House of Commons EFRA Committee – Food Security Inquiry

Written evidence submitted by Dr Kelly Parsons, research associate at the MRC Epidemiology Unit, University of Cambridge.

Introduction

My research interests are food systems and policy, with a particular focus on the procedural aspects of food policymaking or ‘food governance’, including: how policy is made; the institutional structures of government; and the tools which can be used to connect policy, including cross-cutting national food strategies.

I have been requested to provide evidence specifically on:

-          Henry Dimbleby’s National Food Strategy Independent Review

-          the Government Food Strategy published earlier this year

-          how Government sets food policy

As such, this evidence submission focuses primarily on Q4, on the Government’s food strategy paper. The content of the submission is also indirectly relevant to Qs 1-3, and 5-6, in that it addresses the government’s approach to food policy, including policies and policymaking processes related to resilience, food prices, access to healthy and nutritious food, food security etc. Under a broad definition of food security[1] - encompassing activities and risks across: food supply, domestic production and trade; environmental influences; affordability and access to healthy food; safety etc - food security policy and food policy are largely overlapping. 

I use the label ‘National Food Strategy Independent Review’ (NFSIR) to refer to Henry Dimbleby’s National Food Strategy, and the ‘Government Food Strategy’ (GFS), to refer to the policy paper published by the Department for Food, Environment and Rural Affairs (DEFRA) in 2022.

Executive Summary:

• Evidence suggests the impact of the GFS is likely to be weak, due to shortcomings in both its substantive content (how the policy issue being addressed is understood, and the policy measures proposed to tackle it) and the procedural arrangements for the policy (the process for developing the policy, and for its implementation and monitoring).
• In theory, a broad, overarching national food strategy is an opportunity to address food systems holistically, and bring the range of policy activities related to food together in one place, both to 1) raise food higher up the policy agenda, and 2) to make sense of how it all fits together and better coordinate the different decisions and policies. However national food strategies have often been developed with holistic ambitions, but ended up prioritising supporting and growing a country’s agri-food sector over other objectives targeting human and planetary health. The GFS risks falling into this camp.
• In its understanding of the issues, the NFSIR offers a detailed and thoughtful explanation of why change is needed to address the major issues facing the food system, and of the systemic nature of food issues, this systems perspective is less evident in the GFS, and its analytical basis is unclear. And while the GFS does include some important recognition of the problems, but this is not reflected in the policy measures proposed. The NFSIR focuses on the harms the food system does to our bodies and the environment, whereas in the GFS the balance of focus on food system outcomes leans more towards the growth of the food sector.
• On substantive measures, the NFSIR contains a robust set of recommendations for policy measures to be implemented to address food system challenges, covering a range of innovative and existing policy tools. Many of these recommendations have not been taken up by government in the GFS, or are deferred, to be explored through collection of further evidence, or following consultation, with no rationale provided for why. Because of the way the GFS is written, it is not always clear whether it is referring to government aspirations or concrete policy measures, or whether the actions being described are existing policy measures or new ones.
• On procedural measures, the NFSIR recognises the flaws in the current approach to food policymaking and proposed a package of measures to improve it, including a Food Bill; better reporting; an expanded role for Food Standards Agency (FSA)
• ; and support for local government food plans. By comparison, the GFS approach is weak, with little detail on how the policy will be implemented and without the procedural tools to ensure it happens
• The approach to policy development and design taken in the GFS does not compare favourably to established principles of good policymaking, the NFSIR performs better. However, both strategies are poor in terms of transparency on the rationale for recommendations, including a failure to provide the reasoning why policy measures were discounted during the process of developing a set of actions.
• Evidence suggests that national food strategies alone are not robust enough measures to shape food policymaking. Other countries which have developed food strategies have also introduced other mechanisms, such as bodies, to support the policy.
• The current government advisory bodies on food are dominated by the food industry, but given the current crisis, food insecurity should be a focus, and beyond this advice should represent the full range of food system actors and issues, including human and planetary health.
• The importance of a political champion on food in Government has been identified, but is not clear who, if anyone, is currently championing the importance of food issues, and food policy, at the heart of government, and the high number of ministerial changes in recent months are likely to undermine the potential for strong political support for prioritising food issues.[2] In the absence of political leadership, a legislative approach, such as the Food Bill recommended in the NFSIR, and recently passed in Scotland, could support the status and political prioritisation of food as a policy issue.
• Evidence suggests that tackling food policy from an embedded position within a department which is responsible for only part of that system, such as DEFRA, can create a barrier to collaboration, especially if departments are not deemed to have the clout to direct other departments to act. An alternative to embedded responsibilities with a sectoral department would be to create a body in central government, or an independent body, though both have their associated challenges.

• Based on the submission, recommendations for the Committee to consider include requesting from Government: a formal response outlining the rationale for the recommendations which were, and were not taken up from the NFSIR, the resources (including staff and budgets) in place to deliver the GFS, and the action/implementation plan it will utilise; details of current mechanisms being used to coordinate policy, and in particular on food insecurity; details of how it plans to support local food partnerships and work with the Devolved Administrations on food policy. And recommending that Government revisit and implement the package of measures proposed in the NFSIR; and establish a body to support coordination and a body to enable participation in policymaking by a large range of food system stakeholders.

Q4: How will the proposals in the Government’s food strategy policy paper affect

1. the resilience of food supply chains?;
2. ii. the agri-food and seafood sectors?;
3. iii. access to healthy, nutritious food?

Evidence on successful policymaking, and on food policymaking in particular, suggests the impact of the GFS policy paper proposals on food system resilience, the food sector, and access to healthy nutritious food is likely to be weak, due to shortcomings in:

• the substantive content (how the policy issue being addressed is understood, and the policy measures proposed to tackle it)
• the procedural arrangements for the policy (the process for developing the policy, and for its implementation and monitoring).

There is a risk the GFS is added to the list of national-level food policies which have been developed with high-level ambitions, but undermined by poor design and/or implementation, as documented in historical policy analyses of England’s food policy.[3]

This represents a missed opportunity, not only for England, but also for food systems and policy globally, where there is considerable interest - as evidenced by the UN Food Systems Summit countries in their national pathway documents - on how to tackle food systems change effectively.[4]

The short comparative policy analysis of the two strategies below details their substantive and procedural proposals, based on my understanding of the contents of the two strategies, against their aims to address food system challenges and catalyse change.

How the policy issue - food systems - is understood

As articulated in the NFSIR and many major food systems reports, there is wide agreement on the need to tackle food systems due to their negative impacts on human and planetary health, and to do so through a ‘systems approach’, which recognises the connected nature of the issues and related policies.[5]

The below depiction of the food system shows the chain that brings food from farm to fork, along with the interactions between the chain and the interconnected economic, political, environmental, health and social dimensions where the problems lie (problems for which food policy solutions are needed). The figure illustrates both the range of outcomes and influences on the food supply chain, and the need for coherent action in the system, given that:

‘When specific food policy solutions are implemented, the interconnections in the system mean all dimensions are affected, directly and indirectly, intentionally and unintentionally. It is only when the food system is considered from this holistic perspective that genuinely effective solutions to current (and future) food problems become possible.’[6]

In theory, a broad, overarching national food strategy is an opportunity to:

• Bring the range of policy activities related to food together in one place, both to 1) raise food higher up the policy agenda, and 2) to make sense of how it all fits together and better coordinate the different decisions and policies;
• Address sometimes competing economic, social, health and environmental policy priorities related to food, for example the kinds of food which are sold, advertised or imported to benefit the economy vs the kinds of foods we should be producing and eating to keep us healthy, or to reduce climate change impacts.[7]

The concept of ‘policy coherence’ helps to articulate the importance of understanding how food policies interact.[8]

However, addressing health, environmental, economic and social outcomes in one policy is challenging, and many attempts to do so have ended up prioritising some outcomes at the expense of others. National food strategies have often been developed with holistic ambitions, but ended up prioritising supporting and growing a country’s agri-food sector over other objectives targeting human and planetary health.[9] One of the reasons for this is when holistic strategies are led by departments with particular sectoral interests, as discussed in more detail at the end of the submission.

The NFSIR offers a detailed and thoughtful explanation of why change is needed to address the major issues facing the food system: climate change, biodiversity loss, land use, diet-related disease, health inequality, food security and trade. It groups its objectives under four headings: Escape the junk food cycle to protect the NHS; Reduce diet-related inequality; Make the best use of our land; and Create a long-term shift in our food culture. The objectives are dominated by pressing health and environmental considerations, rather than food as an economic sector, and the review does not directly address the issue of livelihoods, and pay and conditions in the food sector. It focuses less on the economic growth of the food sector than national food strategies or plans traditionally tend to.[10]

The NFSIR includes a strong analysis of the systemic nature of food issues, informed by systems science, and the concepts of system lock-ins and feedback loops:

‘Henry drew heavily on work by Donella Meadows on systems thinking which characterises systems and ways of intervening in them. This provided a useful framing for thinking about the food system. The diagnosis presented in the Strategy was based on describing two feedback loops: one reinforcing feedback loop named the ‘Junk Food Cycle’ and one missing feedback loop named the ‘Invisibility of Nature’. [11]

This systems perspective is less evident in the GFS, partly because it spends less time on problematisation. The GFS itself states that ‘it is not a comprehensive summary of everything that government is doing to improve our food system’[12], though it does not explain why. It does describe the NFSIR as a ‘powerful analysis’. An analysis of an earlier leaked version of the GFS against the published paper suggests the following line was removed:

‘This Government Food Strategy responds to the findings and recommendations of the independent review; we accept much of the analysis and do not repeat it here. We also accept the majority of recommendations’[13]

Without clarity about the analysis the policy is based on, it is difficult to assess how the issue the paper is addressing is being defined. The GFS does include some important recognition about the problems, for example that:

• the link between deprivation and dietary outcomes is not merely about price, but other factors such as equipment, time, skills, the stresses and pressures of poverty etc are important;
• choosing the healthier option is more challenging than the healthy option, and there has been a problematic growth in takeaways;
• there is a role for government in creating a level playing field through regulation.

But the policy measures proposed do not necessarily reflect the problem statement, as discussed further below.

The balance of focus on food system outcomes in the GFS also leans more towards the productivity of the food sector, for example the first priority is: ‘a prosperous agri-food and seafood sector that ensures a secure food supply in an unpredictable world and contributes to the levelling up agenda through good quality jobs around the country’. Improving economic growth for the sector, including around jobs and profitability, is more dominant in the GFS, and health outcomes secondary, for example. The GFS notes that:

‘The Department for Health and Social Care (DHSC)’s forthcoming health disparities white paper will also set out further measures to reduce obesity by setting out our approach to working with the food industry to create a healthier food environment for all and investing in innovative approaches to address weight and diet related ill health.’[14]

Certain activities from the NFSIR are also being addressed under the Levelling Up agenda:

‘As announced in the levelling up white paper, we will invest in enabling primary care to undertake a pilot programme to improve diets through the Community Eatwell programme. This will build on the growth of social prescribing within primary care networks, the additional roles available via the Additional Roles Reimbursement Scheme and consider the role of those staff in primary care who have completed the Healthy Weight Coaches training. Further details will be published in the health disparities white paper.’[15]

Evidence - for example, on Australia’s experience of developing a cross-cutting national food plan - suggests hiving off particular food system objectives and actions to forthcoming policy projects risks the issues in question falling between the cracks in government, if these projects do not materialise, or are based on an alternative analysis of the problem.[16] A mechanism to embed responsibility for delivery on the different actions related to food could support the monitoring of activities and transparent communication of progress and may help mitigate these kind of fragmentations and loss of momentum, as discussed further below.

Substantive Policy Measures

As noted above, a number of major food systems reports from consortia of leading scientists have concluded that ‘transforming food systems will require a bolder approach to applying policy levers than has historically been taken, due to the scale and urgency of the challenges’ and that ‘innovative solutions to complex policy problems are required’.[17]

The need for an ambitious policy response is echoed in UK government documents including its National Pathway Document submitted to the UN Food Systems Summit of 2021, which talks about the UK’s ‘ambitious direction and commitments to changing the food system’:

‘The UK is developing comprehensive strategies to support a more sustainable, resilient, and affordable food system that enables people to live healthy lives and protects animal health, welfare and the environment. These strategies will be shaped by comprehensive review of the food system and diverse stakeholder engagements to identify challenges, opportunities, best practise and define collective action.’[18]

While the focus does change slightly to emphasise production, prior to publication of the GFS, DEFRA Secretary of State Victoria Prentis described the forthcoming strategy as: ‘a once in a generation opportunity to create a food system that feeds our nation today and protects it for tomorrow’.[19]

Comparing the NFSIR and the GFS against the high levels ambitions for addressing food systems, the former is stronger than the latter. The NFSIR contains a robust set of recommendations for policy measures to be implemented to address food system challenges, covering a range of innovative and existing policy tools. It explicitly aims for interventions to prevent the ‘harms the food system is doing to our bodies and to the environment’.[20] Some of recommendations are individual measures - such as the sugar and salt reformulation tax - while others are packages of measures, such as around school food (‘Eat and Learn Initiative’). An analysis by the Food Research Collaboration details how the 14 key recommendations in fact involve 70 different recommended actions, and as such can be considered a ’comprehensive programme’.[21] Although, as noted above, it has less of a focus on food sector productivity and livelihoods.

As illustrated in Table 1, many of the NFSIR recommendations have not been taken up by government in the GFS, or are deferred, to be explored through collection of further evidence, or following consultation. In particular, more concrete measures such as a sugar and salt reformulation tax, and expanding free school meals, are not in the GFS. Deferment risks both loss of momentum and political support and fragmentation of actions. Because of the way the GFS is written, it is not always clear whether it is referring to government aspirations or concrete policy measures, or whether the actions being described are existing policy measures or new ones. This makes it difficult to assess how ambitious the GFS is, and to track its progress.

The alignment between the stated problems and ambitions, and the measures included - the ‘internal coherence’ of the policy - is also questionable in places. For example, on trade the GFS acknowledges the ‘government was elected on a manifesto commitment that ‘in all of our trade negotiations, we will not compromise on our high environmental protection, animal welfare and food standards’ and ‘how much the British public care about the standards of food on offer, no matter its origin’. But it rejects the NFSIR to address this by defining minimum trade standards and introducing a mechanism for protecting them.

This is not uncommon with national food strategies: they begin life with ambitious aims and often their problematisation introduction is robust, but actions to be taken are weak in comparison.

Table 1: Comparison of Policy Measures

Author, from Parsons and Barling 2021; MacMillan 2022[22]; Sustain 2022[23]

The GFS also contains a range of activities in addition to those in Table 1, though it is not clear whether these are aspirations, or new or existing commitments.[24]

The analysis above compares the proposals in the proposals in the strategy documents. Whether the proposals in GFS are actually being actioned is not clear, and it is possible that the gap between the two strategies is even wider than indicated above.

Procedural Measures to Support Food Policymaking

Calls for a more joined-up or connected approach to food policy have been made for several decades.[25] In part, this is because the policy responsibilities related to food are spread across a range of government departments. One review identified at least 16 departments with a role:

Source: Parsons (2020)[26]

In addition, many food-related issues cross the remits of multiple government departments, and require joint working. Examples identified in research on food policy in England are illustrated in the diagram below.

Source: Parsons 2020[27]

A great deal of effective coordination takes place between these different departments and other organisations and we should be wary of blanket criticisms that food policy is not joined up,[28] but there are also coordination failures: one example being the lack of prioritisation of healthy diets in many policy decisions.[29] The NFSIR details several requirements for coordination, including: ‘the need to align trade policy with agriculture policy; the need to ensure policy interventions are coherent with the government’s dietary guidelines; and the need for ‘joined-up thinking across government’ to ‘create a new deal for livestock farming’. The report also notes a public desire for a more unified approach to food system governance: participants in its public dialogues emphasised the need to ‘include more formal arrangements for bringing government departments together to plan strategically for food issues on, for example environment, health and social support measures’.[30]

Research published in 2021 on how connected England’s food policy is, based on interviews with those working inside and outside government, highlighted a range of examples of connected working, including on: animal and plant health, anti-microbial resistance, and in the development of the childhood obesity strategy. While disconnections were identified on issues such as: climate change; nutrition, obesity and income; agriculture and public health, and hunger.[31]

Fragmented policy responsibilities for food can result in a number of different problems:

1. Coordinating action across multiple departments. Policy responses to major social challenges such as obesity and healthy diets, and climate change, require multiple departments to act in a coordinated way. They requires the primary department responsible to drive forward actions in others, and for secondary departments to deliver on objectives which may not be the primary ones they are being measured against, and which there may not be any effective monitoring of. This is hard to do, as the history of attempts to create joined-up approaches to many issues – such as health inequalities – illustrates.[32]
2. Tensions between objectives of one department and another. We have seen this clearly with trade policy and domestic agriculture, and the conflicting aims of Department for International Trade and DEFRA around trade deals. Another example is around healthy eating – the tension between the need to improve food environments to tackle diet-related ill health, and the sale, advertising and sponsorship of foods we should be eating less of – with the recently announced delays on interventions to support healthy eating, such as the junk food advertising ban a case in point.
3. Issues falling through the gaps between responsibilities. Food insecurity is the classic example of this problem. For those outside government it is perceived to be an issue which is kicked from one department to the next, Department for Work and Pensions (DWP) to DEFRA, DEFRA to the Department for Education (DfE) or the Department for Health and Social Care (DHSC), and there have been calls for a minister for food to address food insecurity more coherently.[33] A recent example is Birmingham City Council asking for an independent national commissioner to improve national level government action on food insecurity and the cost of living crisis, noting it is a cross government challenge crossing DEFRA, DHSC, DWP and the Department for Business, Energy and Industrial Strategy (BEIS), but there is limited evidence of a coherent response.  Issues can also fall through the gaps when actions are passed from one strategy to another, such as from the Food Strategy to the Health Disparities White Paper, which is yet to be published. In Australia a similar approach was taken to hiving off health actions from the National Food Plan to a proposed ‘National Nutrition Strategy’, but the latter was never produced.[34]
4. Overlapping, Redundancy. A good example is around evidence. Stakeholders report being asked to deliver the same kind of evidence by multiple departments, and that one department is not aware of similar work being done in other parts of government, and data is siloed.[35] Another example is when there are multiple departments working on one issue, for example labelling.[36] The Data Transparency Partnership may support a more connected approach to the different labels and outcomes that consumers have to deal with, and whether it will attempt to combine both health and environmental considerations for example.
5. Lack of Profile and Progress. Finally, there is the problem of food being relevant to many but a priority for few. The NFSIR captured this nicely when it described ‘responsibility for decision making on food as being spread, like a thin layer of jam on toast, across government.’ Food being a second order priority for departments contributes to a lack of profile and progress.

Beyond the need for improved coordination and coherence, food policymaking has been criticised for being short-termist; opaque and low on the political agenda. A new approach to governance is needed to address these shortcomings.[37] The governance approach proposed in the NFSIR is considerably more robust than that in the GFS.

Table 2 compares the proposals for procedural tools to ensure successful implementation of the NFSIR, and to improve food policymaking more broadly, to the governance approach detailed in the GFS. It shows that many of the proposals from the NFSIR were not taken up in the GFS.

The NFSIR recognises the systemic nature of food systems, and the fragmented nature of food policymaking. It also prioritised, and took a relatively holistic approach to, governance; proposing a package of measures to improve food policymaking. These include: a Food Bill; a State of the Food System Report; Good Food Action Plan; Mandatory reporting of food sales and waste by companies; Expanded role for Food Standards Agency; Reference Diet to be applied by public bodies and in food procurement; What Works Centres and Data Programme; support for local government food plans. This is positive, because it recognises the importance of focusing not only on what the policy wants to achieve, but how this will happen.

Table 2: Governance approach in the NFSIR vs GFS

Source: Author, drawing on Parsons and Barling (2021) and the GFS[38]

The development process of the NFSIR involved a dedicated workstream on the governance arrangements for connected food policymaking, and how to prioritise, join-up and make progress on the range of policy issues included in the terms of reference for the review. The team’s recommendations on a new governance structure for food policy were informed by advisors with direct experience of working on earlier national food strategy projects, and experts in government and policymaking. A conscious effort was made to address the pitfalls associated with previous national food strategy projects, for example how shorter-term political cycles can undermine progress and long-term policymaking[39]:

‘One of the recommendations was specifically aimed at creating institutional arrangements which would embed long-term system change within the business of Government. This included recommending a Food Bill be introduced to parliament which would embed reporting on progress in delivery of the strategy within a non-ministerial department (The Food Standards Agency).’[40]

The NFSIR governance proposals demonstrate a solid understanding of the issues of food governance, as summarised here by Parsons and Barling (2021):

‘Many weaknesses which have been identified in the current food policymaking arrangements are addressed in the NFS. The proposals for What Works Centres address the issue of poor institutional memory and lack of policy learning over time, whereby new policies are introduced without reference to what has been attempted previously and whether it was successful. The Good Food Bill supports long-term thinking - and acting - on the food system, and can help alleviate challenges around short-term electoral cycles which can interrupt and reset progress. Although it will enshrine largely procedural rather than any substantive policy commitments. A new more rigorous and transparent approach to evidence, and data on the food system, could also improve monitoring of progress, and inform more effective policy design. The duty for Local Authorities to produce a food strategy addresses the current patchwork approach, whereby some cities have food plans while others do not’.[41]

By comparison, the GFS approach is weak, with little detail on how the policy will be implemented and without the procedural tools to ensure it happens. For example, while the GFS recognises that ‘DEFRA is responsible for food policy’ and that ‘the policy levers that influence the food system are dispersed across government’ and states that to implement the strategy, it will: join-up within government to collectively drive progress; work closely with the DAs, reflecting that the food system operates on a UK-wide basis; and champion a collaborative approach by working in partnership with industry and civil society[42], no details are provided on how this will happen in the GFS report itself. Information identified elsewhere suggests there is a dedicated team working on the GFS, and a ‘cross-government food group’.[43] But it is not clear what resource there is involved, which departments are involved, and how contributing departments are being incentivised to contribute. Evidence suggests it is challenging for a sectoral department to drive forward a holistic whole-of-government approach to food, as discussed later in this submission.

The NFSIR recommendation for a Food Bill is rejected in the GFS:

‘Our assessment is that we have existing powers in primary legislation to implement the measures in this strategy. However, we will seek primary or secondary legislation as required to achieve our objectives. Before doing so, we will consult fully on all policy changes in the usual way.’[44]

The NFSIR has a specific recommendation with regard to the development of (participatory) local food strategies:

‘Local Authorities to be required to put in place a food strategy, developed with reference to the goals and metrics set out in The Plan, and in partnership with the communities they serve’.[45]

The value of local food partnerships is recognised in the GFS:

‘We will learn from their approaches and work to understand and identify best practice in addressing food affordability and accessibility to healthy food.’[46]

However, no detail is provided on how this might happen, or if any funding will be forthcoming to support this activity. Without this, the local food sector will continue to rely on limited funds and the goodwill of volunteers, and there will be a patchwork of different local food approaches across the country. The Welsh Government’s recently announced £3 million funding to support the development of cross-sector food partnerships in response to the cost of living crisis would be a useful starting point for exploring options for economic support.[47]

Approach to Policy Development and Design

There is a significant body of evidence across both the policy sciences literature, and from experts on the business of government including the Cabinet Office, Institute for Government and the National Audit Office, which establishes the fundamentals of ‘good’ policymaking, and the factors which contribute to successful policies more broadly. Many of these principles have been circulating for decades.[48] They include: well defined and framed policy issues, and target outcomes; a long-term approach; robustly-assessed and innovative recommended actions, based on evidence and informed by lessons from other countries and past experiences; inclusive participation of those who will implement and be affected; joined-up approach with a holistic view, and consideration of the appropriate management and organisational structures needed to deliver cross-cutting objectives, with joint working arrangements between departments clearly defined and understood; plans in place for review/monitoring and evaluation.[49] Other factors include the estimated costs of action, and having a dedicated budget assigned to support implementation.[50]

In the case of national food strategies in particular, there is evidence which suggests the factors influencing their development and enactment. These include: who the originating actor/lead department is; the terms of reference set; the problem definition; input from relevant government departments; approach to advice and consultation; mechanisms put in place to support the policy development, and its enactment; the budget for development, and for enaction; the policy measures selected; and the plans for implementation and monitoring. Having political support for a policy is a widely agreed determinant of success.[51]  While a full analysis of the two strategies against this set of influences has not been conducted, the evidence presented in this submission suggests the GFS is likely to compare less favourably to the NFSIR across many of these categories.

For example, the NFSIR conducted a full evidence review, and a series of engagement activities with citizens.[52] In the NFSIR, the recommended policy measures are clearly laid out, along with supporting evidence, details of who is responsible for delivering, and financial considerations around costs and budgets:

‘The team deliberately tried to make the recommendations few in number (a total of 14) and to be extremely specific about their cost, who should implement them and the mechanism of Government which should be used’[53]

A multi-pronged approach to setting food system and food policy targets and monitoring is proposed, as detailed in Table 2.

By comparison, the GFS is characterised by vaguer policy measures, and lack of detail on delivery, both in terms of who, timetable and costs. Civil society organisation Sustain has developed a framework of measures included in the GFS and has assigned these to the departmental actor responsible, based on information in the GFS paper and elsewhere, or on most likely candidate.[54] This is the kind of monitoring which should be designed in, and transparently communicated, as part of strategy development and implementation. The GFS commits to monitoring, but it is not clear what form this monitoring will take, and if the process will be transparent:

‘We will publish a report to monitor progress against the food strategy goals, listed in paragraph 10, alongside the next UK Food Security report and will continue to do so regularly at a frequency that allows trends to emerge, and dovetails with other relevant publications. This will draw on independent analysis from the Climate Change Committee (CCC), Food Standards Agency (FSA) and the Office for Environment Protection (OEP).’ [55]

The Strategy was planned to be a White Paper, which is usually the precursor to legislation, whereas what was published was only a policy paper.[56]

There are some areas where the NFSIR could have gone further in its governance recommendations for procedural measures. There are question-marks over how well it addresses the issue of coordination. And though the process of consultation itself was participatory, there is no recommendation for a mechanism which would embed participation of outside actors in policymaking, to address the need for a range of voices to be at the table when food policy advice is being sought by government.[57] Scotland’s approach, and the governance approach it takes around the recently passed Good Food Nation Bill, offers an interesting opportunity to consider what could be done in England[58], as do the approaches taken in other countries, for example Canada’s national food policy advisory board.[59]

One of the weaknesses of both the NFSIR and the GFS is transparency on the rationale for recommendations – including a failure to provide the reasoning why policy measures were discounted during the process of developing a set of actions. This makes it challenging to identify whether particular policy measures were reviewed and considered infeasible or ineffective, or simply not considered at all. The rationale behind the content of the strategies, and knowledge of what works in terms of measures, remains in the hands of a limited number of members of the drafting teams.

Given the GFS is a response to an independent review commissioned by the government itself (a review which involved significant resources and input from stakeholders), it is disappointing that there is little connection made between the review and the response. There is no indication whether NFSIR measures were considered, but not taken up because they:

• were deemed politically infeasible because they didn’t align with current political ideology or values;
• were considered to be being dealt with elsewhere in government;
• were subject to a rigorous criteria and evidence review and not deemed to be effective options;
• would cost too much.

This may be due in part to the approach to consultation taken in development. The NFSIR took a highly consultative approach in some senses, but there is no formal analysis of the evidence provided/recommended actions proposed by stakeholders. The GFS does not offer any indication of what basis the recommendations are drawn from, and does not formally confirm the analysis outlined in the NFSIR.

There are existing examples of good practice which could be followed. For example, the model for government responses to select committee recommendations, and the approach taken to consultation by the Food Standards Agency, whereby responses to consultees are prepared and made publicly available.[60]

Improving transparency on how recommendations are reached, and why particular issues are not included, would be of benefit to stakeholders who were involved in feeding in suggestions to the process, and also to other national governments – such as in Wales and Northern Ireland – which are in the process of developing their own national food strategies. Doing so would enable more effective use of government resources.

Given evidence on the influences on policy decisions beyond evidence, including political values and ideologies, habits, lobbyists and pragmatism[61], developing a set of recommendations grounded in economic and political realities is sensible. However, censoring recommendations according to feasibility criteria, with no transparency on the reasoning via an official consultation response, runs the risk that less ‘landable’ policy options - potentially more effective or transformative measures - become lost in the process. If the landable policy options are not taken up, they nevertheless become a baseline for what should be done.

A more effective approach to managing evidence beyond national food strategies would help to mitigate against problems of this nature. There is a large amount of evidence of ‘what works’ around healthy sustainable diet shift, for example, which evidence-users find difficult to access and implement because it is fragmented, and sometimes contradictory.[62] The NFSIR recommended government fund two What Works Centres - focused on farming, and diet shift - which would address shortcomings in the current approach to food systems evidence, and support policymakers and practitioners to act on improving health and sustainability, but only one, focused on farming, was picked up in the GFS.

Other considerations related to national food strategies

The following section outlines some further considerations when evaluating the effectiveness of national food strategies, and food policymaking, which have not been covered above.

1. National Food Strategies alone are unlikely to improve food policymaking

National food strategies are only one of a range of procedural policy tools which can be implemented to connect policy.[63] These tools range from softer tools like day-to-day personal connections, and more issue specific groups – for example on childhood obesity – at one end of the spectrum, to harder tools such as dedicated food bodies, food legislation, or food ministries at the other, as illustrated by the below taxonomy (Parsons 2022):

Source: Parsons (2022)[64]

Evidence suggests that national food strategies alone are not robust enough measures to shape food policymaking. Other countries who have developed food strategies have also introduced other mechanisms, such as bodies, to support the policy, though the evidence on how these have performed is weak.[65] There are a number of existing bodies in use for connecting various activities related to food in government in England, and for connecting government with those working in the sector outside government, though it is challenging to find details of who is involved, how often they meet, and what is discussed.[66] This makes is difficult to assess how effectively they are working together, and whether the right issues are being addressed (for example whether health and environmental priorities are being prioritised).

Evidence on what they do, and how they influence policy, is poor, but nevertheless there is a question-mark about how representative these bodies are, given the membership appears to be dominated by representatives of the conventional private sector supply chain. For example, research on the food policy response to the Covid-19 crisis suggests the membership of the government’s advisory bodies skews the advice provided towards mainstream supply channels, and fails to sufficiently consider the system as a whole – overlooking the role in resilience of the independent food sector and community food organisations, or coherence of actions with health and environmental policy priorities.[67]

In the current climate, institutional architecture is needed to prioritise and support work on food insecurity. Birmingham City Council have recently called for an independent commissioner to address food insecurity and the cost-of-living crisis. During the first phase of Covid, there was a specially created Food to the Vulnerable Ministerial Task Force, a cross-Whitehall ministerial taskforce led by DEFRA Secretary of State Victoria Prentis, with membership from departments including DEFRA, Housing Communities and Local Government as was, DWP, and ministers from the Devolved Administrations. There was also a Food Vulnerability Stakeholder Group – attended by 100 individuals with representation from across Whitehall, Local Authorities, and charities.[68] Part One of the NFSIR recommended the task force be kept in place for a further 12 months (to July 2021), but it is not clear if this recommendation was acted on, or if that group still exists. If not, and given the current crisis of food insecurity, a forum which is focused on food insecurity, which looks beyond the food industry perspective on food supply, and links up national and local level action to tackle this crisis, should be instigated.

Beyond food insecurity, examples from other countries, and historical approaches in England, offer inspiration for the different ways that food bodies with more of a holistic focus on food systems can be designed.[69] For example, to support its national food policy, Canada created the Canadian Food Policy Advisory Council, a multidisciplinary group of stakeholders, selected to ‘to bring diverse social, environmental, health and economic perspectives’[70], and the approaches in Brazil and Scotland are also good examples to learn from.[71]

The importance of leadership, long-term thinking

One of the key success factors for successful policymaking is political will and leadership. Food policies, and cross-cutting national food policies in particular, are more likely to be effective is they have a champion at a senior level within government. At the outset of the NFSIR process, the Secretary of State for DEFRA Michael Gove arguably represented a champion who recognised the impacts of the food system on health and the environment. This was reflected in the Terms of Reference for the NFSIR, which were to design recommendations to ensure the food system: “Delivers safe, healthy, affordable food; regardless of where [people] live or how much they earn” and “restores and enhances the natural environment for the next generation in this country.”

One of the documented lessons learned from the NFSIR process was the importance of a political champion in government[72]:

‘Of utmost importance is ensuring the Strategy has, once published, a top-level political sponsor to ensure its passage through Government is smooth and to ensure that the recommendations cannot be ignored.’[73]

This importance is reiterated in research findings on government policymaking, where interviewees within government note that:

‘it’s all about leadership’…because… ‘leadership matters more than the machinery of government that follows it’. Another agreed: ‘it’s all really, really simple – you need strong political support, sustained political support’, noting that, for the work on childhood obesity ‘it helped having the same Health Secretary for what is one of the longest periods of time’. Another went further, arguing ‘it’s not a governance issue – I would say [it’s] a real lack of leadership, rather than governance, that nobody in government is really trying to make the case that we will have to move in this direction, not today but even in five years’ or ten years’ or 15 years’ time’.[74]

It is not clear who, if anyone, is currently championing the importance of food issues, and food policy, at the heart of government, and the high number of ministerial changes in recent months are likely to undermine the potential for strong political support for prioritising food issues.[75]

In the absence of political leadership, a legislative approach, such as the Food Bill recommended in the NFSIR, and recently passed in Scotland, could support the status and political prioritisation of food as a policy issue.

The challenges of driving food policy from a sectoral department

One of the challenges for food policymaking is deciding which organisation should oversee an issue which stretches across multiple departmental remits. Evidence suggests that tackling food policy from an embedded position within a department which is responsible for only part of that system, can create a barrier to collaboration, especially if departments are not deemed to have the clout to direct other departments to act.[76] Given lessons from previous national food strategy projects, it is unsurprising that there was shift in focus from the NFSIR prioritisation of health and environmental issues, to the dominance of food production in the GFS, given the latter is a DEFRA-led paper. There is precedent for this course of progression with the 2008 Food Matters Report, developed by the Cabinet Office, focusing on health and environmental outcomes, which - when passed to DEFRA for implementation - shifted the priorities towards production, food security.

The NFSIR proposed to utilise the FSA’s role as a non-ministerial department to monitor progress on delivering the strategy:

‘One of the recommendations was specifically aimed at creating institutional arrangements which would embed long-term system change within the business of Government. This included recommending a Food Bill be introduced to parliament which would embed reporting on progress in delivery of the strategy within a non-ministerial department (The Food Standards Agency).’[77]

Expanding the role of the FSA has the potential to provide a more effective institutional arrangement for making progress on food policy, as long as adequate resources are in place:

‘The FSA’s existing obligation ‘to promote the consumer interest would be redefined in law to include our collective interest in tackling climate change, nature recovery and promoting health, in the resilience of our food supply, and in meeting the standards that the public expect’. Adapting the FSA is justified as less costly, and less confusing, than a whole new body, and the FSA is positioned as well-placed to take a ‘whole-systems perspective’. It remains to be seen whether the FSA’s historic focus on the post-farm gate food system, and on consumers, and proposed remit for diet shift can deliver a holistic view, particularly given the remit of DEFRA across some of the collective interest areas, including nature recovery, and resilience.  Also, will the FSA have the capacity, and the necessary budget to take on these tasks successfully? Additional resources required for monitoring the policy measures recommended are acknowledged in the Strategy, which notes for example that if responsible, the FSA would require the recruitment of more Environmental Health Officers, ‘at considerable cost’.[78]

An alternative to embedded responsibilities with a sectoral department would be to create a body in central government, or an independent body, though both have their associated challenges.[79]

Recommendations for the Committee to consider, based on the evidence presented above

Request from Government:

• A formal response outlining its rationale for the recommendations which were, and were not, taken up from the NFSIR
• Confirmation of whether the analysis as laid out in the NFSIR is formally accepted, and if not, what alternative analysis the GFS is based on
• Information on the resources (including staff and budgets) in place to deliver the GFS
• An action/implementation plan for delivery of the GFS, including responsible department and timeframe, and details of the plans for monitoring and tracking progress, including when the first monitoring report will be published
• Details of any dedicated mechanisms to support delivery of the GFS, such as a cross-government group (including its membership and schedule of meetings, and plans for publication of any discussions), and what the arrangements for joint working are
• Whether there are any other forums currently in place to support connected working on food policy, alongside groups such as the F4 Group, Food Industry Resilience Forum, Retailer Forum, Food and Drink Sector Council, and what consideration has been given to advisory input beyond the food industry (for example on healthy diets, sustainability)
• Whether there is any cross-government body in place on food insecurity
• What plans it has to support and work with local food partnerships
• What arrangements are in place to coordinate and share learning with the devolved regions on food policy

Recommend that Government:

• Revisit and implement the package of measures proposed in the NFSIR
• Establish a body to address food policy coordination, drawing on international best practice
• Establish a mechanism for food policy participation by stakeholders, drawing on international best practice

-ends-