Evaluating Scotland’s Good Food Nation Plan: A Critical Analysis (Part 2)

The Good Food Nation Plan – A Critical Analysis

In December, the Government published The First National Good Food Nation Plan.

The Good Food Nation Plan is one of two major policy developments intended to be taken forward by the Scottish Government in 2026, alongside an update to the Diet and Healthy Weight Implementation Plan, as highlighted in the Population Health Framework (2025). The Plan itself is the product of policy and laws proposed by the current Scottish Government and passed by the Scottish Parliament.

This blog is intended as an analysis of the Plan in order to determine actions for those primarily interested from a public health, diet and healthy weight perspective. An offers an overview and guide to the plan.

The Plan is substantial in scope, acting itself as a guide and map for policymakers as well as an index of relevant policy and information. It spans multiple policy areas and has significant reach. For any further detail, please consult the documents through the links below.

What is the Plan, and for whom?

The Plan is extensive; it is best understood as a framework. It is a well written and readable document. It has origins dating back to 2014, legislation in 2022, with a Commission as independent arbiter from 2024 but coming into being now.

Of the parts, the Foreword and Introduction are extensive and high level, parts one and two policy-related, three and four almost encyclopaedic and with many hyperlinks, a short conclusion and six annexes. The Plan’s prime readership is other policymakers at national level, for them to have ‘due regard’ to the Plan – its scope and direction. Future authors of local plans will offer targets, monitoring and data sources, which may or may not be available at local level, but the primary readership is for national level use. The third sector is mentioned later in the document, whilst people with lived experience are in focus earlier.

What is it not?

It’s not a blueprint in the sense of a plan, but a framework for a national plan. It aims for transformation, but it will not deliver that of itself. There is a lot of focus on poverty and food insecurity, less than expected on food costs, and costs of healthy food; no mention at all of plant-based / animal diet balance, or mental wellbeing and stigma, or specific disease groups such as diabetes / cancer / NCDs, or appetite suppressants. If it is world-leading as it claims, there is no explicit challenge to take innovative world-first steps to address the challenges that the Plan unwraps.

Where is health?

The Plan acknowledges strengths in Scotland’s food system, although the drivers for change are mainly around poor health and wellbeing. It is not a health focused document - Population Health is one of many considerations; it is not prevention focused. We’re eating (and drinking, but no mention of alcohol) the wrong diet. It is sound on our current problems not being a matter of individual choice and, commendably, it avoids defaulting there.

How best to approach the Plan?

The Plan does well to acknowledge many dimensions of food. There is a tilt, as one might expect from the policy authorship, toward environment, economy and rural affairs aspects. There are several mentions, including in the legislative section, on consulting with commercial interests and taking their views into account.

From the health perspective, the population health improvement role of Public Health Scotland is undeclared – it is mentioned as a participant, and a source of data. The role of health boards seems to be confined to convening plans, and service delivery – also food and drink provision as an ‘out of home’ setting – hospitals and health centres or care settings.

The more accepted drivers of change might well be where more attention is warranted:

• Children and struggling families.
• Poverty – various dimensions including fair employment, migrants and refugees.
• Rural economy, remote and rural communities (costs and availability).
• Rights – to food, nutritious food, for children, women.
• Local drivers – emphasis on local plans to deal with local issues and priorities.

Delivering ‘The Vision?’

The Vision is perfectly acceptable and encompasses health and wellbeing amongst the Outcomes. In breaking down The Vision, health and wellbeing features in the Childhood section; obesity in the Adult life section, and fair employment in subsequent sections.

The ‘Childhood’ section begins with:

‘…access to healthy, safe, and nutritious foods….’ and covers age and stage, educational as well as cultural, maternal and child matters.

Health occupies much of the ‘Adult life’ Vision:

‘Positive early experiences with food mean that people in Scotland are able to maintain a healthy relationship with food throughout their lives, enjoying a variety of foods appropriate to their tastes and cultural backgrounds.

‘Inequalities that prevent people from accessing healthy and nutritious food have decreased, with financial support easily available to those that need it. Rates of experienced food insecurity are at an all-time low, with advice and support readily available to ensure that everyone is able to access food in a dignified manner.

‘Diet-related health outcomes have improved. As a result of better diets, Scotland is experiencing a decline in the rates of obesity and associated conditions. Most adults are able to maintain a healthy weight.

‘The food environment in Scotland supports healthy and sustainable food choices.’

The more direct references to health in respect of The Vision for food and its production and sale is about safety, and:

 ‘Food manufacturers are empowered to reformulate their products to improve the nutritional content whilst maintaining a diverse portfolio of options. They use fresh and seasonal ingredients wherever possible to make healthy and sustainable products.’

‘Inequalities’ is a key focus

The focus on inequalities is detailed and multi-dimensional, with little direct reference to the health consequences. The challenges of remote rural and island communities are a highlight. There is no consideration in the main text to the costs – financial or other – of the shortcomings of our current food system, only the strengths and benefits, particularly in terms of livelihoods, the economy (community, coastal, farming and rural) and national reputation.

Targets and Monitoring – evidence and data gaps

In Part 3, the monitoring framework, and Part 4 on Targets, there is an opportunity to contribute to the development of the dataset and framework. They highlight the likelihood of data gaps and limitations.

National and Local focus

This Plan gives no indication about the expectations of local plans; it does not steer national organisations in a local direction, other than the requirement to consult – presumably involving local stakeholders. There may be potential for demonstrating aspects of a good food nation initiative ‘once and well’, or toolbox approaches to solve specific problems, or pilots that require particular skills and support.

Legislation

Annex D is instructive – any health-focussed initiative has a host of potential counterbalances, with policy interests that could modify or constrain chances of success. Any initiative that has health at its heart will need to look for policy ‘friends’ and fellow travellers under the headings listed above. 

Where are the opportunities?

There are potential opportunities for better population health throughout the Plan, and this aspiration is built into its text at key points – Outcome 3 is centrally about better health, and several others have that implicit ambition. There are also risks to worsen health in allowing, for instance, HFSS, alcohol, commercial, (including sports sponsorship) and/or meat and dairy-based interests to thrive without due regard for health. PHS, FSS and other key national organisations may be in a position to bring their strategic weight to the plan for health, offering leadership, technical skills and data, and momentum.

There are opportunities for OAS, its alliances and networks - in strengthening advocacy towards specific ambitions. These are not exhaustive:

• To highlight the Government’s existing commitments and targets, not least childhood obesity to halve and the direction of travel for adults.
• To unpack the health-related visions, starting with children, young people and adults, noting the focus on rights, and what means for advancing toward the outcomes of the plan (beyond what is envisaged in current plans).
• To add to the evidence base (where there are gaps), not least to fill out the picture of health and disease, benefits and costs.
• To highlight and seek to address gaps in data for monitoring and target setting, not least lived experience, diverse groups through mixed methods. Ethnic groups are a specific area for known unknowns.
• Consider the potential of prevention, the return on investment with better food environments, again bringing in lived experience.

The right to food – and health

There are also opportunities to ‘fine-tune’ the rights debate more closely to health interests, and to strengthen what are the elements of accessible, available, affordable, and quality of good food.

Some reference material on rights

This passage quotes the relevant instruments:

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

• Article 11 (so far as it concerns adequate food) of the International Covenant on Economic, Social and Cultural Rights (“ICESCR”)^[12]
• Article 24(2)(c) (so far as it concerns the provision of adequate nutritious foods) of the United Nations Convention on the Rights of the Child (“UNCRC”)^[13]
• Articles 27(1) and (3) (so far as they concern nutrition) of the UNCRC
• Article 12(2) (so far as it concerns adequate nutrition during pregnancy and lactation) of the Convention on the Elimination of All Forms of Discrimination Against Women (“CEDAW”)^[14]

‘These human rights instruments are woven into the Outcomes. The Scottish Government is committed to respecting, protecting and fulfilling internationally recognised human rights.’

The section continues:

‘The right to adequate food can only be fully guaranteed by addressing the accessibility, availability, acceptability, and quality of food in an integrated and systemic manner, and by recognising the indivisible, interdependent and interrelated nature of all human rights which are underpinned by dignity.

‘The United Nations Committee on Economic, Social and Cultural Rights considers the key components of the right to adequate food include^[15]:

• Availability:
• Food should be culturally acceptable.
• Food must satisfy dietary needs, taking into account the individual’s age, living conditions, health, occupation, etc.
• Food should be safe for human consumption.
• Food should be available from natural resources, either through the production of food by cultivating land or animal husbandry, or through other ways of obtaining food (such as fishing, hunting, or gathering).
• Food should be available for sale in markets and shops.
• Food should be available for future generations through sustainable production, considering factors such as the impact of possible climate change.
• Accessibility:
• Food should be physically accessible for all, including individuals who live in very rural areas; and individuals who are physically vulnerable. (such as children, people with ill health, disabled people, or older people)
• Food should be economically accessible for all. Everyone should be able to afford food for an adequate diet without compromising on any other basic needs such as heating or housing.
• The accessibility of food should be sustainable for present and future generations.

Closing Note

The Good Food Nation Plan is an extensive, possibly comprehensive document, ambitious in its scope and aspiration. It is at first base, no further - the framework for a Plan and that has taken about 12 years. There are many facets and health colleagues should study them carefully for opportunities to influence and develop. Many of these potential opportunities may not be termed ‘health’ or even ‘diet’, and there will be a long pipeline with many potential distractions before we may even see a difference. But it is a better chance than we have had for some time to gain leverage and see the prospect of progress in the right direction.