Revocation of Commencement No 4 under the Good Food Nation (Scotland) Act 2022: a practical update for regulatory compliance and business planning in UK health and safety law

Revocation of Commencement No 4 under the Good Food Nation (Scotland) Act 2022: a practical update for regulatory compliance and business planning in UK health and safety law

What has changed

The Good Food Nation (Scotland) Act 2022 (Commencement No 4) Revocation Regulations 2025 revoke the Regulations that would have brought into force section 6 on 16 December 2025. As a result, section 6 will no longer come into force on that date. The change alters the intended timetable for introducing provisions under the Act and removes the anticipated obligations associated with that timing.

Who is affected

The revocation primarily affects organisations operating in Scotland that would have been subject to section 6 of the Good Food Nation Act. This includes businesses across sectors involved in food production, distribution, hospitality and retail, as well as public authorities and other bodies involved in policy and procurement decisions relating to food.

Why this matters for health and safety and regulatory compliance

There are no new duties arising from this revocation on the date it takes effect. However, the change signals a shift in the regulatory timetable and highlights the importance of robust governance and readiness for future policy developments. Organisations should maintain effective risk management practices and avoid assuming that earlier provisions will automatically apply. This is an opportunity to strengthen ongoing compliance programmes and ensure flexibility to respond to evolving food policy requirements in Scotland.

Key actions for duty holders

• Review current policies and risk assessments to ensure they reflect the existing regulatory position and do not rely on provisions that were due to come into force
• Monitor official updates from Scottish Government and sector bodies for any reintroduction of similar provisions
• Assess procurement, supplier management and food safety controls in light of the delayed timetable, and adjust contracts if necessary
• Strengthen governance and change management processes to remain capable of rapid response if regulations are reintroduced
• Consider aligning health and safety management with a recognised framework such as ISO 45001 to support ongoing regulatory compliance and risk control
• Communicate clearly with workers and stakeholders about the current regulatory position and how the organisation will respond to future changes

For systematic control of workplace risk and legal compliance, organisations may consider ISO 45001 occupational health and safety management. For health and safety risk assessments, see health and safety risk assessment. For competent person support, visit Competent Person support.

Enforcement and sanctions

There are no new penalties arising from this revocation. Enforcement expectations will continue to be governed by current Scottish law, with the focus on the existing duties that remain in force and on readiness for any future changes to the Act or related regulations.

Practical integration with management systems

organisations should align governance, risk assessment, supplier management and training with their existing management systems to ensure resilience against regulatory shifts. Integrating with a structured health and safety management framework such as ISO 45001 supports systematic control of workplace risk and legal compliance and helps organisations stay prepared for updated or reintroduced provisions.

Wrap-up

The revocation of Commencement No 4 for the Good Food Nation Act 2022 alters the expected implementation pathway and provides organisations with an opportunity to reinforce regulatory governance and risk management while remaining adaptable to future policy changes. Maintaining timely monitoring, clear governance and robust risk controls will help organisations respond effectively and demonstrate compliance when new requirements are introduced.