Submit Your Views by THURSDAY 18th April 2019: Making Scotland a Good Food Nation

Since 2014 it has been the Scottish Government’s policy that Scotland should become a Good Food Nation. What does it mean to be a Good Food Nation? The Scottish Government set out some broad objectives for the policy, which are laudable and in line with a country that values fairness, justice and equity for all. They said that a Good Food Nation Scotland would look like this:

  • "Everyone in Scotland has ready access to the healthy, nutritious food they need;"

  • “The people of Scotland have improved access to, and understanding of, the benefits of healthy local foods”;

  • "Dietary-related diseases are in decline, as is the environmental impact of our food consumption;"

  • "Scottish producers ensure that what they produce is increasingly healthy and environmentally sound;"

  • “Our progressive food industry is clearly operating in a sustainable way."


What is envisioned then is a Scotland in which we have eradicated food poverty and ensured that everyone has access to good quality, local, healthful food, and the knowledge and skills to prepare delicious and nutritious meals with it. We will have transformed our broken food system into one that promotes health and well-being, and is sustainable and in tune with our environmental obligations and safeguarding the future of our environment.

The question now is how we get there. The first step is this consultation, in which the Scottish Government is seeking views on four broad but quite technical questions about putting a framework in place within which further more detailed legislation would be developed.

It is very clear to us that a healthful and sustainable food system is one based on plants. Recent reports by those who are expert in the relevant fields of nutrition and sustainability agree, for example:

When the Scottish Government opens the next rounds of consultations we will be able to get into this in more detail. For now we have to answer the four questions about framework legislation. We’ve set out below the questions, a short explanation in ( ) of what we think they are asking (because the wording is really quite technical, which is not helpful for a public consultation) and our answers, which you may wish to make use of in submitting your own responses.

This is where you can make your submission: https://consult.gov.scot/food-and-drink/good-food-nation/

Question 1: To what extent do you agree with the framework proposals for Ministers and public authorities to prepare statements of policy, have regard to them in the exercise of relevant functions, and report on implementation, with regard to international obligations and guidance?

(In the Consultation briefing they explain that they are proposing to make an overarching policy about food, which would cover the whole food system. This would include measurement of progress by individual

entities. We see this as an opportunity to bring in international and regional human rights obligations, as well as commitments on environmental protection and climate change, food justice and the right to food and health, all of which support the promotion of plant-based eating.)

Our Answer:

'Strongly Agree'

"It is of critical importance that our entire food system be covered by overarching fundamental principles based on justice, equity, respect, health and sustainability.

Framework legislation, applicable to the Scottish Ministers and public authorities, must include:

  • the right to food; food justice must be a focus for a Good Food Nation Scotland. Everyone should have access to the good quality, nutritious food they need. The Scottish Government has stated that in a Good Food Nation “Everyone in Scotland has ready access to the healthy, nutritious food they need." To make this a reality the first step is to make this an express right of everyone in Scotland, enshrined in domestic legislation. To state that in a Good Food Nation everyone has access to the healthy, nutritious food they need and then refuse to enshrine that as a right in the framework legislation for a Good Food Nation would be completely inconsistent.

  • the right to health; there must be express recognition of the connection between access to good, nutritious food, and the knowledge and skills to prepare it, and health. Everyone has the right to up to date information about nutrition and health, free of the influence of vested interests;

  • the right to food security; including a requirement that we emphasise and support community, urban and public growing spaces and related skills development;

  • the right to life and specifically the right to a healthy environment; this is squarely relevant to our food system which is (and historically has been) a key contributor to greenhouse gas emissions, land clearance, deforestation, eutrophication, waste, chemicals, antibiotics and water usage;

  • workers’ rights;

  • equality and freedom from discrimination;

  • the absolute exclusion of big business / those with vested financial interests and their spokespeople, from the process of policy-making, including the setting of national food guidelines;

  • a requirement that we emphasise and support sustainable and environmentally friendly food production;

  • a requirement that we emphasise and support local, chemical free, food production;

  • a requirement that we emphasise and support locally sourced, freshly prepared food in our public entities;

  • a requirement that businesses pay for damage they cause and have caused to our land, water, air, biodiversity and environmental sustainability, and public health, and for their contribution thereto;

  • setting up an independent body to assess progress;

  • require progress reports at least every two years; these reports to be made public and views to be taken from the public on the adequacy of the progress made, with the relevant parties required to address any concerns raised.

Question 2: Whilst we do not plan to require all sectors to prepare statements of policy on food, they do all have a role to play in achieving our Good Food Nation ambition. To what extent do you agree that Government should encourage and enable businesses in particular to play their part?

(They seem to be saying that state or government entities will be required to prepare a statement on food policy, and this question is asking to what extent should private businesses be required to do so).

Our answer:

'Strongly Agree'

"We can only achieve the Good Food Nation objectives if every party involved in our food system is involved. All those involved in our food system ought to be subject to the rights set out in the framework legislation, and be required to produce a Good Food Nation policy in order that there is openness and clarity in terms of their understanding of what is required of them, their acceptance of the need to make changes, and how they intend to adapt. Their policy must be put out for comment by the public, with challenges and concerns raised considered by the independent body set up to measure progress. They must also be required to produce progress reports at least every two years, these reports to be made public and views to be taken from the public on the adequacy of the progress made, with bodies required to address any concerns raised.

What is absolutely critical is that the influence of big business does not dictate our policies on food or anything to do with our food system. Our food system must be led by considerations of fairness, justice and the sustainability of our planet, not on short-term gain or vested financial interests. For a recent example of a policy process in which real efforts were made to ensure that big business did not influence outcomes we can look to Canada’s recent rewriting of their national food guide. See for example: https://www.theglobeandmail.com/canada/article-new-food-guide-shifts-toward-plant-based-foods/?fbclid=IwAR2Jwh5eM3w12wQAXRkOurKb2PidRb0yon_HQ_14NXkh6Tv3_axw25HgtoM "

Question 3: To what extent do you agree with the proposed approach to accountability of Scottish Ministers and specified public authorities?

(The Scottish Government is suggesting that reports on progress should be sent from public bodies to Parliament or the Scottish Government, not to an independent body of experts)

Our Answer:

'Strongly Disagree'

"It is essential that an independent body is established to review and assess progress against framework rights and objectives. This independent body would apply the rights set out in the framework legislation, including the right to food, health and a healthy environment, recognising the role of our food system in climate change, environmental destruction, waste, land use and food insecurity, and ensure that adequate progress is made."

Question 4: To what extent do you agree with the proposal for targeted legislation relevant to specific policy areas as an alternative to a single piece of legislation?

(It sounds as if they are asking if instead of framework legislation which would establish rights or principles that would then apply to everything that was done thereafter, would it be better to have separate pieces of legislation on different areas of the system. That would be the norm and would miss the critical opportunity that the Good Food Nation approach presents us with).

Our Answer:

'Strongly Disagree'

"It is essential that the first step is to establish overarching framework legislation setting out key rights, principles and objectives, which will guide future, more specific, legislation. The key rights, to food, health, a healthy environment etc referred to in answer to Q1 above, must be set as the priority objectives, and everything that is done thereafter must be done to promote those objectives. The Good Food Nation policy has created a critical opportunity for Scotland to view the food system holistically, and to make essential changes applying human rights and environmental justice that will result in Scotland becoming more fair, just and equitable for all."