Good Food Nation: we have a plan, but does it have any teeth?

In this guest blog, Dr Claire Périer explores the latest developments in Scottish food policy, including the publication of the first National Good Food Nation Plan, the twist and turns around the secondary legislation meant to give it effect, and what may come next.

As with all guest blogs, what follows are the views of the author and not those of SPICe, or of the Scottish Parliament.

The list of contents below has been provided to aid navigation

The first National Good Food Nation (GFN) Plan was published on 17th December 2025, just over 3 years after the Good Food Nation (Scotland) Act 2022 was enacted. This marks an important moment in Scotland’s food policy journey, which was explored in the previous blog next steps towards a good food nation.

The GFN Act requires Ministers to publish a National Plan that sets out the outcomes the Scottish Government wants to achieve in relation to food-related issues. Alongside these overarching objectives, the Plan details a range of indicators to measure progress, as well as the list of policies and initiatives that will contribute to achieving the outcomes.

While the first National GFN Plan is now finalised, it has limited legal bearing because Section 6 (effect of the plan) of the Act is not yet in force. Section 6 introduces a statutory duty for Scottish Ministers to “have regard” to the Plan, meaning they must demonstrate they have taken the GFN objectives into account when exercising certain functions and, if they decide to depart from them, they must give clear reasons for doing so. The commencement of Section 6 had to be delayed as the regulations listing the functions covered by this “have regard” duty were not approved by the Rural Affairs and Islands Committee and were subsequently withdrawn.

The rest of this blog explores the broader effects of Parliamentary scrutiny on the first National GFN Plan, what led to the regulations being rejected, and what this could mean for the future of Scottish food policy.

What is (and isn’t) in the first National GFN Plan?

Issues raised during parliamentary scrutiny of the proposed Plan

The final version of the Plan was issued after a period of intensive Parliamentary scrutiny in September 2025. Three Committees took evidence on the proposed National GFN Plan (see Table 1). This level of engagement is relatively unusual, but it reflects the cross-cutting nature of food policy, which encompasses areas as diverse as food production, diet-related health, inequalities, and environmental degradation.

Table 1 – Evidence considered during the scrutiny of the Proposed GFN Plan 

Each Committee focused on the plan’s impact over elements falling within their respective remits, but common themes emerged from these discussions:

• Uncertainty around resources and timescales: who should pay and be responsible for transforming the food system, especially over the long-term?
• Need for greater emphasis on role of private and third sectors
• Limited practical details on the new mechanisms and ways of working the Scottish Government intends to implement to foster cross-sectoral and cross-portfolio collaboration, including linking local and national plans
• Lack of clarity on the purpose and functions of the Scottish Food Commission (an independent oversight body introduced by the GFN Act and formally established in March 2025), including its role in supporting coordination but also its relationships with other existing bodies like Food Standards Scotland

No single document synthetised the evidence heard by the various Committees, in part due to time-constraints during the final term of the Parliamentary session. Instead, the Health, Social Care and Sport Committee and the Local Government, Housing and Planning Committee each published a report (available here and here) with their respective recommendations. The Rural Affairs and Islands Committee only had time for a single evidence roundtable amidst its busy timetable and instead of a report issued a letter to the Cabinet Secretary drawing attention to the topics heard during the session.

It is beyond the scope of this blog to cover all the recommendations in detail, but the Accompanying Statement published alongside the National GFN Plan sets out how each matter was addressed. 

Comparing the proposed and final versions of the plan

The final version of the National GFN Plan does not depart significantly from the proposed version scrutinised by the Scottish Parliament in September. The main changes are:

• A new section on inequalities that summarises the impact assessments, and is intended to be used as “a prompt for the kind of inequalities policymakers will need to think about when developing new food related policy”
• Clarification that the outcomes should be considered as a cohesive set, rather than one being more important than the others
• Explicit mention of systems thinking as the underpinning approach to changing working practices and tackling complex, cross-cutting issues
• Greater emphasis on links between national food policy and relevant authorities, with partnership working presented as key to deliver the GFN ambition
• Recognition of the role of third sector and community organisations
• A streamlined section on indicators, with much of the detail now presented in a separate Monitoring Framework document
• Added mentions of:
  • the Food (Promotion and Placement) (Scotland) Regulations 2025
  • policies seeking to reduce harms associated with alcohol consumption
  • malnutrition
  • the Fruits and Vegetables Aid Scheme
  • the UK Pesticides National Action Plan
• Extra annexes with resources on procurement

Potential gaps and weaknesses

It is also worth noting what is not included in this first National GFN Plan, even if an initial iteration could be expected to not be all encompassing. The officials tasked with writing the Plan explained in the Accompanying Statement (item 63, page 14) that they sought to balance the need for setting out outcomes that can be understood by the general public, whilst also providing enough detail about the many policies involved to enable Scottish Ministers and their teams to meet their “have regard” duties. An in-depth analysis of the areas included or not would take much more than this short blog, but a few structural weaknesses merit to be highlighted.

Firstly, the Plan does not introduce any new targets or policies. Instead, it simply lists what is already happening across food-related areas where Scottish Government has devolved competencies. Whilst establishing this baseline is of course important, the absence of new commitments could become problematic given that the plan also lacks details on implementation and responsibilities for delivery.

Secondly, there is limited assessment of each policy’s contribution to each outcome, and more specifically the potential for trade-offs or co-benefits between the many interventions mentioned. For example, the policy area of climate change and agriculture is not linked to outcome 3, which states that the food system promotes a physically and mentally healthy population. This is despite increasing evidence that addressing climate change can also address health inequalities (see the recent SPICe briefing on links between climate change and health in Scotland). In Part Four of the Plan, each individual policy is cross-referenced with the outcome(s) it contributes to, but this is not evidenced nor quantified. Moreover, only a few policies are linked to all six outcomes, even though the Plan is articulated around the principle of a joined-up approach, with “no Outcome being considered more, or less, important than the others” (p. 11). If the Outcomes are to be a coherent set, then shouldn’t each policy be assessed against all of them?

Finally, the Plan remains vague in terms of delivery mechanisms and future steps for implementing a more strategic approach to food policy. For example, the Ministerial Working Group on Food is presented as the main channel for cross-portfolio discussions and high-level decision-making. However, there are no details as to its terms of reference, membership or meeting frequency, and unlike other groups, minutes are yet to be made public. Likewise, the Plan does not specify how the “have regard” duty will be implemented, even though this new mechanism is presented as central to changing working practices and ensuring joined-up policymaking.   

Giving effect to the plan through the specified functions regulations 

Section 6 of the GFN Act states that

The Scottish Ministers must, when exercising a specified function or a function falling within a specified description, have regard to the national good food nation plan.” 

In the Scottish Government’s view, this is preferable to a blanket requirement that would place an unnecessary burden on policy areas unrelated to food. Here, “specified” means specified in regulations made by the Scottish Ministers. A function will be a power or duty detailed in other pieces of legislation, for example the power of making codes of practice under section 37(1) of the Animal Health and Welfare (Scotland) Act 2006. A function falling within specified descriptions will be broader, like making policies, strategies or plans about diet-related health conditions. 

Even though this mechanism has been presented as giving “teeth” to the GFN Act, the initial bill documentation did not cover what might be considered a specified function or description. An initial list of topic areas was included in the public consultation on the draft GFN Plan held in 2024. This was refined through extensive engagement with policy teams and legal advice, and further examples were provided in a brief overview of the upcoming regulations published in June 2025. 

Specifying the functions in regulations: Committee scrutiny

On 27^th October, the Scottish Government laid a draft secondary instrument (“The Good Food Nation (Specified Functions and Descriptions) (Scottish Ministers) Regulations 2025”) before Parliament. The accompanying policy note referenced the public consultation, but gave no detail on the rationale behind the list of specified functions and descriptions included in the proposed regulations.

Approval of the draft instrument was subject to the affirmative procedure, meaning that it could not come into force until approved by the Parliament (first through a lead Committee then a vote in the Chamber). The Rural Affairs and Islands Committee led the scrutiny, including issuing a short call for views, which was answered by 24 organisations and 3 individuals.

Most respondents felt that the draft regulation was incomplete and called for significant amendments (although secondary legislation cannot be changed by committees in the same way as Bills, instead it must be re-laid). A notable omission for instance was agricultural policy, which covers the provision of farming subsidies and consideration of the environmental impact of food production, including climate change mitigation and adaptation.

The Rural Affairs and Islands Committee wrote to the Cabinet Secretary asking for further details on how the proposed list of functions and descriptions were arrived at. The Government’s response to the Committee’s questions is a detailed commentary for each function, including why some previously mentioned in the 2024 consultation were eventually not included. Agricultural policy for instance is understood to be covered by an existing requirement introduced by the Agriculture and Rural Communities (Scotland) Act 2024.

Crucially, the Cabinet Secretary’s letter was published after the call for views had concluded. This lack of transparency fuelled criticisms about the proposals. In their submission to the Parliament, the Scottish Food Commission expressed strong concerns over the minimal level of information surrounding the Scottish Government decision-making process.

An unexpected twist: the Committee disagrees

When presenting oral evidence to the Rural Affairs and Islands Committee, The Cabinet Secretary explained that the main rationale underpinning the development of the draft regulations was to avoid duplication:

 “You might have noticed what appear to be gaps in some instances. They have arisen because other legislation already provides what is, in essence, a specified function outside the instrument. In other cases, it is because a general duty to have regard to a broad policy area already exists, so it was felt unnecessary to duplicate that in the SSI [Scottish Secondary Instrument].” 

The Committee, however, echoed stakeholders’ concerns that having some functions specified in different pieces of legislation would go against the very purpose of this new mechanism, which was introduced to provide clarity around the legal effect of the Plan. The Cabinet Secretary noted that monitoring the “have regard” duty would be critical in delivering the Plan, however officials explained there was still uncertainty around how this would be done in practice, in part due to the novelty of the specified functions and descriptions approach.

Another key argument advanced by the Cabinet Secretary was that this first draft of regulations represented just a starting point. Amendments could easily be scheduled alongside the regular reviews of the National GFN Plan or whenever required (for instance in the case of new legislation being passed). However, the Committee noted that any subsequent modification would be subject to less scrutiny as revisions would go through the negative procedure (whereby regulations may become law automatically unless actively annulled). Moreover, members stressed that pressing forward with the draft in its current state would not answer the many concerns raised by stakeholders.

Eventually, the arguments presented by the Cabinet Secretary failed to reassure members, and the Committee voted against recommending the approval of the draft instrument (For: 4, Against: 5, Abstentions: 0). This decision was highly unusual, only a very small number of draft regulations have resulted in a disagreement during this Session of the Parliament.

A plan with no teeth (yet)

After the Committee’s decision, the Scottish Government chose to withdraw the draft instrument (the only alternative being seeking a favourable vote in the whole Chamber). In a letter to the Delegated Powers and Law Reform Committee, officials confirmed plans to engage in further consultation with relevant stakeholders before issuing a revised version. However, given pressures on Parliamentary time, this will not happen until after the Scottish Parliament election and summer recess.

In the absence of regulations specifying the functions and descriptions covered by the “have regard” duty, Ministers are under limited legal obligation to consider the National GFN Plan and its objectives.  Until a new draft instrument is approved, the only way the Plan has any legal bearing is through other pieces of legislation. The Agriculture and Rural Communities (Scotland) Act 2024 for instance states that Scottish Ministers must have regard to the objectives of the Good Food Nation plan when preparing a rural support plan.

These legal ramifications may sound dry and technical, but they also offer a silver lining. The very existence of the GFN Act could help mitigate the effect of electoral cycles and changing political priorities. Indeed, the successor to the Rural Affairs and Islands Committee will have the option to put the forthcoming specified functions regulations on their radar. More importantly, even if Section 6 is yet to be triggered, other elements of the Act are in force, including the requirement to review and revise the plan, and the establishment of the Scottish Food Commission.

What is next for the Good Food Nation agenda? 

Despite the uncertainty over the legal implications of the GFN Plan, the coming months could see several developments that should bolster Scotland’s ability to deliver integrated food policy. First, the roles and responsibilities of the newly established Scottish Food Commission should be clarified through a framework document agreed with ministers (although there is no set timeline for its publication). The inaugural Chief Executive, Jayne Jones, took up post in January 2026 and has begun work on a corporate plan that will set out how the Commission plans to exercise its function and develop relationships with other public bodies.

At the local level, several councils and health boards have begun preparations ahead of the commencement of Section 10 of the GFN Act, which mandates the development of local plans. Stirling Council held a good food fortnight in March 2026 to celebrate the local food scene and spark conversations about what a Good Food Nation may look like for the area. In the Highlands, GFN leads from the council and NHS have engaged with other key stakeholders like the Highland Good Food Partnership to build connections, share resources and co-design a shared strategic vision.

The requirement to produce local plans is not expected to be in place for at least another two years. The GFN Act includes a 12-month period for the preparation of the plans, and the Scottish Government confirmed it was considering ways to give advance notice to relevant authorities. This should avoid a clash with the 2027 Local Government elections, and, building on the National plan experience, allow more time for meaningful consultation and community engagement.  It will also give time for the Scottish Government to prepare another raft of regulations specifying the specified functions and descriptions applying to relevant authorities, as the powers and duties of local government and health boards are different from those of Scottish Ministers.

Finally, the GFN Act should also benefit from recent interest shown for the role of legislation in food policy outside of Scotland. In February 2026, over 100 businesses, investors, NGOs and academics issued a joint statement calling for the UK Government to introduce a Good Food Bill to transform England’s food system. The signatories, which include major private actors like Sodexo, Marks and Spencer and Danone, argue that primary legislation with long-term duties and targets would support integrated, cross-government action, and help drive the food systems transformation needed to address major societal challenges. The value of such legislation would certainly be justified if the Good Food Nation question remains high in the public agenda after the upcoming Scottish Parliament elections.

Dr Claire Périer, Academic Fellow