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
these!

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

Technology/consultancy

  • 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
equivalent.

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
judgements.

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

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

This event in January provided an opportunity to promote the benefits of farmed insects as a novel food/food ingredient and argue for a balanced approach to protecting the consumer. The event focused on the regulations relating to novel foods and how these might change in the light of Brexit.

While there was some speculation and expression of interest in a more flexible and less cautious approach, this has to be balanced with the continued need to protect consumers from risky products entering the market and the benefits of retaining the ability to sell into Europe.

I gave an impassioned presentation about insect protein and the tricky situation the sector finds itself in in the UK, given both the transition from former Novel Food Regulations to the new ones which now require insect material to be explicitly approved, the on-going situation where we are waiting to hear which insect products will be approved by the European Commission (and which of these will only apply to products developed with proprietary processes), and how the UK will diverge from the EU post Brexit in its rulings about Novel Foods.

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.

This presentation was reported in Food Navigator.com with a headline referring to the safety of insects as food.

A more comprehensive report of the meeting is available in the members section of the Woven website. A PDF copy of the briefing document for the whole meeting may be ordered for £95 from Westminster Forum Projects.

Nick Rousseau

Full Report on FSA Novel Foods Workshop

Food Standards Agency - Featured Image

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!

FSA Novel Foods Workshop

Food Standards Agency - Featured Image

Today I attended the FSA workshop on Novel Foods Regulations, with Neil Whippey of Eat Grub.  It was a really useful and informative although we came away with some challenges for the fledgling UK insects for food sector (insects for feed was not in scope).

Full report will follow as an in-depth article for Woven members (see membership offer coming out soon).

A few highlights:

  • There is a £4,000 fee for applying for Novel Food approval and you have to submit one for each individual product that has a distinct risk profile
  • There is scope to secure a blanket approval relating to an ingredient but this would potentially need to be very tightly defined  – this could mean multiple companies securing this together, or Woven acting on their behalf, to share the costs
  • You can trade now and manufacture, market and sell products with whole insect material.  From January 2018 when the new regulations come in you will only be able to continue if you are in the process of working through a Novel Foods application – but this process can take up to 18m and you can trade throughout.
  • The potential for insect materials in foods to cause allergic reactions needs research and careful thought.  Woven will seek to work with its members and the FSA to ensure that the right balance is struck between risks and benefits and we have secured some champions within the FSA and the committee that advises them, with whom we will maintain a positive relationship.

So, definitely a worthwhile event and further signs that Woven Network is going to be critical if this sector is to succeed in the UK.

Nick

European Novel Foods Regulations now recognise edible insects!

European Parliament - Featured Image

The European Parliament agreed a new set of Novel Food Regulations on 28 October which recognise that edible insects can be included – whether whole or only part of them.

This will require companies selling products that include insect material to comply with requirements to demonstrate their safety but companies already trading have some time to work up the necessary evidence.

Here is the full text of what was agreed.

It is not an easy ready so here is a link to an article that sets out the implications:

http://foodhealthlegal.com/?cat=17

Woven will be keeping in touch with these developments and providing more info as things become clearer. Also, you can join the Forum to take part in discussions on the implications of all this and help us understand your position.

Nick

Image Credits: Wikimedia Commons