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Four-country working

Guidance on devolved responsibilities and collaborative working across the UK
Last updated

Four-country working is the Food Standard Agency’s collaborative, UK-wide approach to policy making. It involves civil servants from England, Northern Ireland, Scotland and Wales working together to achieve desired outcomes across the UK.

We work this way because:

  • the Food Standards Agency’s remit covers three countries - we operate in England, Northern Ireland, and Wales and we have different policy responsibilities within these countries
  • Food Standards Scotland (FSS), an independent public body, has responsibility for food policy in Scotland 
  • devolution has resulted in different policy requirements, accountabilities and priorities across the four countries

A commitment to four-country working ensures that we can effectively protect public health and consumer interests across England, Wales and Northern Ireland. Practically speaking, a four-country approach involves collaborative working practices at all levels of our organisation.

Devolved policy responsibilities

Responsibilities in the following policy areas have been devolved:

  • food and feed safety and hygiene
  • nutrition and health claims, standards and labelling
  • food compositional standards and labelling

This means powers to develop policy for Northern Ireland, Scotland, and Wales have been transferred from the UK government to these countries. Devolution also means that the Food Standards Agency is accountable to each country’s administration for our activities within these countries.

This devolution of power has led to differing governance, accountability and delivery models for the FSA across England, Northern Ireland, and Wales, and for the FSS in Scotland.

These differences include:

  • the creation of independent food advisory committees for food safety and standards issues in Northern Ireland and Wales
  • alternate delivery bodies for official controls in Northern Ireland
  • alignment with different policy requirements, such as those set out in the Welsh Language Act

Policy responsibilities within each country also differ. The Food Standards Agency is responsible for different policy areas across England, Wales and Northern Ireland.

Summary of the policy area and the responsible department by country

Food Standards Scotland

Food Standards Scotland is an independent public body working for consumers in Scotland. On 1 April 2015, it took on the functions that the Food Standards Agency (Scotland) previously carried out.

The Food (Scotland) Act 2015 established Food Standards Scotland as a non-ministerial office. It is part of the Scottish Administration and sits alongside, but independent from the Scottish Government. It is primarily funded by the Scottish Government, but charges fees to recover costs for regulatory functions.

Food Standard Scotland's role is comparable with the Food Standards Agency’s. It develops policies, provides consumer and business guidance, advises stakeholders, and enforces food regulations. The FSA works closely alongside the FSS to achieve shared results.

The FSA and FSS have a Memorandum of Understanding (MoU) in place. The FSA-FSS MoU was originally written and signed in 2015, when responsibility for FSA policy areas in Scotland were transferred to Food Standards Scotland. It has been jointly reviewed and updated by experts in both organisations to ensure it is fit for purpose in the post EU transition regulatory regime. 

The FSA-FSS MoU sets out the principles that will underpin the relationship between the two organisations the two organisations. It provides a high-level summary of the commitments made by the FSA and FSS on how we will work together, and defines our working relationship in detail across key areas of work.

The updated MoU was signed by FSA and FSS CEOs in December 2020.