Proposed national Good Food Nation Plan consultation: statement

Part B: Summary of Responses to the Consultation and how regard was had to these responses

27. The following summarises the actions taken in response to the responses received during the consultation. There is a focus on the public consultation activities but the actions taken were also informed by the wider consultation that took place throughout the development of the Plan. A summary of the consultation responses and key themes identified across the Citizen Space consultation, the in-person and online workshops and the contributions from children and young people is provided below. In addition, a detailed analysis of public consultation responses is available online.

28. By and large, responses raised in the stakeholder workshops and by children and young people and teachers tended to cover the same issues as those raised in responses to the consultation.

Summary of number of responses to the public consultation

29. The information below is taken from the consultation analysis report, to avoid repetition the information on the number of responses received to the various parts of the consultation is summarised as follows:

• 452 responses to the consultation (received either via Citizen Space or paper copies of the respondent information form),
• 400 people attended the workshops
• Around 250 individuals attended the in-person workshops. These were held in Edinburgh (36 attended), Alloa (20), Glasgow (40), Dundee (36), Dumfries (19), Galashiels (14), Oban (24), Peterhead (19), Orkney (20) and South Uist (20).
• Around 150 individuals attended the online workshops
• The information stalls engaged with over 450 people, based on the number of flyers distributed.
• 883 questionnaires were received from children and young people aged 13+.
• 202 questionnaires were received from teachers who responded on behalf of children aged under 13.

Respondent profile

30. A copy of the respondent profile table from the consultation analysis report is provided below:

Respondent profile (consultation)

Respondent type	Number
Total organisations	171
Community Group	27
Education / Academic / Research	7
Food / food retail / producer / distributor	13
Health Board	8
Other Health	11
Local authority	22
Public sector	7
Third sector	32
Trade association / representative body	36
Other	8
Individuals	281
Total	452

Summary of Responses

31. A number of key themes were evident across responses to the consultation questions, stakeholder events and schools, as well as across respondent groups. Across consultation responses, local authorities and health boards tended to be most positive about the draft national Good Food Nation Plan. Organisations within the third sector, trade associations/representative bodies and those in the public sector tended to be least positive. However, some of the bases for these groups were small, so any quantitative findings need to be considered with a degree of caution. Additionally, when considering group differences, it should be recognised that where a specific opinion has been identified in relation to a particular group or groups, this does not indicate that other groups did not share this opinion, but rather that they simply did not comment on that particular point. While the consultation gave all who wished to comment an opportunity to do so, given the self-selecting nature of this type of exercise, any figures quoted here cannot be extrapolated to a wider population outwith the respondent sample.

32. To a large extent, comments made by respondents across all elements of the stakeholder engagement echoed many of the points raised in the draft national Good Food Nation Plan. While many respondents provided considered opinions on the questions they were asked, some of the responses also focused on how the draft national Plan could be implemented. The following provides a summary of the responses to the public consultation. These have been grouped by key themes.

a) Across all respondents, views were generally positive about the draft national Good Food Nation Plan and its constituent elements. That said, many respondents also felt the draft national Plan as it stands is too general in nature and rather vague, with a focus on existing policies rather than new policies and initiatives. There were a significant number of concerns as to how Outcomes, targets and indicators will be measured, monitored and evidenced. There were requests for detail to be provided on pathways, measures and timeframes.

b) There were a number of requests for more information regarding how Outcomes, targets and indicators will be achieved. Some respondents pointed to a need for baseline data against which progress can be measured and monitored. It was felt that the indicators need to provide a clear path to achieving the Outcomes.

c) A key concern from many respondents related to the funding and resources that would be needed to implement the draft national Good Food Nation Plan. There were calls for additional funding and resources from all respondent sub-groups, including local authorities and health boards, who will be required to develop local Good Food Nation Plans.

d) Allied to the issue of increased resources and funding, a number of respondents pointed out the need for local authorities and health boards to develop Plans in conjunction with each other so as to have consistency across all Good Food Nation Plans.

e) There were many queries as to how the draft national Good Food Nation Plan would link into other strategies and policies, along with comments on the need to ensure that the national and local Good Food Nation Plans are fully aligned with other policy areas.

f) Collaboration across the full range of stakeholders was seen as important, given comments that the draft national Plan is ambitious and needs a collective response across a wide range of organisations, including public sector and non-public sector. It was felt that collaboration would help to achieve buy-in to the draft national Plan. Engagement by the Scottish Government was seen as central, alongside support through resources and finance. Community participation was also considered to be important in achieving the Good Food Nation ambition.

g) While there was support for the concept of a ‘right to food’ for all people, a number of concerns were highlighted over how to achieve equitable access across Scotland. As such, there were a number of comments on the need for all people to have access to good quality, nutritious food which is affordable. Many respondents noted that some people in Scotland cannot afford high quality food, and that ultra-processed foods and/or foods high in fat, salt and sugar are often much cheaper options and more readily available.

h) Many respondents wanted to see increased availability of local foods, albeit they felt this would only be achieved with improved local supply chains.

i) The role of public procurement was seen as an important enabler for local food supply chains. However, many respondents identified a need for changes to procurement practices. It was felt that at present constrained budgets and a lack of flexibility in procurement practices are key barriers to the procurement of local produce. There were therefore calls for more flexibility in procurement approaches; e.g., to allow for support for local suppliers.

j) A significant number of respondents focused on the need for better education, training and skills so that all people can have an understanding about good food. While some of these respondents focused on education from early years throughout the curriculum, others also noted that education should be lifelong. Overall, respondents wanted to see everyone having access to education on growing, preparing and cooking food as an essential life skill. That said, while education is seen to be important, the determinants of food choices also include affordability and access to food.

k) A number of respondents also focused on the need to ensure that people working in the food and drink sector are well trained. This would ensure the necessary skills are developed and that all have a good understanding about good food.

l) A number of respondents pointed out the need for enough people with the right skills to be employed in the food and drink sector to support the future of the sector. For example, some respondents pointed out that the number of Environmental Health Officers has declined in recent years. Furthermore, some respondents saw the food and drink sector as having a poor image in terms of pay and working standards. This would need to be addressed in order to attract more skilled workers to the sector.

m) The need for changes to diet were suggested by a number of respondents, with references to a need to transition to a more sustainable plant-based diet. There were also some references to the need for more organic food to be available. Linked to the issue of diet, some respondents also focused on the need for high animal welfare standards and the need for changes to farming and fishing techniques.

n) While a significant number of respondents focused on the availability of local food and supply chains, there were also some references to the need to take a global view and collaborate internationally as Scotland is currently, and likely to remain, reliant on some imports and unlikely to become self-sufficient.

o) Finally, there were calls for clear definitions to be provided so that all people have a clear understanding of the draft national Good Food Nation Plan. Some respondents felt that the language used assumes a level of knowledge about food that might not exist.

Changes made as a result of responses to the consultation

33. The text below aims to set out the main changes that have been made to the Plan based on the consultation responses. These are based on the key themes raised.

Changes to Outcomes

34. There were many responses that suggested changes to the Outcomes (see Annex 3 of the consultation analysis report). The responses ranged from general comments to very specific suggestions for changes. The suggestions were wide ranging, sometimes contradictory and variable in terms of specificity and length. To redraft the Outcomes the key points and themes have been identified and considered and the changes made are as set out below.

Outcome 1

Text from consultation draft:

• Outcome 1: Everyone in Scotland eats well with reliable access to safe, nutritious, affordable, sustainable, and age and culturally appropriate food.

Amended text from proposed Plan:

• 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.

35. The comments in consultation responses suggested that Outcome 1 did not have sufficient focus on the importance of reducing the prevalence of unhealthy foods in the food environment. An added initial sentence seeks to address this point by highlighting the role of the food environment.

36. Other consultation responses requested that this Outcome should have more focus on the importance of dignity in access: we have added the word “dignified” to address this point.

37. A number of consultation responses felt that the Outcomes did not place enough emphasis on the joy that food can bring, and so we have added a reference to enjoyment here.

38. While culturally appropriate is no longer directly mentioned in the Outcome wording it is our intention that Outcome 1 supports the access to culturally appropriate food. This is signalled by the inclusion of the words “everyone” and “reliable and dignified access”.

39. We have made it clear that people should expect to be able to enjoy access to good food in all circumstances, e.g. in situations where they may have limited choice of food such as in hospitals or prisons.

40. A small minority of comments expressed doubts that everyone can eat well due to affordability concerns; we have addressed this by emphasising elsewhere in the Plan that Outcomes are long-term and aspirational, not a reflection of the current situation.

Outcome 2

Text from consultation draft:

• Outcome 2: Scotland’s food system is sustainable^[4] and contributes to a flourishing natural environment. It supports our net zero ambitions, and plays an important role in maintaining and improving animal welfare and in restoring and regenerating biodiversity.

Amended text from proposed Plan:

• Outcome 2: Scotland’s food system is sustainable and contributes to a flourishing natural environment on our land and in our waters. It supports our net zero and climate adaptation ambitions and plays an important role in maintaining and improving animal health and welfare, and in restoring and regenerating biodiversity.

41. In relation to this Outcome, a number of consultation respondents queried the use of the wording around “maintaining” animal welfare, feeling that it was not sufficiently ambitious as the aim should be to improve as much as possible. We gave careful consideration to removing the word “maintaining” from this Outcome. However, this wording aligns with that used in the Agricultural Reform Programme and so for consistency it has been kept. The scope of this Outcome has also been extended to cover animal health as well as welfare.

42. A number of consultation respondents noted that the Outcomes as a whole did not contain sufficient focus on the marine environment; we have amended this Outcome to ensure that the importance of the marine environment is given equal consideration with the land environment by adding “on our land and in our waters” to the first sentence.

43. The words “and climate adaptation ambitions” were added based on input from policy officials that food security and supporting the farming industry play an important role in the Scottish National Adaptation Plan 2024-2029 (“the Adaption Plan”). Adding this wording creates a link between the Good Food Nation Plan and the Adaptation Plan.

44. There were a number of suggestions about including specific policies within this Outcome, e.g. on organic food. We have not done this, as the Outcome is not the appropriate place for individual policies.

Outcome 3

Text from consultation draft:

• Outcome 3: Scotland’s food system encourages a physically and mentally healthy population, leading to a reduction in diet-related conditions.

Amended text from proposed plan:

• 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.

45. The largest number of comments on this Outcome were in relation to the importance of improving the general food environment and creating a situation where healthy foods are the easier choice. We have reflected this by specifically referencing the food environment in the Outcome.

46. Several respondents suggested that the word “encourages” be replaced with “enables” as this was viewed as more positive and pro-active. The word “promotes” has also been added to strengthen the Outcome.

47. There was a desire from some respondents to specifically mention the prevention of poor health outcomes, and so we have added a reference to this point.

48. There were calls for the addition of various specific policies, e.g. taxing or banning certain foods. We have not made reference to these in the Outcome as such a detailed level of action is beyond the intended scope of the Outcome.

Outcome 4

Text from consultation draft:

• Outcome 4: Our food and drink sector is prosperous, diverse, innovative, and vital to national and local economic and social wellbeing. It is key to making Scotland food secure and food resilient, and creates and sustains jobs and businesses underpinned by fair work standards.

Amended text from proposed plan:

• Outcome 4: Our food and drink sector is prosperous, diverse, innovative, and vital to national and local economic and social well-being. It is key to making Scotland food secure and food resilient, and creates and sustains jobs and businesses underpinned by fair work standards throughout food supply chains.

49. A number of suggestions and comments on this Outcome sought more emphasis on fairness throughout the whole supply chain; we have added the additional wording “throughout food supply chains” to clarify this.

50. A significant minority of respondents sought a far greater emphasis on producers and in particular on farmers in this Outcome. However, the Outcome is intended to be as broad as possible to capture the full extent of the food and drink sector, not only primary production. We have therefore not altered the emphasis here.

51. Some concerns were raised about the potential for the Outcomes to have contradictory aims e.g. a focus on growing the food and drink sector and also on meeting climate change targets. Our view is that one of the main aims of having such wide-ranging Outcomes is to bring a focus to these contradictions so that food policy is not developed in isolation but rather as a broader discussion that ensures a food systems approach is taken. There will always be contradictions and sensitivities and embedding this approach will ensure that food policy is taken account of as a whole rather than in isolation.

52. As with the other Outcomes we have avoided adding references to specific targets, policies and indicators, as these are set out elsewhere in the Plan.

Outcome 5

Text from consultation draft:

• Outcome 5: Scotland has a thriving food culture with a population who are interested in and educated about good and sustainable food.

Amended text from proposed plan:

• Outcome 5: People and communities are empowered to participate in, and shape, their food system. Scotland has a thriving food culture with a population who are educated about good and sustainable food.

53. Comments on the Outcomes as a whole sought a greater emphasis on the role for communities in achieving a Good Food Nation. We have reflected that in the re-wording of this Outcome.

54. As with the other Outcomes, we have avoided adding references to specific targets, policies and indicators. We also note that some respondents expressed concern about a focus on education, stating that it is an insufficient driver of behavioural change. However, the Outcomes should be viewed as a whole, and whilst there is overlap between them, each individual Outcome need not and cannot cover every element of a Good Food Nation.

Outcome 6

Text from consultation draft:

• Outcome 6: Scotland has a global reputation for high-quality food that we want to continue to grow. Decisions we make in Scotland contribute positively to local and global food systems transformation. We share and learn from best practice internationally.

Amended text from proposed plan:

• Outcome 6: Decisions we make in Scotland contribute positively to local and global food systems transformation. Scotland actively engages in learning and exchanging knowledge and best practice internationally.

55. A significant number of respondents considered that the focus on global reputation was unnecessary. We have reworded the Outcome to remove this, and to emphasise that Scotland should take a proactive approach to exchanging knowledge and best practice internationally.

56. Some respondents commented on Outcome 2 outlining concerns about the risks of exporting Scotland’s environmental footprint, and noting the importance of taking a global view of the food system. We believe Outcome 6 adequately addresses this point already and accordingly no changes were needed in that respect.

57. Some respondents felt that Outcome 6 should be replaced with a wider governance Outcome. We have instead reworked other elements of the Plan to ensure greater clarity about governance and working mechanisms for the Good Food Nation.

Changes to the Structure of the Plan

58. The biggest change to the Plan was in relation to the structure. This was for a variety of reasons and was informed by responses to the consultation, feedback from policy officials within the Scottish Government and the Ministerial Working Group on Food. The changes also reflected the need for the Plan to be able to be used in a way that facilitates the breaking down of silo working and moving towards a more joined up way of developing food policy.

59. Having a more coherent and collaborative approach to food policy is one of the main aims of the Act. Breaking down silo working and changing working practices to ensure this happens is one of the key asks of stakeholders and much of the change in format is to support that aim. It should be kept in mind that many of these changes relate to the way in which policy officials work within the Scottish Government and may not be immediately obvious to those outwith Government. Taking a food systems approach will not be possible unless there is a change in working practices to enable the long-term work of developing joined up food policy. This first generation of the national Good Food Nation Plan needs to support this change and, as set out below, requires a different approach to the traditional format of a Plan.

60. Set out below are the changes that have been made to the structure of the Plan and the reasons for doing so. As noted above these changes are all informed by the wide and extensive consultation around the development of the Plan.

Technical Note

61. To respond to feedback that the Plan might not be understandable to everyone we have restructured the Plan to make clearer what its purpose is.

62. We have added a technical note to the very beginning of the Plan, laying out the legislative requirements that apply to the drafting of the Plan. This has been added because it was apparent from the consultation responses that these requirements were not well understood, and therefore it was not always clear to respondents why the information included in the Plan was there. This note seeks to make it clear from the outset why the Plan has been drafted as it has.

63. A summary of the legislative requirements will ensure that when the Plan is being used to develop policy it is very clear that there is a need to have regard to the Plan when Scottish Ministers are carrying out functions specified in secondary legislation. This will support officials to know when they need to have regard to the Plan and help embed the requirement into policy development working practices.

64. There were requests for clear definitions to be included so we have developed a glossary where key concepts are defined.

Snapshot Boxes

65. The consultation draft of the Plan contained a series of “snapshot boxes” interspersed with the policy narratives. These boxes were to address the issue that some of the concepts within the Plan might seem abstract. To help make life in a Good Food Nation more tangible the consultation draft of the Plan contained a series of snapshots to illustrate what a Good Food Nation might look like in practice. We received a great deal of feedback from consultation respondents on the content of these boxes.

66. Although the snapshot approach worked well in the consultation draft, the boxes no longer fit comfortably in the revised structure of the Plan. Therefore, we have taken all the feedback on the snapshot boxes and used it to create a narrative about what people in Scotland want a Good Food Nation to look like. As before, the purpose of this is to provide a description of what a Good Food Nation would look like in the future.

67. This helps make sure the overall vision of Scotland as a Good Food Nation is embedded in the Plan and that the feedback of the people who contributed to the consultation is represented in that overarching ambition.

68. This narrative will also help guide policy officials and Scottish Ministers by setting out the bigger picture so that it does not get lost in the minutiae of policy development.

Working Mechanisms

69. Responses to the consultation indicated that some stakeholders wanted to see greater prominence in the Plan given to working mechanisms, and explanation of how the Good Food Nation approach will be embedded in government structures.

70. Some consultation respondents wished to add an Outcome specifically to address the question of governance and internal structures, suggesting that there is a need for greater transparency around how the Scottish Government is implementing the Good Food Nation approach in wider policymaking.

71. We carefully considered this option but have not included it. This is because the Outcomes are intended to be ambitious and stretching, presenting a vision for Scotland as a Good Food Nation, rather than technical. In addition, it would be extremely difficult to identify suitable and measurable indicators to attach to such an Outcome.

72. Instead, we have expanded Part Two of the Plan in order to emphasise the crucial importance we attach to putting in place structures and mechanisms that will embed the Good Food Nation approach throughout the policymaking process.

Baselining and Working Mechanisms

73. This is the first Good Food Nation Plan and the primary focus of the Scottish Government is to identify relevant policy areas, build a coherent picture and develop working mechanisms that will enable greater consistency across policy areas. We recognise that it would be helpful to set out pathways to achieve the Outcomes, as suggested by some consultation respondents, but we do not think this is possible for this first Plan. We intend to do this as we start working on the next iteration of the Plan.

74. To ensure that the Outcomes will be achieved in the future it is essential that we have tackle the challenging task of changing long established working practices and undertaking baselining work. We will do this by providing cross government support to ensure officials are enabled and supported with the correct knowledge and tools to start embedding this new approach to food policy into their work. This is integral work that will take time and needs to put in place right at the start of our journey towards becoming a Good Food Nation.

Indicators and Targets

75. We received many responses about the targets and indicators section of the Plan. The overall theme was that there were no new targets, that some existing targets were too vague, more baseline data was needed and there needed to be a timeline setting out dates to achieve targets by. There were also comments for the need for more quantitative targets generally and a need for information on how progress would be measured against the targets.

76. The responses also highlighted the targets, which are already in place as government policy ambitions, may be too aspirational or challenging to deliver and that there was a need for more information regarding the actions to achieve the targets. There were concerns about where support (e.g. funding) for the targets and Outcomes might come from noting that there are limited resources and budget to deliver against targets.

77. There were concerns raised that there was a need have a collaborative working approach and also to make links to other plans and strategies in order to progress targets.

78. Respondents to the public consultation provided detailed and specific comments in relation to the targets and indicators suggested for each Outcome. This information was supplemented by other more general suggestions throughout the responses for where targets might be needed (the consultation analysis report contains more detail). The following list provides a summary of some of the subject matters/areas in which consultation respondents wished to see targets:

• Discourage poor quality foods or a percentage reduction target to be set for the consumption of ultra-processed food in national dietary guidance.
• Removing or reducing over-processed food from schools, hospitals and food banks.
• Action in relation to producers and supermarkets selling unhealthy food, and against the prevalence of sugar, artificial sweeteners and additives.
• Improving the food environment, with views that unhealthy foods tend to be cheaper and more accessible. These included restricting fast-food outlets opening near schools, hospitals and community centres.
• Tackling restrictions on access to food for disabled people.
• Public procurement targets and it was noted that collaboration was needed to help ensure small and local food producers could contribute to public procurement.
• Targets around animal welfare and improved living conditions for fish, cattle, pigs and poultry. Links to the Five Domains Model of animal welfare or the recommendations of the Farm Animal Welfare Council in 2012 were suggested.
• Targets to reduce the consumption of meat and dairy products though this was balanced by others citing the importance of meat production and that Scotland’s land is most suitable for raising livestock, that meat is an important dietary component and that farmer’s livelihoods would be adversely affected.

79. The Scottish Government has taken on board the feedback about targets and acknowledges that there is a strong demand from respondents for the Plan to contain new targets. The Scottish Government recognises this but needs to balance this demand against the complex practicalities of developing new targets.

80. As noted in the consultation draft any development of new targets needs to consider the feasibility and affordability of meeting the targets and the costs of associated data collection. Consideration also needs to be given to the most efficient way of collecting data without creating a disproportionate bureaucratic burden. There is also a need to take account of the interactions between reserved and devolved powers and by international trade agreements.

81. Given the length of time it can take to undertake all the due process associated with developing targets it is not possible to include new targets in this iteration of the Plan. One of the main aims of the Plan is to encourage a food systems approach to the development of food policy (and any associated targets), and so developing new targets at this stage of the Good Food Nation journey i.e. before the internal working mechanisms are embedded runs the risk of maintaining a silo approach.

82. However, we fully support the need to have a transparent way of assessing progress against our Outcomes and have responded to this feedback by working with Scottish Government analysts to develop a new indicator framework to support the Good Food Nation Plan. This will consist of several high-level data-driven primary indicators, as well as signposts to relevant evidence that relate to each Outcome. These will be visualised on in supplementary analytical publication or dashboard that will be publicly accessible.

83. Our primary indicators are drawn from a range of sources but will mainly seek to draw upon existing official statistics produced elsewhere across the public sector that intersect with food policy and the Good Food Nation Outcomes (i.e. poverty, health, environmental and economic statistics) and may be used in other settings such as the National Performance Framework. These primary indicators will be presented alongside relevant supporting evidence drawn from wider consideration of existing research, identifying limitations where there are known evidence gaps to allow monitoring of some aspects of the Outcomes at this point in time.

84. The data series for indicators used on the dashboard is not always updated on a yearly basis which makes setting a common baseline year very difficult. We will use the year as a baseline that is closest to 2025 for each indicator, when reporting on progress.

85. Our intention is that the monitoring framework developed to support the Good Food Nation Plan will be made accessible to a wide audience and publicly available in a supplementary analytical publication or dashboard. We will seek to publish a document that will capture each primary indicator and present data graphically.

86. Alongside primary indicators we have also retained the set of targets included in the consultation draft. These are existing targets or a refinement of existing targets in place across a range of policy areas

87. The new set of indicators; the dashboard format; and the proposed availability online provides a more transparent and long term way of measuring progress that can be added to as more new data become available.

88. We are committed to regularly updating data indicators used in the Plan in line with the review and revision cycles to ensure future iterations are informed by relevant and up-to-date evidence.

Reduction in length of Policy Section

89. Section 1(3)(c) of the Act requires that the Plan include the policies which the Scottish Ministers intend to pursue in order to secure the achievement of the Outcomes. However, the Act is not prescriptive about the form this should take. In the consultation draft we included a longer section with narrative description of individual policy areas but did not ask specific consultation questions.

90. However, having taken account of consultation responses, input from across Government and further consideration of how the Plan will be used in practice by Ministers to meet the legislative duties set out in the Act, we have made changes to this section. A summary of the reasoning for doing so is set out below.

91. In the proposed Plan we have significantly reduced the length of this section. We have retained the same overall organisational structure, dividing the polices into categories based around key groups in the food system: People and Communities; Providers and Places; and Farmers, Food Producers and Processers.

92. Within these sections, we have retained and expanded on the bullet points providing key summaries of the policies. These are intended to set out what the overall policy is, and what action is being taken to achieve the policy aim. We have removed the narrative and descriptions of policies that was contained in the consultation draft and have instead provided tables which explicitly link each policy area to the Outcome(s) that it contributes towards. The table also contains links to documents relevant to the policy or broader policy area.

93. The policy section of the consultation draft was extremely lengthy, with a great deal of detail about individual policies. This made it quite unwieldy. It was time consuming to collate and, most importantly, any information included quickly becomes out of date, as happened even during the timescale of the consultation. Keeping in mind that the Good Food Nation Plan is expected to be reviewed on a basis of five years, a Plan with a detailed explanation of the current state of play of policy quickly becomes outdated and makes the task of having regard to the Plan when exercising specified functions more difficult from a practical standpoint.

94. Our main consideration when developing the new format was that the Scottish Ministers and officials will be required to have regard to the Plan when exercising functions specified in secondary legislation in accordance with section 6 of the Act^[5]. Therefore, it is important that the Plan is presented and formatted in a way which facilitates this process and is user friendly. This is a major change in the process of developing Government policy and it is therefore important the Plan functions as a document that can facilitate this process. Our changes mean this shorter policy section focuses on drawing explicit links between policy areas and the Outcomes. This supports the process on taking a food systems approach as such a format will make it simpler for Ministers, and by extension officials, to identify connections between their own policy areas and others which contribute to the same Outcomes.

95. Retaining the summaries of policies and the structure of organising policies according to groups in the food system, provides an overview for the general reader that allows them to understand the policies that the Scottish Government is pursuing, without an overwhelming amount of detail.

Response to Key Themes

Funding

96. Many respondents raised concerns about funding and resources in relation to the development and implementation of both the national and relevant authority Good Food Nation Plans.

97. Officials from the Good Food Nation Team have worked with COSLA throughout the process of taking the Bill through the Parliamentary process and once the Act came into force. These discussions remain underway to develop our understanding of the likely resource impact for local authorities and health boards.

98. Consideration will need to be given to budgetary constraints and the timing of the commencement of section 10. Once this provision has been commenced, relevant authorities will be required to publish their plans within a 12-month timeline. The resource impact for relevant authorities is closely linked to the timeline for commencing section 10. The Good Food Nation team are working with relevant authorities to collate evidence around the preferred commencement dates for section 10. This evidence will inform future budget discussions.

Relevant Authorities

99. Respondents raised concerns about the consistency across all of the Good Food Nation Plans produced at national and local levels and noted there was a need to ensure that the national and local Good Food Nation Plans are aligned with other policy areas.

100. The Act sets out the legislative requirements that the Scottish Ministers’ and relevant authorities’ Plans needs to fulfil. These are quite prescriptive and will ensure a minimum baseline that all relevant authorities should meet. Although there are some differences between the requirements on the Scottish Ministers and the relevant authorities, the core aspects of what the Plans must contain are very similar. This includes needing to set out the main Outcomes to be achieved in relation to food policy, the policies to do this and indicators or other measures to assess progress. There is also a list of matters and principles that both the Scottish Ministers and relevant authorities must have regard to when developing their Plans. Relevant authorities must also have regard to the national Good Food Nation Plan when developing their own Plans. This means there will be a common thread throughout all the Good Food Nation Plans, as they must consider these same aspects.

101. Beyond these requirements relevant authorities will have a degree of flexibility in the drafting of their Plans. This is to enable the plans to be developed to reflect their own particular food related issues that are likely to be different for each local authority and health board. This flexibility combined with the common thread of legislative requirements mentioned above means there is a balance between providing some consistency while also allowing for innovation and localisation in the development of the Plans.

102. Respondents also noted that local authorities and health boards developing Plans in conjunction with each other would mean more consistency. Scottish Ministers’ position is that it is for each relevant authority to decide how to produce their own Plan, and they may choose to work collaboratively or take a partnership approach to preparing their Good Food Nation Plans. However, the Act places various requirements (such as the main outcomes that a relevant authority wants to be achieved within its area of responsibilities) and, in order to act lawfully, each relevant authority must comply with these requirements.

103. To address some of the concerns highlighted we have published guidance for relevant authorities on the legislative requirements for local Good Food Nation Plans. In addition, we have also run a workshop on those requirements. We will continue to consider how we can support relevant authorities in sharing of best practice.

104. It should also be noted that variation across the first Plans is entirely expected as a natural part of a circle of refinement and improvement over the next iterations of the Plans.

Links to other Scottish Government strategies

105. Responses to the consultation highlighted that it was not clear how the Good Food Nation Plan would take account of other Scottish Government strategies. To address this concern we have made it clearer in the structure of the Plan how Good Food Nation links to other relevant policies of strategic importance. This includes an overview of these policies and there are cross references to Part Four of the Plan to make clear how the overarching policies link to the six Good Food Nation Outcomes. The Plan notes the interlinked and overlapping nature of these cross-policy strategies, plans and programmes and emphasises that these have all played a part in formulating the Outcomes contained within the Plan.

Future engagement with stakeholders

106. It was clear from the consultation responses that stakeholders are keen to be involved in the ongoing development of the national Good Food Nation Plan.

107. Once the final version of the first national Good Food Nation Plan is published later this year, there will be a requirement to review it within 5 years of publication and, if considered appropriate, revised. The same consultation requirements will apply to the revision of the national Good Food Nation Plan as were required for the first draft Plan.

108. In addition to consulting in accordance with the legislative requirements, the Good Food Nation Team will continue to engage with stakeholders. This might include, for example, providing guidance and support for the development of the relevant authority Plans and provide an opportunity for sharing good practice.

109. The views of the food business sector on the implementation of both the policies set out in this Plan and any relevant policy to be included in future Plans will be taken into account through a variety of means. There will be regular engagement with Scotland Food & Drink and the Food and Drink Federation Scotland and working groups such as the Food Sector Resilience Group, the Public Sector Food Forum and the Procurement Supply Group, where they will have the opportunity to provide their views on policies and policy implementation, amongst other things. These regular discussions will play an important role in gathering the views of the food business sector on an ongoing basis. In addition, the sector will be invited, as required, to respond to consultations on the formulation of individual polices. When consulting on individual policies we will encourage policy teams, where not already the case, to include questions seeking the views of the food business sector on effective policy implementation. This range of engagement with the food business sector will ensure their views are taken into account.

Right to Food

110. There was support for a concept of a “right to food” as respondents were concerned there was not equitable access to food across Scotland. For example, respondents noted that some people in Scotland cannot afford high quality food, and that ultra-processed foods and/or food high in fat, salt and sugar are often much cheaper options and more readily available.

111. The Act requires Ministers, when preparing the national Plan, to have regard to specific provisions in international human rights instruments. This includes article 11 of the International Covenant on Economic, Social and Cultural Rights (“ICESCR”) and the fact that the adequate food is a human right (as part of the overall human right to an adequate standard of living), and is essential to the realisation of other human rights^[6]. In the preparation of the Plan, Scottish Ministers are also required to have regard to specific provisions in the United Nations Convention of Rights of the Child^[7] and the Convention on the Elimination of all Forms of Discrimination Against Women, which concern adequate nutrition for children and women during pregnancy and lactation^[8]. These rights are woven into the Outcomes and policies in the Plan. Therefore, every time Ministers are required to have regard to the Plan they are indirectly having regard to these rights too.

Specific concerns about policy goals

112. A key theme across the consultation responses was concern about specific policies. For example, respondents raised issues or asked questions about one or two policies that were of particular importance or interest to them. To address these concerns we have put greater emphasis on the working mechanisms to achieve a Good Food Nation in the Plan. For policies that are listed in the Plan, we have also made it clearer what they are attempting to achieve. The working mechanisms (discussed from paragraph 69) and the legal status of the Plan will progressively help us move closer to achieving our ambitions set out in the Outcomes. While this approach does not address each individual policy for which questions were raised, it does explain how policy questions and concerns will be addressed by taking a food systems approach across Government.

113. The Plan is given legal effect through the requirement on Scottish Ministers to have regard to the Good Food Nation Plan when carrying out specified functions.

114. As time progresses we would expect that more and more policies and activities are adjusted to account for the Good Food Nation Plan, resulting in greater consistency on food policy across Scottish Government and indeed enhancing join up between the national and relevant authority Good Food Nation Plans.

115. The Scottish Statutory Instrument (SSI) on specified functions is still being drafted, and Parliament will have a chance to scrutinise its content, in accordance with the affirmative procedure. In drafting the SSI, we will have regard to the responses to the consultation relating to specified functions.