Coops Wales: response to Welsh Governments school meals standards consultation on 26/7/25. We publish a full response which spans a wide range of issues, stretching way beyond issues raised by the consultation. It is an issue our members have tracked for decades. If required, https://www.cancook.co.uk provides an obvious social enterprise solution.
The Governments summary does not list all who responded, including Coops Wales. This can be found at https://www.gov.wales/sites/default/files/consultations/2025-10/healthy-eating-in-schools-summary-of-responses.pdf
Q1 Strongly agree (a) Carbohydrates provided 3 times a week? A mistake in the schedule? This isn’t what the regulations should be. Is it not three different types of carbohydrates and carbohydrate should be served daily? After years of delay how was this allowed to slip through your system? Does this nurture confidence in governments capacity to manage improved public health?
(b) How will Welsh Government work with local government to implement proposed measures locally, whether services are provided in house or commissioned? Does each local authority have agreed/appropriate software to do so? This to include establishing a robust monitoring system, leveraging digital tools to streamline the task of food monitoring, and driving higher standards across Wales.
(c) How will Government encourage local authorities and Health Boards to utilise the school meals data for thoughtful consideration, thorough scrutiny, and prompt action?
(d) Expanding Welsh vegetable production is a welcomed initiative but only a small part of what is required. https://futuregenerations.wales/news/children-across-wales-should-have-more-welsh-vegetables-on-their-school-dinner-plates-urges-future-generations-commissioner-in-the-week-after-he-publishes-his-future-generations-report/
Q2 agree nor disagree “Processed meat products must not be provided more than once a week” What definition of processed will be used in these enforcing these regulations? Will meet be grass fed? Farmed fish?
Q3 AGREE nor disagree “Processed meat products must not be provided more than once a week” – what definition is proposed?
Q4 agree nor disagree. We are not persuaded that asking micro questions, such as this, will make much, if any difference unless training and skills are properly mobilised across many widely different catering operations.
Fundamental changes are required in the way in which school catering takes place. We know much variation exists between and within local authorities. Without labouring the point, serious attention needs to be given to catering and management skills, changed culture and different ways of approaching the delivery of healthy food in the kitchen. How can local authorities gain the capacity to address such issues without over wheening government? What’s to be done when staff have their hands turned tied behind the back and can’t use common sense on how to manage operational issues on a daily and seasonal basis.
Q5 agree nor disagree. See responses to questions 4. and 1 (b) and (c)
Q6 strongly agree. Will pupils be allowed to discreetly bring other drinks onsite? Just a school or Wales wide issue?
Q7 strongly agree. This is a widely heard common complaint and rightly so. Generally, we need to accelerate updating the 2013 Healthy Eating in Schools regulations that further support the inclusion of fresh, locally produced, minimally processed food, including portion sizes tailored to different age ranges and promoting healthier pupil eating habits, aligned with pupil well-being, sustainability, and climate goals.
Q8 agree nor disagree, Reflection: If we were starting from scratch from the early 2000’s, resources should have been invested in the main mid-day meal of the day. At that time Welsh Food Alliance argued that was essentially being pursued as a labour market, rather than as a public health measure. This combined with poor planning meant ‘cats were urinating on early milk deliveries’ and headteachers ‘arriving early make toast’. The time & effort spent in sorting out such issues would have been better spent in sorting out the main meal of the day, especially in secondary schools – See Q 16.
Q9 not sure. Whist regulatory standards related to healthy school meals in Wales do exist, compliance is not routinely monitored. See Question 1. comments. This means it is impossible to obtain a good picture of the current state of school food in Wales. More consistent and regular monitoring would incentivise higher standards – and provide valuable data which could help target improvements. There may be opportunities for better use of existing data (eg, from digital payment providers) as well as of well-designed digital tools to reduce the burden of school food monitoring. Why can’t this be centrally driven as in the case for breakfast provision?
Q10 not sure, Depends on the level of training, support and supervisor provided/required.
Q11 Good school meals provide government with a once in a life time opportunity to address growing health inequalities. However, there is no magic bullet in relation to obesity and overweight, and a wide range of varied responses are required at different levels of government.
With over 80% of food purchased by Welsh consumers from six UK based retailers it is essential we challenge obesity and overweight as far upstream to food chain as possible – not forgetting branded food service operations most likely provide a high proportion of ultra processed foods. What conversations Welsh Ministers are having with their UK counter parts on issues raised by Prof Vogel? – see Question 13 below. When can this be made public?
Future Generations Plan (FGP) says “People in Wales do not have equal access to a local, affordable, sustainable and healthy diet. Public bodies can use levers around planning and the promotion, procurement and provision of food to improve diets” https://futuregenerations.wales/discover/about-future-generations-commissioner/future-generations-report-2025/ Initiatives such as https://futuregenerations.wales/news/children-across-wales-should-have-more-welsh-vegetables-on-their-school-dinner-plates-urges-future-generations-commissioner-in-the-week-after-he-publishes-his-future-generations report
Necessarily, work undertaken is limited by the Commissioners remit and is narrow and project driven. Sadly, it will have limited benefit, especially those with limited family income. Wales requires a food response that can scale and deliver a new direction. For example, see Question 14. Can Cook is a social enterprise with charity status, catering commercially using its profits to support the services it provides. https://www.cancook.co.uk
Q12 The once in a life time opportunity to address growing intergenerational health inequalities.
Q13 In answering your question ref “draft regulations on children, families living in socio-economic disadvantage” we urge two key actions recommended by Prof Vogel (below) that have much greater degree of certainty and beneficial impact at a population level than can be achieved by a focus upon school meals, especially for secondary pupils experiencing what some consider to be a ‘Wild West’ catering operations. A practical example being one authority experiencing a low take up of freshly cooked free school meals by primary pupils from low-income families – who were accustomed to low-cost fabricated foods. If UPFs trans nationals are testing food on babies for acceptability – then non devolved remedies will be essential. This submission arises from a Coops Wales 17 May 2025 UPF event with Chrstina Vogel, Professor of Food Policy, Director Centre for Food Policy, City University, London. https://youtu.be/m0tKHW3QY30
“Making the case
- The combined cost of current rates of obesity and overweight to the UK economy is £97.9 billion per year; £19.2 billion of this is paid by the NHS and £15.1 billion is paid in productivity losses
- Adult obesity has risen from 15% in 1993 to 28% 25 years later – poor diet is the key driver of obesity and many other non-communicable diseases
- 120 children are hospitalised each day due to tooth decay and extraction which is caused by high sugar diets
- Over 11,000 hospitalisations each year are due to malnutrition, mainly rickets and scurvy – due to very low intakes of milk and fruit and vegetables
- The number of 18-34 year olds not working due to poor health (largely driven by poor diet) has doubled in the past 10 years.
- These statistics are not the result of people not knowing what to eat – they are driven by the ubiquitous nature of unhealthy foods across our everyday settings
- Fruit and vegetables are double the cost of HFSS (high fat, sugar and salt (foods and drinks, price promotions are dominated by HFSS foods, only 1% of location promotions are on fruit and vegetables, our menus, high streets and schools are dominated by the availability of HFSS foods
- Obesity drugs will not have a sustained effected if we do not make our everyday settings healthier and more reflective of our Eatwell guide.
What can be done?
Two key actions can be taken:
- Use High Fat Salt & Sugar (HFSS) as the definition of unhealthy food and drinks across everyday settings as part of a joined-up regulatory framework that restricts the dominant presence and intensive marketing of HFSS products and introduce a HFSS label across all settings
o For example: a) restrict or prevent availability/sale of HFSS products in schools (including breakfast and after school clubs) /hospitals/prisons; b) require HFSS labels on infant/toddler products; c) require HFSS (and calorie) labels on out of home outlets including workplace canteens; d) restrict marketing of HFSS products without delay; e) restrict multi-buy and temporary price promotions and location promotion of HFSS products in retail outlets;
o Require the definition and algorithm (nutrient profile model) of HFSS to be reviewed by the Scientific Advisory Committee on Nutrition (SACN) every five years to ensure it stay abreast of the latest scientific evidence on nutrition (i.e. new evidence on artificial sweeteners, emulsifiers, additives, sugar etc)
o Adequate funding for enforcement of regulations to ensure a level playing field for all businesses – a HFSS label would assist with active enforcement by enforcement officers and the public
- Ensure regulations which restrict HFSS products are coupled with requirements to promote plant-based minimally processed foods (MPFs) (such as fruit and vegetables, beans and pulses, and nuts and seeds) and nutrition safety nets for more disadvantaged families are strengthened
o To shift societal attitudes towards wholesome foods we need to boost their promotion and presence. This could be achieved by coupling some regulations which restrict HFSS products to also, concurrently require promotion/availability of MPFs. For example, requiring retail outlets to have a F&V section at the front of store in addition to restricting placement of HFSS products at the front of store, aisle-ends and check-outs or requiring for a 1% marketing spend to be on MPFs or meals offered in schools to have a minimum of 1 portion of F&V
o Strength nutrition safety nets – by increasing the eligibility criteria (Free School Meals (FSM) and the Healthy Start scheme (HSS)), increasing the value (HSS and FSM), streamlining the eligibility criteria across FSM and HSS and ensuring 4-years olds do not miss out (currently there is a gap in financial support for families when children turn 4 years old) and introducing autoenrollment to make it easier for families and avoid unnecessary NHS/community staff resource signing families up to these schemes. Also, social prescribing is incredibly successful for shifting to care for adults at risk of/early onset non-communicable disease to the community from hospitals. There are some excellent outreach examples in Lambeth”
Q14 Sadly, this question is to narrowly focused and related to regulating dietary changed rather than focusing on how we make existing public expenditure more cost effective. This is the real challenge if we are to avoid, what is in the main, an outdated school food sector…complaining again about cost when there is already enough funding to make a difference.
https://www.publicsectorcatering.co.uk/in-depth/free-school-meals-expansion-challenge-education-caterers?utm_source=emailmarketing&utm_medium=email&utm_campaign=psc_daily_update_230725&utm_content=2025-07-23
With increasingly financially constrained local authorities, we address these wider issues, so Wales can effectively deliver on its wider public health and sustainability agenda.
With Can Cook https://www.cancook.co.uk they have a scalable model that addresses every issue discussed, including removing Ultra Processed Foods (UPFs), standardising meals, using Welsh produce and companies, and promoting sustainability. Everything they do at Well-Fed aligns with the Well-Being of Future Generations Act Wales. Can Cook believe it all starts with policy change:
Farm to Order at Scale: Help stop intensive farming by working with chefs to develop seasonal meals that kids want to eat. Allow farmers to grow seasonally and be paid a real wage, planned in advance with school food contracts.
Utilise the Current Welsh Supply Chain: Use logistics by Harlique and Castle Howedd to collect from farms to central production kitchens (CPKs), then from CPKs in trackable reusable GNs directly to schools, with empties returned within the same supply cycle.
Central Production Kitchens (CPKs): At Well-Fed, they are ready to scale and can replicate every 50 miles or so. They receive Welsh raw produce, process it, cook zero UPF prepared chilled meals, pack into reusable metal GNs, and send directly to schools through the current supply chain. This helps to standardise meals, gravies, etc.
Keep contracts with current Contract Caterers: Allow the incumbent caterer (hopefully the local authority) to retain the contract and use the Well-Feds CPK as a supplier.
Policy Changes: change school food policy to ban the use of plastics, paper, and UPF, and promote seasonal eating in educational public sector catering. The government has the power, and they have the scalable model.
Our understanding is that there would be no need to terminate any public sector contracts with wholesale supply chains or contract caterers, whether local authority or private business which would result in job losses. It’s a simple case of reallocation, meaning the caterer and suppliers would work with Can Cook as a social enterprise with charity status, catering commercially using its profits to support the services it provides instead of numerous UPF manufacturers. In that way, Can Cook https://www.cancook.co.uk , as an example of a charitable community benefit enterprise, could be working together with more public bodies to tackle a food system that is destroying our people our planet and our economy.
Q15 not sure. User perspective key to change. We need to build upon existing best practice in improving existing school participatory structures to further support pupil engagement in the co-design of menus.
Bite Back provide an exciting approach: Change that affects young people, has to include them!”www.biteback2030.com
Q16 We fully understand why Welsh Government sought more evidence. Secondary school catering has been described as the ‘Wild West’. To tackle this problem head on it must be upstream the food chain aimed at existing commercial practices driven by maximising profit. Once the ‘fox is in the coup’ regulation and enforcement at the school level is likely to make very limited difference – although this is not to suggest nothing should be done. Here we argue for a more strategic approach to food policy at all levels of government. To this end, we repeat a UK submission which arises from the Coops Wales 17 May 2025 UPF event with Chrstina Vogel, Professor of Food Policy, Director Centre for Food Policy, City University, London. https://youtu.be/m0tKHW3QY30 See above,
Q18/19 None
Q20 (a) We are amazed with the planned delay of Healthy Eating in Schools regulations until 2026 + which should further support the inclusion of fresh, locally produced, minimally processed food, including portion sizes tailored to different age ranges and promoting healthier pupil eating habits, aligned with pupil well-being, sustainability, and climate goals.
(b) Welsh Govt needs to be far more proactive with local government to implement changes locally, whether services are provided in house or commissioned. This to include establishing a robust monitoring system, leveraging digital tools to streamline the task of food monitoring, and driving higher standards across Wales.
(c) We need positive action to ensure local authorities and Health Boards utilise the schools meals data for thoughtful consideration, thorough scrutiny, and prompt action.
(d) Could this example provide insight into how objectives can be achieved in a wide variety of contexts across Wales driven by pupils themselves as part of their curriculum https://www.biteback2030.com/join-bite-back-in-schools/
(e) The school food supply chain is already 10 years out of date, and this is exemplified by the constant repetition of ‘there is not enough money to feed children well’ – this is not true, but it is made because the lack of food skills/knowledge in a large number of schools in Wales. This will not change unless we properly invest in catering and management skills and knowledge. See our response to Questions 11 and 14.
(f) One challenge would be for the Welsh school meals advisory working group to reflect on the extent to which: “the whole system set up to protect the supply chain and not the children eating the food”. In our view, until this is reversed nothing will change. We note this Welsh Govt consultation is supply chain focused.
(g) In the early 2000’s, the need for practical food education was vigorously championed by the Welsh Food Alliance and the Home Economics Teachers Association by avoiding the substitution of ‘Home Economics’ curriculum with ‘Design and Food Technology’. (This when Rosemary Butler AS was Education Secretary). Food education and vocational training go the heart of challenges being currently experienced with 60% of the population lacking a practical food skills, with pupils thinking that milk originates in supermarkets.
(h) Now we lack the capacity to properly train food teachers within the new national curriculum. No wonder teachers report lack confidence and skills to do so. In the space of 25 years we have moved from a year course training food teachers, to now were we have a short Level 2 accredited course with ‘staff training (consisting of): Community Food & Nutrition Skills course x 9; Food Hour facilitators day x 11″).
See our YouTube event on Ultra Processed Food Playlist 17 May 2025 UPF event
https://www.youtube.com/playlist?list=PLGbE0b-Z8DOZ5ItEzGmIF4VF1Dqr_uwTb
Our Food Economy: The case for improving the UK labour government’s approach to long term food strategy within and between several of governments five missions
What was the motivation of the Rochdale Pioneers, who codified the values and principles on which the co-operative movement has based since 1844? As Dame Pauline Green, a former President of the International Co-operative Alliance reminds us, “We know it today as food security” in what is 2025 International Year of Co-operation.
There is a growing and widespread recognition that our food system is not working – for people’s health, for people on low incomes, for farmers, for the wider economy. The problem, and many of the solutions, have been identified and discussed at length but we have lacked the political will to take the necessary steps to effectively address one of the greatest long-term health challenges this country faces https://www.gov.uk/government/publications/tackling-obesity-government-strategy/tackling-obesity-empowering-adults-and-children-to-live-healthier-lives (2020)
In October 2024, the House of Lords food diet and obesity committee concluded poor quality diets were the primary factor contributing to an obesity crisis https://lordslibrary.parliament.uk/a-plan-to-fix-our-broken-food-system-house-of-lords-food-diet-and-obesity-committee-report/ The government’s response in January 2025 to this was ‘Recipe for health: a plan to fix our broken food system’ report. See https://www.gov.uk/government/publications/government-response-to-the-house-of-lords-food-and-health-report/government-response-to-the-house-of-lords-food-diet-and-obesity-committees-report-recipe-for-health-a-plan-to-fix-our-broken-food-system
“These statistics are not the result of people not knowing what to eat – they are driven by the ubiquitous nature of unhealthy foods across our everyday settings” See Prof. Vogel at https://www.youtube.com/watch?v=m0tKHW3QY30
The impacts of our broken food system is felt across many areas of Government and has a major impact on several of Labour’s Five Missions. Most notably, this included the impact of obesity on health, the long-term sustainability of the NHS and inequalities in healthy life expectancy. However, there are also major impacts on educational outcomes and children’s prospects in life and on economic growth – with obesity one of the most important factors dragging down productivity and increasing health-related economic inactivity.
It is therefore reasonable to have a dedicated process to exploring policy development in this area, as it is critical to many of Labour’s main objectives and cuts across many areas. The NHS 10 Year Plan is due imminently and will allow us to understand the Government’s current ambitions for fixing the health-harms of food.
If we are to contribute, how can we prepare at a very early stage for a cross departmental focus upon food across the economy and society, and avoid a policy development process that is currently siloed?
These are examples of how we should examine the cross-cutting role of food across several different policy areas. For example, the combined cost of current rates of obesity and overweight to the UK economy is £97.9 billion per year. £19.2 billion of this is paid by the NHS and £15.1 billion is paid in productivity losses. https://www.frontier-economics.com/uk/en/news-and-insights/news/news-article-i20358-the-rising-cost-of-obesity-in-the-uk/
It is recommended that representatives from several policy areas to consider how food intersects with their sphere of interest. The Government is rightly working on a cross-government Food Strategy with involvement from DEFRA, DHSC, DCMS, DSIT, DBIS and others. We require an equivalent process to work across siloed policy areas, which should involve devolved administrations, combined authorities and other local governments in England, Scotland, Wales and Northern Ireland.
Working to develop a new service – you are welcome to contribute!
During meetings we often use words and phrases that may not be fully or consistently understood, such as; food poverty, food (in)security, cash-first approach, income maximisation, affordable food, food bank, food pantry, food club, community fridge /pantry, food resilience and cultural foods.In this Jargon Buster Lewes & District Food Partnership have provided examples and definitions of affordable and emergency food schemes.
https://lewesdistrictfoodpartnership.org/resources/jargon-buster/
Dignity in Practice
Learning, tools, and guidance for community food providers
Sustain’s Diversity Style guide
This includes some guidance around talking about food insecurity as well as health and weight, and other diversity aspects.
https://www.sustainweb.org/assets/sustains-diversity-style-guide-Apr23.pdf
Scotland – industry responsibility
“Industry has many levers it can pull to improve the healthfulness of the food we eat. .., the food industry needs to acknowledge the significant role it plays in this health crisis and take responsibility for being part of the solution….there is no single way to make the significant and urgent change … it will need layers of policies and initiatives that address different facets of our food environments. Approaches such as reformulating some food products that are particularly high in fat, salt and sugar so they … don’t harm our health could have significant positive effects on obesity.
Food Insecurity
The UK Food Standards Agency provide the latest evidence on food insecurity.
https://www.food.gov.uk/print/pdf/node/18891 Approximately a quarter of respondents were food insecure (for example, had low or very low food security) in England (24%), Wales (27%) and Northern Ireland (26%)
Food security varied by age group with older adults being more likely to report that they were food secure and less likely to report that they were food insecure than younger adults.
Above from FSA’s flagship survey shows food insecurity continues to rise.
Read more: https://www.food.gov.uk/…/fsas-flagship-survey-shows…
Cancer striking more and more people
“The basic message hasn’t changed – don’t smoke, drink alcohol sparingly, eat less and move more – but it’s clear that relying on education and individual behaviour is not enough. As a recent analysis from the UK recommends, we need good social policies and interventions including regulation and taxation to shape population health which will deliver benefits for all” See https://www.theguardian.com/commentisfree/2023/aug/04/cancer-is-striking-more-people-in-the-prime-of-their-lives-what-can-we-do-better
‘We need a new long-term vision for food in Wales’ This is a recent contribution by Derek Walker – Future Generations Commissioner for Wales
https://nation.cymru/opinion/we-need-a-new-long-term-vision-for-food-in-wales/
It says, “This autumn, I will publish my priorities for my role for the next seven years, and the long-term questions I’m exploring include – how can we involve communities to shift diets to meet the nature and climate emergencies and create green jobs? And what kind of support do food businesses and consumers need to grow and eat more fruits and vegetables?”
Public Health Nutrition
In our view, government has a key interventionist role – see the Scottish NESTA report above. One seriously neglected aspect concerns Public Health Nutrition and how markets are nudged in a planned way to meet Public Health requirements. Welsh Government can give a lead, requiring policy direction, appropriate regulation of food standards – that are consistently applied through publicly funded catering – we already do this with the Welsh Free Breakfast programme. This approach needs extending to the School Meals Service and separate NHS Local Health Boards, enabled by adequate funding. Procurement for the Public Good to address improved nutritional standards.
Procurement for the Public Good
Public procurement of food is an under-utilised tool to improve dietary intake. Ultra-processed Foods are a major driver of growing child and adult obesity. Government should regulate levels of industrial processing in school food so that 75% of the food purchased must be minimally processed and wherever possible 30% must be supplied from local sources.” See: https://www.imperial.ac.uk/news/223573/urgent-action-needed-reduce-harm-ultra-processed/
Ultra-processed Foods
This latest study provides new, important data on the impact of industrial food processing, in which foods are modified to change their consistency, taste, colour, shelf life or other attributes through mechanical or chemical alteration – typically lacking in traditional, home-prepared meals – on child health. Led by a team from Imperial’s School of Public Health The work is the first to look at the link between the consumption of UPFs and obesity in children over a long period of time, with findings broadly applicable to children across the UK)
Reducing health inequalities
Reliable, nutritious food at school helps children to focus on their learning and attainment. Crucially, it will also result in a healthier population and reduce health inequalities. Any future UK government should fund & deliver, within its first term in office, a progressive roll out of healthy school meals for all primary school children and expand access for any secondary school children living in poverty.
Labour’s draft manifesto
In a recent submission to Labour’s draft manifesto reference is made to ‘breakfast clubs’ in terms of family support, without relating to this wider ‘anti- poverty measure’. This and the above comments on public catering should be seem as mutually reinforcing each other and can also be seen as supporting the creation of socially useful employment.
UK wide summary
It is noted that Welsh government provides free lunches for all primary school children by 2024. In Scotland, children receive free meals for the first five years of primary school. In Northern Ireland, the family earnings threshold for free school meals entitlement is £14,000, compared to £7400 in England. This is intended to enable many more families to benefit from school meals provision.
