National Good Food Nation Plan: consultation analysis

Life in a Good Food Nation

176. The consultation paper presented a number of snapshot boxes, each offering a scenario to highlight what life will be like for different groups of people in a GFN. These groups were selected to reflect a broad range of roles across the food system. The groups represented were:

• A child.
• A parent/carer.
• An adult.
• A public caterer.
• A retailer.
• A restaurant owner.
• A farmer/crofter.
• A fisher.
• A food processor.

177. Respondents were asked whether each scenario reflected what they would like their life to look like. They were asked to respond if they had relevant experience of each group represented in a scenario. Given some of the responses to this series of questions, it appears likely that some respondents answered some or all of these questions but did not necessarily have the relevant experience. The scenarios presented to respondents are provided in Appendix 4.

178. Across the different snapshot boxes that were presented in the consultation, many of the same themes emerged. While many respondents provided comments on the snapshot boxes, some also provided suggestions for changes or additions/amendments. There were also a few suggestions for additional snapshot boxes that should be incorporated in the draft national GFN Plan. These included snapshot boxes for community organisations/groups, wholesalers, Chief Executives and educators.

179. Across all the snapshot boxes, there were a number of comments on the need for consistency. For example, the statement ‘I will never experience hunger’ only appears in the snapshot box for the life of a child in a GFN, but some respondents felt this was relevant to all individuals. Similarly, waste is mentioned in some snapshot boxes, but thought to be relevant to all.

180. The following paragraphs present a summary of common themes emerging across all the snapshot boxes. Comments relating to specific snapshot boxes are provided in Appendix 4.

Education, training and skills

181. A key theme which emerged was the role education needs to play in the development of a GFN. It was felt that education has a central role in helping to change attitudes towards eating choices. A key focus was on the need to strengthen the emphasis on food education within schools. Suggestions made by respondents included the provision of nutritional education in terms of teaching children how to make healthy food choices, and how to prepare and cook food. It was felt that food education should be lifelong, starting in nursery settings and continuing within the curriculum throughout school and further education. There were also comments on the need for an integrated and broad approach towards food education to include geography, culture, history and food.

182. There were also many comments on the need to provide food-related education to a wide range of individuals outwith the school/college system. This included parents, whole families, teachers, procurement officers and others working in the food and drink sector. It was felt there needs to be a greater awareness of, and emphasis on, what constitutes safe, healthy and nutritious food.

183. A number of respondents also focused on education and training for skills within the food and drink sector. This would enable those working in the sector to have the necessary knowledge, understanding and access to training and education on how to procure, prepare and produce healthy nutritious meals. For example, for public caterers and those working in procurement to have the necessary knowledge, understanding and access to training and education on how to prepare healthy and nutritious meals. There were also a number of comments on the need for increased numbers of environmental health officers to ensure correct standards are maintained and that food is prepared in a safe environment.

184. It was also felt that education including a greater focus on sustainable food sources would help individuals learn about the environmental impact of their food choices.

The provision of funding and resources

185. While there was broad support for the draft national Plan, another key theme, from all sub-groups, was of a need for further funding and resources to meet the Outcomes. Calls for additional funding and resources came across from all sectors including local authorities and health boards, who will be required to develop local plans for the implementation of a GFN. Local authorities in particular felt that additional resources and funding would be needed to introduce new initiatives under the draft national Plan.

186. Within the farming sector, there were calls for support for soil health and regenerative farming to increase environmental sustainability. Additionally, there were requests for funding or apprenticeships to help bring in new entrants to farming. There was a suggestion that agricultural subsidy needs to value small scale producers in rural areas. This was perceived to be of particular relevance, given a preference to focus on local produce and supply chains.

Procurement

187. Many respondents focused on the need for changes to procurement practices. It was felt that at present constrained budgets are a key barrier to procurement. There were also calls for more flexibility in procurement approaches; for example, to allow for support for local suppliers. An organisation within the health sector noted that catering managers can only procure from local organisations if they are on the national procurement list (many are not).

188. A need for public procurement to focus more on nutrition and food quality than cost was also mentioned by a number of respondents across all sub-groups who felt that budgets act as a barrier to purchasing healthy safe food. Allied to the issue of procurement, there were calls for all public sector environments (including schools, hospitals, social care settings, prisons etc) to offer healthy and nutritious foods.

189. As noted by a trade association/representative body:

“The aspirations outlined in the snapshot are laudable, but far removed from current practice, where often costs are the main motivator for procurement and there is little evidence that, particularly in hospitals, support for a variety of producers or using healthy, fresh and in-season food is a significant consideration. To move closer to the vision outlined in this snapshot, health boards and social care providers will need significant additional investment as well as support and guidance to move away from a national model of procurement where the focus is on cost towards more local provisions of nutritious food for both patients and service users as well as staff working in these sectors.”

Monitoring progress

190. There were a significant number of queries as to how the draft national GFN Plan will be delivered in a practical or affordable way and how access to a healthy diet will be achieved. Respondents identified the need for a clear action plan to identify how the Outcomes will be delivered. There were also some calls for a clear timeline for delivery. A third sector organisation identified a need for a clear set of deliverable actions, with measurable and realistic targets, set within a specific timeframe. An organisation in the health sector asked for further detail on how the draft national plan will be practically implemented and felt there is a need for guidance, resources and skills to bring this about. A trade association/representative body felt there were no substantive proposals for new actions and no proposed changes to any current actions. They suggested the setting of new SMART^[4] targets. There were also some queries as to how data would be collected and used in development of the draft national GFN Plan.

Linking to other policy areas

191. There were a number of comments that the draft national Plan does not make clear how the ambition and commitments of a GFN will be reconciled with other policy initiatives and legislation. For example, there was seen to be a conflict between the aims and ambitions of the industry-led food and drink strategy, which focus on business growth and profit, rather than health.

192. It was also suggested, primarily by organisations, that the draft national Plan tends to focus on the positive aspects of the Scottish export sector for alcohol and salmon. There were some criticisms of a lack of reference to the damage alcohol causes to health and related health costs, or to fishing practices that are not sustainable and which damage the environment.

193. There were also a few references to the need for employers to follow Fair Work principles and offer work that is flexible and pays a real living wage. This is particularly important as some respondents felt the food and drink sector pays poorly and has a negative image as an employment sector. There were references to the need for Fair Work principles to be embedded in the draft national GFN Plan.

194. It was also felt that there is a lack of connection between the Good Food Nation Act and pre-existing legislation requirements already in place to ensure safe food delivery. Reference was made to, for example, Hazard Analysis and Critical Control Point (HACCP) standards by an organisation in the health sector.

195. Other policy areas where there were calls for clear links included:

• Climate change.
• Net zero.
• The circular economy.
• The Agriculture and Rural Communities (Scotland) Bill and recognition of the impacts and opportunities this will bring.
• The Vision for Sustainable Aquaculture, which is felt will not tackle the problems caused by approaches to salmon farming.

The importance of ‘local’

196. There were many calls for the need to eat local and seasonal food. The key benefits of this would be support for local producers and a benefit to the environment through a reduction in food miles. However, linked to this, there were also requests for further developments to strengthen local supply chains; for example, the provision of local abattoirs. There were also comments on the need for local grocery stores to offer fresh, local produce but with the caveat that this needs to be provided at affordable prices.

197. Some respondents suggested that greater use of local produce would help to develop shorter supply chains and help to meet net zero and environmental targets. That said, there were some comments that funding would be needed to help bring this about. Linked to the issue of local supply chains, there were a few calls for Scotland to become more self-sufficient in food production. That said, some respondents acknowledged that Scotland cannot become self-sufficient because it cannot grow and produce the wide range of foods that people wish to eat.

198. While a number of respondents focused on the importance of local supply chains, there were some comments of the need to also consider global supply chains. A trade association/representative body commented that the draft national Plan fails to recognise the reality of global supply chains for commodity crops, livestock and export markets, and that global supply chains are an important part of the food system.

Access to safe, nutritious, healthy food

199. A number of respondents focused on the need for all individuals to be able to access safe, nutritious and healthy food. Indeed, some of these respondents felt the word ‘safe’ should be included in all snapshot boxes.

200. A number of respondents felt a move towards a more plant-based diet would offer nutritionally good food which is environmentally sustainable. There were also a few references to moving towards a vegan diet or an increase in organic food products.

201. There were a number of calls to reduce the availability of fast-food options and to reduce access to ultra-processed food and foods high in fat, sugar and salt (HFSS). Respondents suggested this could be brought about by increased taxes, limits on the availability of ultra-processed food (UPF), changes to its positioning within supermarkets and retail outlets, and restrictions in the promotion of these food types, along with reduced advertising or marketing. There were also calls for changes to labelling on food, to increase the amount of information available.

202. A number of respondents pointed out that safe, healthy and nutritious food also needs to be affordable if the Scottish population is to be weaned away from unhealthy UPF. UPF and HFSS foods were perceived to be much cheaper and more readily available than fresh food. It was felt that for people on a tight budget, there was little choice to buy fresh foods.

203. As noted by a third sector organisation, considerable damage has been done through the use of UPFs:

“While ultra-processed diets are of concern for various reasons, the loss of connection and relationship to good food sits at the heart of the dietary health crisis overtaking young people. Growing up surrounded by ultra-processed products, their appreciation of the joy, complexity, taste and texture of whole foods is inhibited. The process of learning to eat should be an exciting and rewarding journey, but UPF-rich diets are undermining children’s ability to appreciate the diversity of flavours, colours, smells and textures of whole foods. UPFs are made using industrial processes and additives that wouldn’t be found in a household kitchen – they typically lack whole, minimally processed ingredients, are excessively sugary, fatty, or salty, and are depleted in dietary fibre. As children learn not only ‘how’ to eat but also what, how much, and in what context to eat, the prevalence of UPFs in their diets can hinder the development of healthy eating habits and taste preferences.”

204. Linked to the issue of safe, healthy and nutritious food, there were also some repeated comments on the need for higher levels of animal welfare.

Equitable access to food

205. A number of respondents felt that at present there is not equitable access to food for all. While the number of food banks has increased in recent years and are seen to be necessary for individuals suffering hardship, to some of these respondents, food banks were seen to exacerbate the issue. As an alternative to food banks, there were a few suggestions for a cash-first response such as food vouchers or a minimum basic income. A few respondents also noted that food banks do not generally offer high quality nutritional and fresh produce and so do not fit with the aims of a GFN.

206. Linked to the issue of equitable access to food, there were a number of comments on making use of opportunities for growing food, often in a community context. For example, using the Community Empowerment (Scotland) Act to access land that could be used for community growing and/or allotments.

Collaboration with stakeholders

207. There were a number of calls for collaboration across the wide range of stakeholders in development of the draft national GFN Plan. For some, it was felt that involvement in development of the Plan would help to reduce any resistance there might be to any elements of the Plan. It was also felt that involving stakeholders would make the Plan more relevant across all parts of the food and drink sector. Alongside the involvement of stakeholders, there were calls for various activities that could be undertaken by the Scottish Government. For example, to prioritise Scottish food products or provide support for local food infrastructures. There were also some references to the role of the Scottish Government. As noted by a local authority:

“It is the duty of Scottish Ministers to protect public health regarding diet-related conditions and there has to be an issuing of guidance, strategies, and plans related to diet, wellbeing and physical and mental health for the public to comprehend and follow accordingly if they (the public) wish.”

208. Another local authority commented:

“Further consideration should be given to Fair Work First criteria, given the

challenging economic backdrop being faced by the hospitality sector. The impact of inflation on business costs, in the aftermath of the pandemic, has meant that many hospitality businesses are continuing to struggle to survive. The support and protection of this sector is critical for the delivery of the Good Food nation, local economies and further assistance from Government to target business resilience will be essential to its longer-term sustainability.”

The need for clear definitions

209. There were a number of calls for clear definitions. A few respondents felt that the language used assumes a level of knowledge about food that might not exist. A health board suggested the need for phrases that account for all types of food experiences and social inequalities. Some individuals queried specific phrases such as what a healthy nation means, or how to define a ‘good, healthy, balanced nutritional health plan’.

210. The final question in this section of the consultation paper asked:

Q18: If you have any further comments on the national Good Food Nation Plan, please comment here

211. A total of 299 respondents across all sub-groups provided comments to this question. To a large extent, comments made reflected those made at earlier questions.

212. A significant minority of these respondents welcomed publication of the draft national Plan or various elements of the draft national Plan. However, some of these respondents felt that the document is aspirational, but that delivery will be a challenge. Some respondents also felt the draft national Plan shows a lack of ambition and does not set out a new vision, or that this is a summary of current policy approaches. For example, a local authority asked what added value this draft national Plan offers as much of it is already in other existing policies. There was also a degree of scepticism as to how practically the draft national Plan will address inequalities, help to meet environment targets and increase health and wellbeing across the Scottish population.

213. A number of individuals commented on the need for businesses to make a profit in order to remain viable and that businesses will stock the types of food that people want to buy, rather than focusing on healthier food alternatives.

214. A small minority of respondents across all organisation sub-groups called for various impact assessments to be carried out. These included:

• Strategic Environment Assessment.
• Cost Impact Analysis.
• Health Impact Assessment.
• Equalities Impact Assessment.
• Consumer Rights Impact.

215. A similar number of respondents also referred to the establishment of the Scottish Food Commission. While welcoming this organisation, it was felt by some that their role needs to be clearly defined and that they will need to have statutory powers to ensure the draft national Plan is implemented.

216. A few respondents, mostly individuals, health boards, local authorities and community groups, focused on the need to bring about culture change so that consumers see food as more than just food and focus more on where it comes from and how it is produced. A local authority noted that consumers need to be aware of the links between a healthy diet and benefits to physical and mental health. An individual noted that legislation for smoking in public places had achieved changes in behaviour and attitudes towards smoking, and that something similar is needed for food and drink.

217. A small number of respondents felt that there will need to be guidance provided to health boards and local authorities to ensure consistency of approach across Scotland. A similar number also felt that it should not just be health boards and local authorities that have to produce local plans but also other public bodies.

218. Most other comments reiterated points made at earlier questions. These included the need for:

• Support to be provided to the wide range of stakeholders within the food and drink sector including farmers, food retailers, businesses within local supply chains and so on.
• Targets and timelines to be set and for effective monitoring to be carried out. For example, the draft national Plan could detail the current and desired situation and the actions that will lead to that change.
• Funding and resources for a wide range of stakeholders so that the draft national Plan can be implemented. For example, continued funding for the Food Processing Marketing and Co-operation Grant Scheme.
• Changes to procurement practices so that they prioritise healthy, local, sustainable food.
• The draft national GFN Plan to link into other policy areas and to ensure policy cohesion.
• Reductions (or bans) on the amount and availability of UPF and HFSS foods.
• Greater numbers of consumers to transition towards a plant-based diet or to reduce their intake of meat. Also, opportunities for consumers to grow their own food, particularly in a community context.
• More local, seasonal produce to be made available to consumers.
• Improvements to local supply chains, for example, local processing plants or local abattoirs. As a third sector organisation commented:

“A more localised, more resilient, more sustainable food system would bring huge benefits for producers and consumers, and for nature. Investment in local processing facilities such as abattoirs, mills, creameries is much needed, as is support for business collaboration e.g. more farmer owned and led co-operatives.”

• For healthy foods to be more affordable for all and to reduce food inequality across Scotland. Also, for healthy food choices to be more widely available.
• Greater numbers of skilled staff within the food and drink sector.
• Collaboration with all groups of stakeholders in the food and drink sector to ensure buy-in for the draft national Plan.
• Lifelong education on what healthy food is; how to prepare, cook and produce healthy meals.
• The draft national Plan to include definitions to ensure consistency and understanding across all stakeholders. For example, to provide clarity on what constitutes a healthy and sustainable diet.
• A greater emphasis on animal welfare throughout the draft national Plan.