The first National Good Food Nation Plan has finally been published on 18 December 2025, just over 3 years since the Good Food Nation (Scotland) Act was enacted. At first glance, this final version does not seem to depart significantly from the one laid before the Scottish Parliament back in June. The Scottish Government helpfully issued a statement explaining how the recommendations of the various committees who scrutinised the draft were taken into account, so add this to your next bedtime read! The long-awaited National Good Food Nation Plan is of course a significant step in delivering a systems approach to food policy in Scotland. That being said, much of the heavy lifting around implementation rests on sections of the Act that still need to be triggered.
Earlier this month, the Rural Affairs and Islands Committee did not recommend (5 members against, 4 in favour) the adoption of draft regulations setting out the specific policy areas covered by the "have regard" duty of the Act. The Cabinet Secretary confirmed during Portfolio Questions (video below) that the legislation had been withdrawn, and it is unlikely a new draft will be submitted before the Scottish Parliament elections in May 2026. This essentially means that Scottish Ministers are under no legal obligation to consider the new Good Food Nation plan and its outcomes when making decisions about food-related issues. Officials have already indicated that work is underway to ensure that policy teams across Government are aware of the Good Food Nation ambition, but until the specified functions come into force there will be little incentive for these considerations to be made public. This lack of transparency extends to the Ministerial Working Group on Food, which is meant to have been active for several years now, but has no publicly available terms of reference or minutes (unlike other groups).
Watch the Meeting of the Parliament recording
Another missing piece to this puzzle is the requirement for local authorities and health boards to prepare their own local plans, which is yet to come into force. The Cabinet Secretary indicated that the Government would now turn its attention to the local plans, however there has been no formal announcement as to when the formal commencement may be triggered. Stakeholders have repeatedly asked for clarity about this, including details on the level of resources that may be allocated to local authorities and health boards to develop and implement their plans. The upcoming budget will hopefully provide further clarity on this, although it remains to be seen whether any new commitments will survive the election.
This level of uncertainty comes at a time when the Scottish Government is also dealing with rough weather in other food-related policy areas. Yesterday, several environmental organisations have announced their withdrawal from the Agricultural Reform Implementation Oversight Board (ARIOB) and the Policy Development Group (PDG), citing a growing lack of confidence with policy development and decision-making processes. Earlier this year, the outgoing chair of Public Health Scotland accused the food and drink industry of "shameful pushback" against efforts to improve the food environment. Indeed, despite committing to tackling promotions on foods high in fat, sugar or salt as early as 2017, the Scottish Government only managed to introduce regulations to this effect this October. More importantly, the new instrument simply aligns to existing initiatives already in place in England and Wales, despite calls for stronger and clearer regulations.
As the pressure increases in the run up to the Scottish Parliament elections, the Good Food Nation agenda is bound to remain highly relevant. In January, multiple Committees will be scrutinising the draft Climate Change Plan. We will be keeping an eye on these debates, and in particular sessions of the Rural Affairs and Islands Committee during which the Scottish Government will need to justify its decision to divert from the UK's Climate Change Committee's advice on agriculture and peatlands.