This is one of two guest blogs written by Dr Claire Perier giving an overview of recent developments in food policy ahead of Scottish Parliament scrutiny of the first National Good Food Nation Plan.
As with all guest blogs, what follows are the views of the author and not those of SPICe, or of the Scottish Parliament.
Below is a timeline for the Good Food Nation
Background: the Good Food Nation Act (Scotland) 2022
The Good Food Nation Bill was passed unanimously by the Scottish Parliament in June 2022, following over a decade of policy developments and civil society advocacy. Developments leading up to this legislation being proposed can be found in the SPICe briefing on the Bill, and discussions around Stage 3 considerations were summarised in a SPICe blog. The Act received Royal Assent in July 2022, establishing a legislative framework to support the Scottish Government’s vision for Scotland to be:
a Good Food Nation, where people from every walk of life take pride and pleasure in, and benefit from, the food they produce, buy, cook, serve, and eat each day. (p.2, Policy Memorandum)
The Good Food Nation (Scotland) Act 2022 (the GFN Act) places requirements on Scottish Ministers and certain authorities (currently the 32 Local Authorities and 14 Territorial Health Boards – although this section is not yet in force) to prepare and publish Good Food Nation Plans that set out outcomes, indicators, and policies on food-related issues affecting, amongst other things:
- Social and economic wellbeing
- The environment, including climate change, wildlife and the natural environment
- Health and physical and mental wellbeing (including through the provision of health and social care services)
- Economic development
- Animal welfare
- Education
- Child poverty
In the context of the GFN Act, food-related issues mean any matter connected with:
- Health which may arise in relation to the consumption of food
- Other interests of consumers in relation to food
- The availability of food
- The production, processing or distribution of food
- The preparation or service of food for consumers
As this broad range of matters illustrates, a central objective of the GFN Act is to address food-related issues holistically and provide “a structure through which we [the Scottish Government and relevant authorities] can work together across the public, private and third sectors to create a food system that works for the people of Scotland”. The legislative framework was designed to underpin existing food policy carried out across government directorates and encourage greater coordination and joined-up thinking between different portfolios. By asking relevant authorities to have regard to the National Plan when preparing their own Local Plans, the Act also seeks to drive coherence across the different levels of government, linking national ambitions with interventions designed and implemented in local areas. This shift towards a more systemic approach to food policy, which is happening across the globe, is due to the growing recognition that food production and consumption face interconnected challenges, and as such represent an opportunity to address major societal issues.
Systems approach to food policy: why and how?
Current patterns of food production and consumption are directly contributing to multiple issues, from food insecurity to diet-related ill-health and negative impacts on climate and biodiversity. These have prompted increasingly urgent calls for a global transformation towards fairer, healthier, and more sustainable food systems. However, a growing body of evidence also shows the interconnected and political nature of food-related challenges1
Food supply chains have become more complex, in part due to the globalisation of commodity markets, and now comprise multiple activities, including primary production, processing, packaging, distribution, retail, consumption and disposal of food. In addition, the many stakeholders involved have different, and in some cases competing, needs and interests: citizens, farmers, industry bodies, producers, retailers, community groups, or public bodies all have their own priorities when it comes to food. Finally, the increasingly volatile and uncertain socio-political context is also making food-related issues more complicated. Indeed, recent events such as the Covid-19 pandemic have highlighted the fragility of food supply chains. The war in Ukraine has exacerbated a global cost-of-living crisis and sent ripples throughout the food system, given its impact on energy, fertilizers and grain prices. Closer to home, the still unfolding consequences of Brexit have led to significant changes in agri-food trade but also the way agricultural subsidies or fishing quotas are managed.
Policymakers are now faced with the unenviable task of designing and implementing food-related interventions that balance ecosystem conservation, healthier diets, social fairness and justice, as well as economic viability. In an ideal world, this would mean keeping everyone – voters, third sector organisations, industry representatives, investors etc. – happy whilst also protecting the needs of future generations. However, food policy interventions tend to be designed in silos and often focus on the short term. Past decisions have actually been shown to be part of the problem, especially when policymakers fail to consider potential trade-offs or unintended consequences across environmental, economic and social dimensions. For example, the EU’s Common Agricultural Policy, originally conceived in the post-war period to ensure availability of food, eventually favoured large-scale, intensive farming, producing commodities high in saturated fats and sugars that have contributed to the increased burden of obesity and non-communicable disease. Moreover, a growing body of evidence suggests that food systems governance is significantly influenced by corporate interests and asymmetric power dynamics.
To address the complexity of food systems, there have been increasing efforts to design governance structures that take a whole-of-food system approach to policy. The objective is to make the connections between the multiple dimensions of food more visible, so that policymakers can actively consider the potential synergies, feedback loops or trade-offs between discrete policy areas and levels of government. This means setting up formal and informal mechanisms across the different stages of policy design and implementation to ensure that interventions seeking to improve one area do not undermine others and, where possible, take advantage of synergies to achieve better outcomes for all. The figure below gives examples of such positive and negative connections in the case of a policy seeking to promote fruit and vegetable consumption (source: Centre for Food Policy Brief, Policy coherence in food systems, 2019).
Implementing a systems approach to food policy: from the GFN Act to the proposed plan
Given the sheer number of policy areas involved and the complex relationships between them, adopting a systems approach to food is particularly difficult. As such, it is perhaps not surprising that the development of the first National Good Food Nation Plan took nearly 3 years. Once the requirement to publish a national plan is triggered through commencement of Section 1, the following statutory timeline – defined in Section 3 of the GFN Act – comes into force:
Whilst the GFN Act received Royal Assent in June 2022, it did not come immediately into force. The Scottish Government indicated its intention to trigger Section 1 much later in March 2023, following criticism about this delay by opposition parties during a Chamber debate on agriculture. The initial timetable, announced in a letter to the Rural Affairs and Islands Committee, confirmed the draft GFN Plan would be published for public consultation by summer 2023. Commencement regulations to this effect were passed in June 2023, meaning that the first proposed Plan would have to be laid before Parliament by the 31st of December 2024. However, as the end of 2023 approached, the public consultation on the draft Plan had yet to be launched. As a result, Scottish Ministers laid an amendment to the regulations to delay the legal requirement to publish the Plan by 6 months, to the 30th of June 2025.
Draft plan and public consultation
The draft National GFN Plan was published in January 2024. The public consultation ran up to April and included questions on the proposed outcomes, indicators etc. The Scottish Government also conducted engagement activities with civil society, including children and young people. The independent analysis of responses, published in September 2024, noted that whilst views about the Plan were “generally positive”, many respondents felt the draft was “too general in nature and rather vague, with a focus on existing policies rather than new policies and initiatives”. A great variety of themes and opinions were raised, from generic concerns over resources required to deliver the Plan’s outcomes, to suggestions for specific interventions. Recurring topics included: the right to food, the role of public procurement, the influence of the food environment on diets, or the links between food and climate change.
The broad range of views expressed by the consultation respondents illustrates once again the complexity of food policy. Officials also had to contend with the other stakeholders it engaged with during the plan’s development, including policy teams across government directorates and agencies. In a statement published alongside the proposed plan in June 2025, the Scottish Government acknowledged that whilst this comprehensive consultation process allowed for many voices to be heard, it meant that suggestions were “wide ranging, sometimes contradictory and variable in terms of specificity and length” (p.13).
Timeline for Parliamentary scrutiny
After a period of revision, during which officials sought to address the comments received during the consultation period, the Proposed National GFN Plan was laid before the Scottish Parliament on the 27th of June 2025. This was three days before the end of the statutory period and, crucially, just a day before the Parliament entered recess. This means that the scrutiny period must end on the 30th of September 2025, or 30 days after Parliament resumes sitting. This adheres to the timetable set out in legislation, although it allows only 30 days for Parliament to scrutinise the proposed plan, report on it and debate it.
Crucially, the delayed timeline meant that the Rural Affairs and Islands (RAI) Committee, which had coordinated the scrutiny of the GFN Act, could no longer lead the scrutiny of the proposed plan due to a heavy workload. Instead, both the Health, Social Care and Sport and the Local Government, Housing and Planning Committees have taken a more prominent role. They issued joint call for views on the 30th of June to gather feedback on the plan’s contents “as they relate to [each committee’s] respective remits and interests”. Whilst, given the short timeframe, this focus on the discrete elements familiar to each Committee is perhaps to be expected, it could also undermine the principles of a systems approach to food policy.
The RAI convener wrote to the Minister for Parliamentary Business to express members’ disappointment at the missed opportunity to scrutinise the detail of this important document, but also:
“strong concerns about how the amount, and timing, of government business is impacting on our ability to carry out effective parliamentary scrutiny.”
The RAI convener later wrote to the Conveners’ Group to draw their attention to these scheduling issues and asked for the matter to be discussed. Over the summer recess, the RAI committee was able to find some space in its busy work programme to undertake some scrutiny of the Proposed Plan within the 30 days window. This will complement the evidence received through the call for view and the subsequent oral evidence sessions held by the Health and Local Government Committees.
Systems approach in the Proposed GFN Plan
The Scottish Government had already expressed its intention to embed a systems approach to food policy in the Draft GFN plan:
The first Good Food Nation Plan represents how the Scottish Government intends to work collectively together with the supply chain and with all parts of society in meeting our Good Food Nation ambitions.
The proposed version of the Plan focuses even further on this aspect. The list of food-related policy has been streamlined to give way to a dedicated section on monitoring (targets and indicators). The practical mechanisms seeking to embed GFN outcomes into the policy development and implementation process are likewise described in Part three, and include:
- the Ministerial Working Group on Food, which allows for cross-portfolio discussions and decision-making. This was set up following a commitment in the 2019 to 2020 Programme for Government, although there is little transparency over the frequency of meetings or their agendas (unlike the Rural Delivery Plan: Ministerial Working Group and other stakeholder groups, for which minutes are regularly made public)
- An internal working group bringing together policy officials from different portfolios, and which already helped to establish connections during the drafting of the GFN Plan
In addition, the GFN Act introduces two accountability mechanisms that aim to encourage a joined-up approach to food policy:
- An independent Scottish Food Commission, whose functions are to review Plans’ progress and effectiveness, and to advise, inform, and assist Ministers and relevant authorities. The first Chair of the Commission, Dennis Overton, was appointed in August 2024, and joined by another three board members in June 2025. At time of writing, recruitment for a Chief Executive was underway, with the Commission expected to begin exercising its functions once the first National Good Food Nation Plan is published by the end of 2025.
- A duty on Scottish Ministers and relevant authorities to have regard2 to the Plans “when exercising a specified function or a function falling within a specified description” (Section 6). Specified functions are existing legislative provisions that give powers or duties to Ministers, such as exercising the power to designate protected areas under Section 54 of the Aquaculture and Fisheries (Scotland) Act 2013. Specified descriptions are more general functions of government, such as when making policies, strategies or plans on nutrition. Note: this is the first time that this type of provision has been used in Scottish legislation. In a statement published alongside the Proposed GFN Plan, officials explained that this mechanism was preferred to a general “have regard duty” to avoid placing unnecessary requirements on policy areas that do not deal with food-related policy. in October 2025 and will be subject to the affirmative procedure.
The Scottish Government clearly does not expect this shift towards working practices that take a systems approach to food policy to happen immediately. The conclusion of the Proposed GFN Plan notes that:
This Plan sets out the foundations for a new way of doing things, setting out ambitious Outcomes and a document that signals to policy officials where they can be working together to achieve the vision of Scotland as a Good Food Nation. The scale of this change in working practice should not be underestimate: breaking down silo working will take time as this innovative approach is put into practice.
That being said, the Proposed GFN Plan does not explore why past attempts at integrating food policy (or policies related to wide-reaching areas like climate change) have failed to deliver. More importantly, because the document still includes a list of existing policies related to food, it is difficult to discern whether the Plan’s development process has resulted in new or changed policies. This also means that attention tends to fall onto each intervention or sector in isolation, rather than how these areas may be better connected. In other words, it remains unclear how the aspirational vision described by the outcomes will be achieved by the assortment of interventions included. Because there is little consideration of these relationships, the Plan lacks nuanced assessments of the potential trade-offs and conflicts between policy areas. There is no clear pathway for instance that shows how the Scottish Government intends to reconcile the competing expectations placed on farmers and fishers: how can they be supported to adopt more sustainable practices, including increasing areas dedicated to wildlife or forestry, whilst increasing economic productivity and growth – often through trade – but also at the same time maintain the quality and affordability of their produce to contribute to better population health and food security.
Reception in Scotland
For the Sustain alliance and Nourish Scotland, ”Scotland’s Good Food Nation Plan is a good start, but fails to impress”. Whilst the broad direction of travel was celebrated, both charities highlighted several fundamental gaps, from inadequate attention given to food environments, the omission of sustainability in relation to the food and drink industry, and little mention of worker safety.
In another reaction piece, Anna Chworow, deputy director of Nourish Scotland, deplored the lack of front leadership by the Scottish Government, whilst noting the plan ”creates a space for the MSPs, Committees, civil society and citizens to lead from behind”.
For the Scottish Fishermen Federation and trade organisation Seafood Scotland, the proposed plan’s move towards a systems approach is an opportunity for the sector to ”play a more active role in shaping the direction of food policy“.
The low number of reactions to the Proposed GFN Plan can be attributed to the publication’s timing on the eve of Scottish Parliament recess, but also by competing food policy news during the same period. These recent developments, in Scotland and elsewhere in the UK, are explored in this companion blog.
Conclusion: what’s next for the Good Food Nation?
A systems approach to food policy is essentially a way to set a common direction of travel towards a shared vision. In the case of the GFN Plan, this has been done using aspirational outcomes, and a set of associated indicators. However, recent policy developments internationally and within the UK show that this may be insufficient to deliver actual change. Scotland has seen disappointing results towards ‘world leading’ ambitions, such as the missed targets on climate change or child poverty. Likewise, even the well-designed and coherent National Performance Framework has been found to be insufficient when not actively used in decision-making and evidenced explicitly in other strategies and policies.
The specified function mechanism technically goes further than other recent developments in the rest of the UK by introducing a statutory requirement to pay attention to food. This type of duty will however be meaningless without some sort of enforcement. It also carries the risk of turning into an entirely bureaucratic process, when the already limited team in charge of the Plan has been tasked with implementing what is essentially a structural reform in the way food policy is designed. The scrutiny of the upcoming regulations on the specified functions will be an opportunity for the Scottish Parliament to question the Government on this point, even if the approaching election means that the actual roll-out of this duty will happen during the next Parliamentary cycle. Monitoring of the GFN ambition could even be linked to, or integrated into other cross-sectoral work, for examples scrutiny on climate change.
Overall, much of the National GFN Plan’s success will hinge on its capacity to drive greater alignment not only between food-related interventions, but also across other policy areas and government levels. Until now, there has been limited evidence of ministerial engagement with the Good Food Nation agenda outside of the Rural Affairs portfolio – in contrast with England where the latest food strategy was explicitly endorsed by the Ministers for Health and Employment. The recently launched consultation on the next Scottish Land Use Strategy for instance makes no mention of the GFN Plan, even though achieving the right balance between agriculture, forestry and peatland restoration will be essential to deliver Net Zero by 2045. Food production and consumption have become particularly contentious issues since the Climate Change Committee (CCC) published its recommendations for Scotland’s carbon budgets, as agriculture and land use are expected to make the biggest contributions to emissions reductions from 2036 onwards. The Scottish Government has already indicated the upcoming Climate Change Plan will not follow all the policies set by the CCC, especially around livestock numbers, but crucially is yet to comment on recommended changes in dairy and meat consumption patterns required to reduce emissions (or how this links to the Scottish dietary goals). Because of these conflicting demands, needs and perspectives, food systems transformation requires difficult choices to be made. Until now, the GFN ambition has remained vague and aspirational, perhaps with the intention to drive coherence and integration, but eventually policymakers will need to engage directly with the potential trade-offs and contradictions between its multiple outcomes. The Proposed GFN Plan has taken a first step by acknowledging the complexity of the issues at hand. The next will be to ensure greater attention to these interactions, and more importantly, transparency over whose interests might need to be prioritised over others.
Dr. Claire Perier, Academic Fellow
- See for instance: the High Level Panel of Experts on Food Security and Nutrition of the Committee on World Food Security note on Critical, emerging and enduring issues for food security and nutrition (2022), the Science Advice for Policy by European Academies evidence review Towards a sustainable food system (2020), the UK’s National Food Strategy (2021) independent review, or the Scottish Food Coalition deep dive A Good Food Nation for Scotland – Why and How (2024). ↩︎
- ‘Have regard’ means that Scottish Ministers or relevant authorities must take something into account and, if they decide to depart from it, must have and give clear reasons for doing so. In other words, policymakers must demonstrate (with evidence) that they have considered the plans, but they are not necessarily bound to follow them and retain discretion to decide how much weight to give to them. ↩︎