Woven was represented at the workshop by Nick Rousseau, Managing Director. In addition Neil Whippey of EatGrub participated, so was able to speak directly about the experience of a company making products for human consumption.
The process for submitting to secure Novel Food approval and role of Committee and FSA
The process is:
- Food product company compiles a dossier of evidence and completes application form – submitting to FSA
- FSA gets the committee to review the dossier and assess the risk
- Committee may well go back to food company for additional details or to highlight areas of concern
- Committee ultimately advise FSA on level and nature of risks associated with the food product
- FSA determines how manageable the risks are and what measures should be taken (eg. Labelling)
- FSA submits this to European Commission who will generally agree with assessments coming from the UK
The process can take up to 18m and the cost of an application is £4,000
What is submitted for approval could be either:
- A specific product that contains insect material
- Insect material ingredients
In the latter scenario, a number of companies that use the same ingredients could benefit from a blanket authority. They must use essentially identical ingredients, however all complying with common standards.
The dossier of evidence can be very substantial and must include specific laboratory testing (at a recognized laboratory) that shows clearly the key nature of the product/ingredient that would enable a risk assessment to be carried out. This will include both composition of the insect material plus any contaminants or other materials that might be introduced as a result of the farming method, environment, etc. There will be significant costs in securing this analysis.
In the former case, if a company has a number of products with different insect materials they will each need individual authorization.
The authorization will specify a given set of restrictions on exactly what is accepted – variety of insect, conditions under which it is farmed, processes of manufacture undertaken, etc.. This will depend on the perception of the variables that could be expected to change the risk profile of the ingredient/product.
Situation regarding the current and new Novel Food Regulations
Companies making products with insect materials could apply right now for Novel Food acceptance. Not required, however.
Currently any company can manufacture, market and trade food products in the UK that contain whole insects – eg cricket flour.
From January 2018 it will be required that companies trading with food products containing insect materials submit applications for Novel food recognition, but will still be able to trade during the period during which the application is assessed – can take up to 18m
Particular issues that will affect protein alternatives – particularly food containing insect materials
We had an extensive debate about the fact that a large number of people in the UK (20-25%) are allergic to dust mites and the fact that insect protein will result in an allergic reaction, in some cases potentially very severed in individuals. There is a need for research to understand the nature of this and how comparable it is to other allergens such as crustaceans, agreed standards for labelling to alert consumers, and post market studies to establish the actual impact on consumers from eating insect products.
The research involved needs to be seen to be independent of the businesses involved.
We were able to secure a commitment from the key member of the committee to find a way to balance the risks and opportunities so that businesses will be able to trade with products including insect material.
This raises many serious issues for the sector and for Woven, in terms of how we can support businesses with this. One scenario is for Woven to act on behalf of its members and seek a blanket approval for insect ingredients used in a range of individual companies’ products, so that the cost and effort involved can be shared.
We are keen to hear your views!