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Novel Foods Westminster Seminar 2020

Novel foods in the UK – innovation and safety, sustainable food production and the evolving regulatory landscape

The event ranged from a useful description of the current procedures for approving Novel
Foods, and how Novel Foods are defined, to some interesting discussions about a range of
different types of novel food and what their state is in terms of being close to market,
ending with a description, as far as was possible, of what will happen post Brexit.

Professor Gregory, Chair of the Novel Foods Advisory Committee, described how things
stand now. There is quite a complex process for assessing the risks associated with a given
Novel Food and it can include reaching out to specialists if there are concerns about
sustainability or other negative impacts beyond the risks to the consumer. It was pretty
clear that assessing risk is not a precise science and consists of an assessment of the
available evidence followed by a judgement.

Interestingly, he described the main trends they are seeing in the kinds of novel foods being
submitted – these tend to focus on one or more of – nutritional/health/well-being
properties, new forms of protein, making new uses of waste/organic bi-products of
conventional food production and sustainability. Of course, insect protein delivers on all of

The head of food at InnovateUK explained the support they can provide for innovation and
the support already provided to insect related companies was acknowledged.

Following this, there was a panel session where a number of perspectives on novel foods
and regulations were presented – a legal view, the Woven perspective relating to insect
protein, CBD sales, Quorn and vegan perspectives.

My presentation set out the many benefits of insect protein from the nutrional and
sustainability perspectives. I also highlighted the recent analysis by Barclays Bank suggesting
the global insect protein market could be worth $8bn by 2030.

I summarized the situation regarding Novel Food applications. The current set of insects for
which applications have been received are:

  • Acheta domesticus (house cricket)
  • Whole and ground crickets (Acheta domesticus) *
  • Dried Gryllodes sigillatus (crickets) *
  • Hermetia meal (black soldier fly)
  • Honey bee drone brood (Apis mellifera) male pupae
  • Migratory locust (Locusta migratoria)
  • Whole and ground grasshopper (Locusta migratoria) *
  • Mealworm (Tenebrio molitor) flour *
  • Whole and ground Alphitobius diaperinus (lesser mealworm) larvae products *
  • Dried Tenebrio molitor (mealworms) *
  • Tenebrio molitor (mealworm)
  • Whole and ground mealworm (Tenebrio molitor) larvae *

Having conducted a recent trawl of insect related businesses in the UK, I was able to set out
a positive statement of the range of these:

Insect Farming

  • Monkfield Nutrition
  • Entocycle
  • Entomics
  • Multibox
  • FERA Science
  • The Cricket Hop Co
  • Green Bee Entomology
  • Horizon Insects
  • Instar Farming
  • Mini Feasts
  • Six Legs Farm
  • Six Feet Farm

Food Products/sales

  • Bug Farm Foods
  • Crické Food
  • Earth and me
  • Eat Grub
  • Hop Bar
  • Krick8
  • Nutribug
  • Yumpa
  • Crunchy Critters
  • Future Food Shop

Pet food products

  • Yora Pet Foods

Restaurants serving insects

  • The Grub Kitchen
  • Archipelago
  • Nightjar
  • Native
  • Greyhound Café
  • Santo Remedio
  • Lao Cafe


  • IMBT
  • Insect Technology Group
  • Beta Bugs
  • Brilliant Bugs Limited
  • Grub Consultancy
  • Flyr

Having consulted our members regarding their concerns, I set out the following key points
for Government to consider.

The EU market is key for UK producers for sales. However, European farmed insects are a
lot more expensive than Thai and being restricted to only sourcing from the EU would push
prices up considerably.

Clearly, we are all waiting to see what insects are approved. However, we also face the fact
that the EU only allows imports of insect protein from Switzerland, Canada, South Korea.
Thus, material from Thailand is not allowed, and once the UK is outside of the EU, products
containing insects may be similarly restricted.

If the UK is seriously looking at diverging from the EU in its decisions about the approval of
Novel Foods, then this could further complicate selling into the EU and mean that
companies would have to seek approval both from the FSA and from the European

The current uncertainties and difficulties in demonstrating clearly the safety of insect
products stem from the limitations of the research that has been done. More is needed to
test, and hopefully demonstrate, the safety of insects, their very limited risks as allergens
and that a less restrictive approach to feeding insects does not introduce unmanageable
risks to consumers.

There was a considerable debate about the balance of risk averseness and how far to go to
protect consumers. While no-one disagreed with the UK Government taking a stance of
standing between consumers and potentially dangerous food products (unlike in the US
where the threat of litigation is the primary driver to ensure safety), it was acknowledged
that some products carry less risks than others – insects that have been consumed for
centuries being a prime example – and that other concerns around feeding the planet
sustainably and helping people have a healthy diet should also be included in these

Clearly there is scope for the UK to become a location that can allow more innovation on
the basis of products that are intended for the UK market, and then once they are
established and there is a good basis of evidence of their safety, the company could seek
approval from the European Commission for approval to enter their market.

The situation with insects should be relatively straight forward, and I made the case during
the discussion. We are not aware of any documented cases of people dying or even having
a severe allergic reaction to eating insect material and millions of people all over the world
have consumed insects harvest from the wild for centuries (although the extent of
documented evidence of safe consumption is limited). The starting point should be one of
assumed acceptance, therefore, unless there is clear reason to believe that some new risk
has been introduced. This is where questions about farming methods and the substrates
on which insects are fed arises. It is where farming practices in the EU can be much more
controlled while those in Thailand, etc. tend to allow for more variability and makes quality
control harder.

After a set of wide-ranging presentations about very radical new forms of “food”, the near
final talk was by Ruth Willis of the FSA. She explained how the FSA is preparing for Brexit
on the understanding that there will be a transition period during which EU regulations still
apply, EU law will be added to the UK Statute books so that we start off on the same page at
the EU, but that the UK will set up an independent process and capacity for accepting and
assessing novel food applications. This is where the UK may end up taking a different
position to the EU in particular cases even though the procedures and evidence-base will be
much the same. This could come down to the assessment of the particular needs of the UK
population which might be different to those of certain EU countries, or down to Ministers
making a different decision based on essentially the same advice.

As insects that have been submitted for approval by the EU are approved or not, the UK will
then determine whether it follows the EU position, or not. Hence we could potentially see
some divergence from very early on, although it seems unlikely UK Ministers will take a
deliberately different position to the EU unless there is some particular lobbying to suggest
they should.

In summary, there is still a lot of uncertainty and Brexit does not help. There was no
discussion about trade relationships with the EU affecting novel foods, and the barriers to
entry into the EU market for insects. These points will need to be taken up separately.

As things develop, the Woven Network will maintain a close interest and seek a meeting
with the FSA once it starts to become clear what response the EU makes to the insect
approval applications. We will continue to consult our members about their concerns and
to lobby accordingly.

So watch this space.

Nick Rousseau

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Edible Insects Research

On the 8th of October 2015, the Scientific Committee of the European Food Safety Authority (EFSA) published a “Scientific Opinion” outlining the risk profile relating to the production and consumption of insects as food and feed. This document was commissioned by the European Commission ahead of their forthcoming decision on whether insects should fall into the category of Novel Foods, which would subject edible insect companies to much stricter regulations (more details coming soon).

One of the most useful things to come of this exercise has been the collation of existing data surrounding edible insects, their production and consumption, focussing on the entire supply chain, from farmed insect to human food or animal feed. Gaps in our current understanding of the science involved were highlighted and recommendations for further edible insects research were made. Those specifically relevant to entomophagy are summarised below.

EFSA Recommendations for Further

Edible Insects Research

Consumption Trends

European trends in insect eating can so far only be estimated from sales of insect products. Other than the inclusion of insects as a category in the EFSA’s own standardised food classification system (FoodEx2), there have so far been limited attempts to acknowledge insects as a food category in Europe.

The EFSA did, however, note that not only are insects eaten as snacks in some European countries, they are now appearing in the menus of high-cuisine restaurants, such as Archipelago in London and Grub Kitchen in Wales, the latter devoted solely to edible insects.

They add that this inclusion of insects in gastronomy has the potential for a rapid change in future consumption trends, but this needs to be quantified through the analysis of insect consumption in national consumption surveys.

If approval as a human food is granted, increasing consumer demand and the rise of edible insect companies will further strengthen their place in the market.


Bacteria can be found both within the gut of an insect and on its surface, as they are with any animal, us included. Bacterial content in itself is not, however, the issue; it is whether bacteria pathogenic to humans can be propagated through the farming of insects, either for human or animal consumption.

The EFSA was not so much concerned with bacteria that were pathogenic to the insects themselves, since insects are genetically so different from us that a case of “entomopathogenic” bacteria developing the ability to infect human hosts would be highly unlikely. They were, however, concerned with the potential for insects to act as vectors for known human and animal pathogens such as Salmonella, E. coli and Campylobacter. Studies have indeed shown that this is possible (Holt et al., 2007; Leffer et al., 2010), but unlike poultry and larger animal livestock, these pathogenic bacteria are unable to replicate inside the insect gut, meaning that this risk can essentially be mitigated as long as substrate choice and processing methods are carefully regulated.

Nevertheless, this opinion is based on scarce evidence in the scientific literature. The ESFA therefore recommends further research into the prevalence of human pathogens in farmed insects.

An additional concern involves antimicrobial resistance, since antibiotics are made use of in insect farms in cases of pathogenic outbreaks, or simply in order to improve insect yields and longevity (Hirose et al., 2006; Eilenberg et al., 2015). It is therefore advised to introduce controlled antimicrobial use for insect farming, and to keep a close watch on bacterial populations in case resistance develops.


The story for viruses is much the same as for that of bacteria. Insects have a multitude of viruses that affect them, but they are all specific at either the family or species level so are of no threat to humans. The EFSA did consider whether some insect viruses with taxonomically related groups affecting vertebrates (e.g. viruses for polio, Hepatitis A, etc.) had the potential to jump to humans, but some studies have shown that insect viruses do not replicate in human cells (El Far et al., 2004), and there is no evidence of such a jump having ever occurred.

Insects do, however, act as vectors for some human viruses (e.g. dengue fever, West Nile disease, etc.) which are actually able to replicate within the insect (King et al., 2012). There is therefore a need to determine whether these kind of viruses can be found in farmed insects, but there is no evidence of this to date.

Similarly, it will be necessary to investigate the potential survival of vertebrate viruses within insects in order to evaluate whether insects may aid in the propagation of viral disease outbreaks, regardless of whether the virus is able to replicate within the insect.


Insects are known to harbour parasites and there have been rare occurrences of transmission of these to humans, although all instances were non-European.

Most of these reports involved trematodes (parasitic flatworms, or flukes). These animals tend to have very complex life cycles involving at least two hosts, one of which is almost always a specific species of snail. An example of such a life cycle for Dicrocoelium dendriticum, a trematode worm that can infect humans through eating ants (Jeandron et al., 2011), is shown below.

The EFSA notes that the risk of parasite infections such as this can be significantly reduced in properly managed closed farming environments, since the parasites will not have access to all of the hosts required to complete their life cycle, nor will the farmed insects be exposed to the parasites in the first place.


Prions are a strange one. They are not living organisms; they are composed entirely of protein – misfolded protein – yet it is widely accepted that they are able to replicate by stimulating their normally folded counterparts found in humans and animals to take on their own misfolded configuration. Since the immune system does not recognise them, they can’t be fought in this way, leading to diseases such as Creutzfeldt-Jakob Disease (CJD) and variant CJD, taking on the apparent behaviour of an unregulated viral infection.

Any animal would need the properly folded prions in their system (found naturally in our cell membranes) in order for a misfolded prion infection to replicate by using them as templates. Insects, however, do not have prion-encoding genes, so the risk of insect-derived prions infecting us is zero. Where the risk lies is in whether they can act as vectors for our own prions. Fortunately, due to the same genetic basis, mammalian prions cannot replicate within insects, but studies have found that they can be carried by them (Thackray et al., 2012; 2014).

The key issue with prions is that farmed insects would need to be fed on human- or animal-derived substrates, such as slaughterhouse by-products or human sewerage, for any potential risks to arise, but this is only going to be a possibility for insects raised for feed since these substrates are not made use of in the farming of insects for human food.


Chemical contaminants that may accumulate in insects through their substrate can be broken down into the following categories:

Heavy Metals

Data on heavy metal uptake by insects is mostly limited to studies on cadmium and lead, but it has been shown that these metals are accumulated in insects through their substrate or from the soil (Vijver et al., 2003; Diener et al., 2011). More research is needed on the uptake of other metals and on the heavy metal content found in different forms of substrate.


Insect toxins are naturally produced by some insect species, but they usually advertise their toxicity through the use of vivid colours to ward of predators. There is no evidence that the most commonly farmed insect species produce these kinds of toxins. Insects do have the ability to accumulate toxins from plants and fungi, so the issue for farmed insects is primarily related to the control of toxin levels in their substrate.

Hormones & Veterinary Drugs

Veterinary drugs, hormones and antimicrobial agents are sometimes added to substrates to fend off disease or promote growth in farmed insect populations, and residues have been found to accumulate in the insects (Charlton et al., 2015). The EU veterinary drug legislation does not currently cater for insect farming, but testing for these kind of compounds can be managed in much the same way as is practised with other foods of animal origin.

Pesticides & Biocides

Very little data exists on the accumulation of pesticides in farmed insects, but most insects tested had levels below the danger threshold (Charlton et al., 2015). Pesticide accumulation is obviously a concern for insect farming, especially if the insects are destined for the plate, but again, close control and traceability of the substrate used should be practised. Similarly, care must also be taken with the use of any biocides for the cleaning and disinfecting of farming equipment.


This is a big one for insect farmers, since there have already been cases of allergic reactions and even anaphylactic shock in humans (Siracusa et al., 2003; Ji et al., 2009). Moreover, the potential for allergic reactions cannot be controlled by choice of substrate, as has been the case for most of the risks discussed so far.

Allergic reactions occur in individuals either because they are already sensitised to insect allergens, the allergen has cross-reactivity with something else they are allergic to (e.g. shellfish), or the allergen is responsible for a completely new food allergy in the individual. The ESFA advises risk assessments need to be informed by further research into these three types of allergic reactions and their relative potential to develop in the population.

The obvious solution, provided that the risks assessed through research are not higher than acceptable levels, is to inform consumers of the insect content and potential allergenicity and/or cross-reactivity of insect-derived products through adequate food labelling.

Farming Methods

The processing and storage methods used following insect harvesting are also key considerations for food safety, as contamination can occur after the farming process, as was the case when five people in Kenya died of botulism after eating termites stored in plastic bags for four days during transport (Knightingale & Ayim, 1980).

A study into different processing methods for mealworms and crickets revealed that the only means of destroying all Enterobacteriaceae and spore-forming bacteria was through a combination of boiling the insects for five minutes, followed by refrigeration at 5 to 7 ºC (Klunder et al., 2012). The study also showed that roasting alone did not eliminate bacteria, so boiling beforehand was again advised.

Environmental Risks

Environmental Risk Assessment (ERA) takes into account many of the risk factors already discussed in this article, their potential to be released into the environment, and any knock-on effects that this may cause. The sustainability of our food sources is another factor that is becoming increasingly more important, and was also therefore considered by the EFSA.

The environmental risks involved in insect farming largely depend on the waste management strategies in place, as is the case for any type of livestock agriculture, but also on the levels of some of the contaminants already mentioned (heavy metals, pesticides, etc.) that might be present in the insect waste. Insect frass, for example, is known to be nutrient-rich and therefore may act as an efficient fertiliser, but risks of environmental contamination may then come into play if the safety criteria for them are not adhered to in the first place.

As far as the sustainability of insect farming is concerned, it does appear to be more favourable than traditional livestock farming (more details here), but the EFSA suggests that more data is required to evaluate the extent to which this is the case, specifically for the mass-rearing of insects compared to that of larger livestock.

Charlton, A. J., Dickinson, M., Wakefield, M. E., Fitches, E., Kenis, M., Han, R., … & Smith, R. (2015). Exploring the chemical safety of fly larvae as a source of protein for animal feed. Journal of Insects as Food and Feed, 1(1), 7-16.

Diener, S., Zurbrügg, C., Gutiérrez, F. R., Nguyen, D. H., Morel, A., Koottatep, T., & Tockner, K. (2011). Black soldier fly larvae for organic waste treatment—prospects and constraints. In Proceedings of the WasteSafe—2nd International Conference on Solid Waste Management in the Developing Countries. Khulna, Bangladesh.

Eilenberg, J., Vlak, J. M., Nielsen-LeRoux, C., Cappellozza, S., & Jensen, A. B. (2015). Diseases in insects produced for food and feed. Journal of Insects as Food and Feed, 1(2), 87-102.

EFSA Scientific Committee (2015). Scientific Opinion on a risk profile related to production and consumption of insects as food and feed. EFSA Journal, 13(10), 4257, 60 pp.

El-Far, M., Li, Y., Fédière, G., Abol-Ela, S., & Tijssen, P. (2004). Lack of infection of vertebrate cells by the densovirus from the maize worm Mythimna loreyi (MlDNV). Virus research, 99(1), 17-24.

Hirose, E., Panizzi, A. R., & Cattelan, A. J. (2006). Potential use of antibiotic to improve performance of laboratory-reared Nezara viridula (L.)(Heteroptera: Pentatomidae). Neotropical entomology, 35(2), 279-281.

Holt, P. S., Geden, C. J., Moore, R. W., & Gast, R. K. (2007). Isolation of Salmonella enterica serovar Enteritidis from houseflies (Musca domestica) found in rooms containing Salmonella serovar Enteritidis-challenged hens.Applied and environmental microbiology, 73(19), 6030-6035.

Jeandron, A., Rinaldi, L., Abdyldaieva, G., Usubalieva, J., Steinmann, P., Cringoli, G., & Utzinger, J. (2011). Human infections with Dicrocoelium dendriticum in Kyrgyzstan: the tip of the iceberg?. Journal of Parasitology,97(6), 1170-1172.

Ji, K., Chen, J., Li, M., Liu, Z., Wang, C., Zhan, Z., … & Xia, Q. (2009). Anaphylactic shock and lethal anaphylaxis caused by food consumption in China. Trends in food science & technology, 20(5), 227-231.

King, A. M. Q., Adams, M. J., Carstens, E. B., & Lefkowitz, E. J. (2012). Virus Taxonomy: Ninth report of the International Committee on Taxonomy of Viruses, Elsevier Inc.

Klunder, H. C., Wolkers-Rooijackers, J., Korpela, J. M., & Nout, M. J. R. (2012). Microbiological aspects of processing and storage of edible insects. Food Control, 26(2), 628-631.

Knightingale, K. W., & Ayim, E. N. (1980). Outbreak of botulism in Kenya after ingestion of white ants. BMJ, 281(6256), 1682-1683.

Leffer, A. M., Kuttel, J., Martins, L. M., Pedroso, A. C., Astolfi-Ferreira, C. S., Ferreira, F., & Ferreira, A. J. P. (2010). Vectorial competence of larvae and adults of Alphitobius diaperinus in the transmission of Salmonella Enteritidis in poultry. Vector-borne and Zoonotic diseases, 10(5), 481-487.

Siracusa, A., Marcucci, F., Spinozzi, F., Marabini, A., Pettinari, L., Pace, M. L., & Tacconi, C. (2003). Prevalence of occupational allergy due to live fish bait. Clinical & Experimental Allergy, 33(4), 507-510.

Thackray, A. M., Muhammad, F., Zhang, C., Denyer, M., Spiropoulos, J., Crowther, D. C., & Bujdoso, R. (2012). Prion-induced toxicity in PrP transgenic Drosophila. Experimental and molecular pathology, 92(2), 194-201.

Thackray, A. M., Zhang, C., Arndt, T., & Bujdoso, R. (2014). Cytosolic PrP can participate in prion-mediated toxicity. Journal of virology, 88(14), 8129-8138.

Van Huis, A., Itterbeeck, V. J., Klunder, H., Mertens, E., Halloran, A., Muir, G., & Vantomme, P. (2013). Edible insects: future prospects for food and feed security. Available at:

Vijver, M., Jager, T., Posthuma, L., & Peijnenburg, W. (2003). Metal uptake from soils and soil–sediment mixtures by larvae of Tenebrio molitor (L.)(Coleoptera). Ecotoxicology and Environmental Safety, 54(3), 277-289.