need of crisis food support, through presenting to the CAB as being in need of crisis food support, or when referred as such by a partner agency.^[14]
• The pilot supported a higher proportion of clients in the 25-44 categories than the Network average, and fewer clients in the 65+ category. Reasons for greater representation in the 25-44 demographic could include word of mouth of the support being shared via social media, as well as being more open to seeking or receiving support. For clients in the 65+ category, CAB noted these clients often face barriers to accepting support, such as not wanting to be perceived as receiving charity or believing that others need help more.^[15]
• ‘The Rights Detectives’ formed a Lived Experience Board to help inform the Scottish Government’s new Human Rights Bill for Scotland. The Rights Detectives are a group of children and young people aged 11-17 from across Scotland. The group identified the following themes around the right to food:^[16]
• Poverty is one of the main barriers to children accessing their rights. Children are particularly affected during school holidays.
• The right to a healthy environment involves more sustainable food sources.
• Many advocated for people growing their own food and rearing their own cows and chickens.
• There was a call for more farmers markets rather than processed food
• Concerns were expressed around high food prices.
• The idea of providing food packages for older people who struggle with cooking was raised.

Food in schools

• In 2021, researchers from Glasgow Caledonian University administered an online survey to find out what secondary school pupils in Scotland thought about school meals. Pupils raised issues including:^[17]
• Length of time it takes to queue for food.
• Length of lunch break is too short.
• Only one third of pupils think school meals have become ‘healthier’ through time.
• Lack of information about school meals.
• Not all pupils who are entitled to a free school meal are taking it – the most common reasons for not are not liking the food and preferring other food.
• Most pupils were not aware of the Healthy Eating in Schools regulations.
• In 2018, the Children’s Parliament facilitated discussions with children and young people to explore their views on the food and drinks provided in school, and produced a report detailing recommendations made by the children and young people. These included introducing healthier foods into school meals (such as substituting white bread, pastas and rice for wholewheat), introducing more variety to meal options, and encouraging locally sourced food.^[18]

Workforce

• Engagement carried out by the Scottish Government with communities across the country highlighted themes around younger age groups in rural-based industries:^[19]
• A gap in apprenticeships and learning for young people in rural based industries.
• Barriers with access to land and housing (particularly for agriculture and crofting) for young people.

2. Disability

Healthy weight

• In 2023, 40% of adults with a limiting long-term condition in Scotland were living with obesity, compared to 31% of those with a non-limiting condition, and 26% of those without a condition.^[20]

Healthy diet

• In 2021, fewer adults in Scotland with a limiting long-term condition (19%) ate 5 or more portions of fruit and vegetables a day than those with no condition (23%).^[21]

Diet-related health conditions

• In 2023, 22% of people with a limiting long-term condition had a cardiovascular condition, compared with 9% with no long-term condition. Similarly, 9% of people with a limiting long-term condition had doctor-diagnosed diabetes, compared with 3% with no long-term condition.^[22]

Food insecurity

• UK level Family Resources Survey data from 2023 show that households with one or more disabled adult are less likely to be food secure (7% low, 9% very low) than households with no disabled adults (4% low; 3% very low). Households with one or more disabled adult were also more likely to have used a foodbank (3% within the last 30 days; 6% within the last 12 months), compared with households without disabled adults (1% within the last 30 days; 2% within 12 last months).^[23]
• Scottish Government analysis of the Family Resources Survey (FRS) provides three-year averages for food security data in Scotland for 2021-24. Looking at household food security by disability, of the households with no disabled person(s), 91% have high, 5% have marginal, 2% have low and 2% have very low food security. Of the households with disabled person(s), 77% have high, 7% have marginal, 7% have low, and 9% have very low food security. Shared households such as a group of students or other unrelated adults were excluded from the analysis.^[24]
• Citizens Advice Scotland ran a Shopping Card Pilot, where shopping cards were provided to those needing emergency food aid. The purpose was to explore options for reducing food insecurity.
• The study identified that over 40% of advice on benefits issued to clients was concerning disability.^[25]
• A similar pilot was carried out by Citizens Advice Scotland called the Food Insecurity Pilot. This delivered short-term crisis support alongside holistic advice. Shopping cards and cash grants were issued to those experiencing severe hardship, along with the offer of holistic advice.
• Over two thirds of the clients supported by the pilot reported having a health condition or a disability, which demonstrates the substantial need for crisis support within this client group.^[26]
• Furthermore, the highest proportion of pilot clients were unable to work due to a health condition or disability, or were unemployed.^[27]
• Health conditions and limited mobility were reported as a common barrier for travelling to a supermarket or carrying the shopping. Mental health issues can also be a barrier for getting to a shop.^[28]
• A lived experience board set up by the Human Rights Consortium Scotland shared that the cost-of-living crisis impacts many disabled people disproportionately. Also, people on specialised diets have higher food bills and can rarely take advantage of food discounts.^[29]

Health benefits from gardening

· Participants in research carried out by the Scottish Government believe there are huge mental and physical health benefits from gardening or simply having access to land.^[30]

3. Sex

Healthy weight

• In 2023, the mean Body Mass Index (BMI) for adults was 28.0kg/m², with no significant difference by sex.^[31]
• In 2023, female children were more likely to record a BMI within the healthy range than males (70% and 66% respectively), but this difference was not significant.^[32]

Healthy diet

• In 2021, similar proportions of males and females consumed five portions of fruit and vegetables per day:
• In 2021, just over one-in-five adults (22% of men and 23% of women) consumed the recommended five or more portions of fruit and vegetables per day, the same as in 2019.
• In 2023, 17% of male children and 19% of female children met the recommended five or more portions of fruit and vegetables per day.^[33]

Diet-related health conditions

• In 2023, 16% of males reported any cardiovascular disease compared with 15% of females.
• In 2023, prevalence of diabetes was 7% for males and 6% for females.

Gender pay gap

• The gender pay gap in 2024 for the manufacture of food products was 14.5%.^[34] This compared to a gender pay gap of 9.7% in all manufacturing and 2.2% in all industries and services.

Food insecurity

• Scottish Government analysis of the Family Resources Survey (FRS) provides three-year averages for food security data in Scotland for 2021-24. Of any households with a male as household head, 87% have high, 5% have marginal, 4% have low and 4% have very low food security. Of households with a female head of household, 81% have high, 7% have marginal, 5% have low and 7% have very low food security. This analysis excludes shared households such as a group of students or other unrelated adults.^[35]
• Scottish Government analysis of the 2021-24 FRS data also looks at single adult households. For both female and male pensioners, 93% have high and 4% have marginal food security. For both groups 2% have low and 2% have very low food security. Among working age males with no dependent children, 69% have high, 7% have marginal, 9% have low, and 15% have very low food security. Among working age females with no dependent children, 68% have high, 9% have marginal, 9% have low, and 15% have very low food security. There is not enough data available for working age males with dependent children, but among working age females with dependent children, 58% have high, 12% have marginal, 13% have low and 18% have very low food security.^[36]
• Scottish Health Survey also provides data on food security. In 2023, 12% of males reported being worried they would run out of food; 9% ate less; and 5% ran out of food. Of females, 16% reported they were worried they would run out of food; 12% ate less; and 6% ran out of food.^[37]
• The Five Family Payments evaluation highlighted concerns around the implications of making an application for the Five Family Payments (social security benefits aimed at reducing child poverty) as a particular barrier for survivors of abuse who might fear that sharing their personal details could put them at risk of harm. The report noted that these clients are mainly women.^[38]

Workforce

• Members of the farming community report barriers for women in agriculture. For example, provision of childcare is a barrier for many people in rural areas.^[39]

4. Pregnancy and maternity

Breastfeeding

• According to Infant Feeding Statistics 2023/24, more than two thirds (68%) of babies reviewed in Scotland in 2023/24 were breastfed for at least some time after their birth.^[40]
• In 2023/24, of babies reviewed at 6-8 weeks, 33% were exclusively breastfed, 16% mixed breast and formula fed and 51% formula fed.
• Increases in breastfeeding over the past 10 years have been greatest among those groups with historically lower rates, such as younger women and those living in more deprived areas. This means inequalities in breastfeeding have reduced over time.

Healthy weight and diet-related health conditions

• Although pregnant women from more deprived areas were more likely to be obese, maintaining a healthy weight in pregnancy is an issue across all areas of Scotland – in 2023/24 20% of women from the least deprived areas were obese at antenatal booking while the figure was 32% for those from the most deprived areas.^[41]
• In 2023/24, over a quarter and nearly a tenth of maternities were affected by obesity and diabetes respectively.
• Almost a quarter of maternities in 2023/24 were to women living in the most deprived areas. Deprivation impacts the health of pregnant women and babies across Scotland with women from more deprived areas being more likely to be obese, have diabetes, to give birth prematurely and to have babies small for their gestation compared to those from less deprived areas.

5. Gender reassignment

Food insecurity

• The Health Needs Assessment (HNA) commissioned by NHS Greater Glasgow and Clyde and NHS Lothian (and from 2020 onwards Public Health Scotland) included a national online survey (conducted in 2021) with 2,358 LGBT+ respondents.^[42]
• More than one in six (18%) LGBT+ respondents said that during the last 12 months there was a time when they were worried they would run out of food because of a lack of money or other resources. The prevalence of food insecurity was highest among trans masculine (30%) and non-binary (27%) respondents. The figure was 19% for trans women.

6. Sexual orientation

Food insecurity

• The Health Needs Assessment (HNA) commissioned by NHS Greater Glasgow and Clyde, and NHS Lothian (and from 2020 onwards Public Health Scotland) included a national online survey (conducted in 2021) with 2,358 LGBT+ respondents.^[43]
• In the HNA, more than one in six (18%) LGBT+ respondents said that during the last 12 months there was a time when they were worried they would run out of food because of a lack of money or other resources.
• Overall, the HNA reported 20% of LGBT+ people aged under 50 experiencing food insecurity in the last 12 months.
• Of the HNA respondents, 13% of gay/lesbian women; 19% of bisexual women; 13% of gay men; and 13% of bisexual men reported experiencing food insecurity in the last 12 months.
• Scottish Government analysis of the Family Resources Survey (FRS) provides three-year averages for food security data in Scotland for 2021-24.^[44]
• Looking at household food security by sexual orientation, among heterosexual/straight households 86% have high, 5% have marginal, 4% have low and 5% have very low food security. Among other households (this category includes ‘Gay/lesbian’, ‘Bisexual’ and ‘Other’), 76% have high, 6% have marginal, 7% have low, and 11% have very low food security. Shared households such as a group of students or other unrelated adults were excluded from the analysis. Many respondents (1,070,000 out of 3,720,000) did not report their sexual orientation.

7. Race

Healthy weight and health conditions

• A recent Scottish Government scoping review (November 2022) reveals that high quality evidence on the intersection of ethnicity and diet, and ethnicity and healthy weight in Scotland remains limited.^[45]
• There is evidence that specific ethnic groups have approximately 3 to 5 times higher rates in Type 2 diabetes than non-minority groups.^[46] Type 2 diabetes is caused by a complex range of biological, socio-economic and lifestyle factors.
• The latest data available on healthy weight in minority ethnic groups compared to non-minority groups in Scotland dates to 2012. This dataset reveals that the highest prevalence of obesity was among African, Caribbean or Black respondents (35%) but this was not significantly different from the average (27%).^[47]
• The Scottish Health Survey results show no significant difference between White British and Asian Indian and Pakistani ethnic groups. This may be down to small sample sizes, however.^[48]
• Chinese and respondents who identified as ‘Asian Other’ had the lowest prevalence of overweight (41% and 45% respectively) and obesity (4% and 9% respectively), and this was significantly lower than the national average.^[49]
• UK wide data^[50] is more recent and reveals that:
• In the year to November 2022, 63.8% of adults aged 18 and over were overweight or living with obesity – up by 0.5% from the previous year.
• 70.8% of black adults were overweight or living with obesity – the highest percentage out of all ethnic groups.
• 33.1% of adults from the Chinese ethnic group were overweight or living with obesity – the lowest percentage.

Healthy Diet

• From 2008 to 2011, ‘White British’ respondents were found to be the least likely to eat 5 portions of fruit or vegetables a-day (21%). ‘White Other’ (40%), ‘Pakistani’ (48%), ‘Chinese’ (49%), ‘Asian Other’ (51%) all reported higher levels of consumption for 5 or more portions of fruit or vegetables per day than the national average (22%).^[51]
• More recent statistics were not identified.

Food insecurity

• Scottish Government analysis of the Family Resources Survey (FRS) provides three-year averages for food security data in Scotland for 2021-24. Looking at household food security by ethnicity, of the ‘White – British’ category, 85% have high, 6% have marginal, 4% have low and 6% have very low food security.^[52]
• For the ‘White – Other’ category, these proportions are 86% (high), 4% (marginal), 7% (low), and 3% (very low) respectively.
• For ‘Mixed, Black or Black British, and Other’, the proportions are 69% (high), 18% (marginal), and 6% (low) – data for very low food security is not available due to sample sizes.
• For ‘Asian or Asian British’ category, the proportions are 87% (high), 7% (marginal), 5% (low) and 2% (very low). Shared households such as a group of students or other unrelated adults were excluded from the analysis.
• Citizens Advice Scotland’s Food Insecurity Pilot report [as described above] noted that Citizens Advice Bureau staff suggested there are barriers to food insecurity support for minority ethnic clients, especially those with immigration status issues, who might not be aware they are eligible for support.^[53]
• An evaluation of the Five Family Payments [as described above] suggested that having limited English can be a barrier to claiming this support.^[54]
• A Lived Experience Board arranged by the Human Rights Consortium Scotland raised the following points:
• Institutional racism can result in people not being able to access education, medical care and food.^[55]
• The right to food should be realised for all, without asking for asylum status or certain paperwork.^[56]
• Some people from asylum seeker background who have been going to food banks felt like they’ve been interrogated when it comes to registration.^[57]
• Nourish Scotland ran an ‘Our Right to Food’ project with Pakistani households in Scotland. The group created a fictional Pakistani family and worked through their typical food routines. They raised the following conclusions:^[58]
• The Eatwell Plate does not represent meal choices in the family. Shopping patterns such as bulk buying, buying items such as okra and eating patterns such as a big family style service make it difficult to use the Eatwell Plate as a reference for health.
• Trying to promote a plate that doesn’t feel relevant to many households in Scotland will not work to improve Scotland’s diet.
• The family shopping basket had a higher environmental impact than the current average diet in Scotland. The main contributor was lamb. Lamb is a culturally valued part of the weekly shopping basket.
• Another issue was the ‘buy local’ advice. Mangoes were a non-negotiable when in season and dates were needed to break the fast during Ramadan. Guavas and lychees were also important items. These flown-in fruits were part of a typical week for this family. Sustainability advice is not going to stop the purchasing of these flown-in fruits.
• Paying attention to these dietary preferences is important when thinking about reducing the environmental impact of Scotland’s diets.
• It’s not possible to understand the right to food in Scotland without understanding what a culturally valued diet looks like for Pakistani households.

8. Religion or belief

Healthy Diet

• Between 2008 and 2011, Buddhists (63%), Muslims (49%) and Hindus (44%) were most likely to meet the 5-a-day recommendation and consumed the highest mean daily portions of fruit and vegetables (6.8, 5.1 and 4.5 portions respectively), significantly greater than the national average (22% and 3.2 portions).^[59]

Food insecurity

• Scottish Government analysis of the Family Resources Survey (FRS) provides three-year averages for food security data in Scotland for 2021-24. Looking at household food security by religion, the proportions are as follows:^[60]
• No religion: 85% high, 5% marginal, 4% low, 6% very low food security.
• Church of Scotland: 90% high, 4% marginal, 3% low, 3% very low food security.
• Roman Catholic: 82% high, 8% marginal, 5% low, 5% very low food security.
• Other Christian: 87% high, 6% marginal, 4% low, 3% very low food security.
• Other religion: 75% high, 10% marginal, 8% low, 7% very low food security.
• Muslim: 73% high, 5% very low food security. No data available for marginal and low food security due to sample sizes.

Public Sector Equality Duty Needs

We expect that the progressive realisation of the national Good Food Nation Outcomes will have a positive impact over time in relation to advancing equality of opportunity between people who share a protected characteristic and those who don’t. Many equality groups currently experience worse outcomes than the general population in relation to food insecurity, access to a healthy diet and healthy weight. If the Outcomes were achieved, this would narrow the gap in inequalities, thereby having a positive impact.

There is also potential for the ‘Inequalities in the food system’ section within the national Plan to have a positive impact here. This section is intended to encourage policymakers to consider inequalities in the food system, work with other policy areas, access evidence and engage with those who have lived experience when developing new policy. This encourages thinking broadly across different and overlapping inequalities and ensuring the voices of those with lived experience help inform new policies. This could also help promote good relations between people who share a protected characteristic and those who don’t.

In relation to eliminating unlawful discrimination, harassment and victimisation, we expect that the Plan will either have no impact or no negative impacts.

Have positive or negative impacts been identified for any of the equality groups?

Yes, we have identified potential positive impacts for the following equality groups:

• Age
• Disability
• Sex
• Pregnancy and maternity
• Race
• Religion or belief

We have not identified any negative impacts.

Is the policy directly or indirectly discriminatory under the Equality Act 2010?

No

If the policy is indirectly discriminatory, how is it justified under the relevant legislation?

N/A

If not justified, what mitigating action will be undertaken?

N/A