What has been endorsed by the Standing Committee?
The Standing Committee on Plants, Animals, Food and Feed (Novel Food and Toxicological Safety section), which is composed of representatives of all EU countries and chaired by a European Commission representative, gave a favourable opinion on the draft legal act authorising the placing on the market of frozen, dried and powder forms of Locusta migratoria (migratory locust), as a novel food on 7th October 2021. This is the second time an insect has reached the final authorising step as a novel food.
The term ‘migratory locust’ refers to the adult of Locusta migratoria, an insect species that belongs to the Acrididae family.
The novel food consists of the frozen, dried and powder forms of migratory locust. It is intended to be marketed as a snack or as a food ingredient, in a number of food products.
In the frozen and dried forms, legs and wings have to be removed by the food business operator to reduce the risk of intestinal constipation.
Why are we approving insects as food?
Novel Food is defined as food that had not been consumed to a significant degree by humans in the EU before 15 May 1997, when the first Regulation on novel food came into force. Although there is anecdotal evidence of insects consumed as food in the past, no Member State has confirmed human consumption to a significant degree prior to 15 May 1997 for any insect species.
The Novel Food Regulation requires an authorisation before a novel food product can be placed on the Union market.
The Novel Food Regulation is only about the approval of a product, following a stringent scientific assessment made by the European Food Safety Authority (EFSA). The Authority verifies, in light of the scientific evidence available, that the food does not pose a safety risk to human health.
What has happened is one of the final steps in the procedure for authorising migratory locust as a novel food. Member States gave their green light for the Commission to allow a food business operator, which had requested this authorisation, to place the product on the EU market. The Commission will now adopt a legal act to that end. This has already happened to yellow mealworm.
What is the Novel Food Regulation?
The Novel Food Regulation helps food businesses bringing innovative foods to the EU market, while guaranteeing their safety, and concerns any food which was not consumed in the EU to a significant degree before 15 May 1997.
This legislation strikes the right balance between innovation and safety. The current legislation has cut in half, the time needed for innovative foods to reach the EU market when compared to the previous legislation. It concerns foods as diverse as insects, algae, new plant proteins or traditional food from Non-EU countries, and will contribute to the objectives of the Green Deal and Farm to Fork strategy.
The principles underpinning the Novel Food Regulation are that novel foods must be safe for consumers and properly labelled, so as not to mislead them, and if a novel food is intended to replace another food, it must not differ in a way that the consumption of the novel food would be nutritionally disadvantageous for the consumer.
Why should we eat insects?
It is up to consumers to decide whether they want to eat insects or not. The use of insects as an alternate source of protein is not new and insects are regularly eaten in many parts of the world.
Is the product safe?
Yes. Novel Foods can only be authorised if they do not pose any risk to human health otherwise its approval would not have been submitted by the Commission to the Member States.
Following an application by the company Fair Insects BV, the product went through a stringent scientific assessment by EFSA which concluded that migratory locust is safe under the uses and use levels proposed by the applicant.
Are there any health issues?
According to EFSA, food allergies represent an important public health problem, affecting approximately 2–4% of the adult population and up to 8–9% of children.
The EU rules on food labelling identify a list of 14 allergens that need to be labelled (e.g. eggs, milk, fish, crustaceans etc…). This is to allow people living with food allergies to be informed on whether products contain ingredients they are sensitive to.
EFSA concluded that the consumption of the migratory locust may potentially lead to allergic reactions. It may particularly be the case in subjects with pre-existing allergies to crustaceans, dust mites and molluscs. Additionally, allergens from the feed (e.g. gluten) may end up in the insect that is consumed.
Therefore, the authorisation of this novel food clarifies this issue and lays down specific labelling requirements regarding allergenicity.
There are already insects already being sold as food in the EU. How is this possible?
This is true, for historical reasons, and there has been already one insect authorised (‘Tenebrio molitor’ larva) under the novel food regulation.
There have been doubts amongst the Member States on whether "whole insects" were covered by the former Novel Food Regulation. This uncertainty was clarified by the ruling of the European Court of Justice (1 October 2020) which concluded that "whole insects" did not fall within the scope of that regulation and could thus be placed on the market without a pre-market authorisation.
In turn, the current Novel Food Regulation, applicable since 1st January 2018, explicitly considers whole insects as novel foods, which must thus get an approval.
In order to alleviate the impact of this extension of the novel food regime on the food business operators (FBOs) of whole insects, the current Regulation provides for a transitional period, which allows FBOs to continue placing whole insects on the market subject to certain conditions. In particular, a request for an authorisation under the current novel food regulation had to be submitted to the Commission by 1 January 2019. This is why some insects are already on the market, while their scientific assessment under the Novel Food Regulation is still ongoing.
Will products containing insects be labelled?
The draft legal act establishes labelling requirements for foodstuffs containing the Novel Food.
This applies in addition to the requirements of the labelling regulation.
Are there other pending files? Can we expect more insects to be authorised in the EU?
Very recently, EFSA has delivered two other positive opinions on the insect species Tenebrio molitor (yellow mealworm) and Acheta domesticus (house cricket). Following the provisions of the novel food regulation, the Commission will present the draft implementing acts at the next Standing Committee to be held at the end of November 2021. In addition, there are at the moment 9 applications for insects, which are subject to a safety evaluation by EFSA.
Will insects for food and feed contribute to the objectives of the Farm to Fork and the Green Deal?
According to the FAO, insects as food emerge as an especially relevant issue in the twenty-first century due to the rising cost of animal protein, food insecurity, environmental pressures, population growth and increasing demand for protein among the middle classes. Thus, alternative solutions to conventional livestock need to be found. The consumption of insects therefore contributes positively to the environment and to health and livelihoods.
The FAO also indicates that insects are a highly nutritious and healthy food source with high fat, protein, vitamin, fibre and mineral content. Therefore, they are an alternative protein source facilitating the shift towards healthy and sustainable diets.
Under Horizon Europe, which is a funding programme for research and innovation, insect-based proteins are considered one of key areas of research.
What is the economic impact of this market?
At present, insects as foods represent a very small niche market in the EU.
The environmental benefits of rearing insects for food are founded on the high feed conversion efficiency of insects, less greenhouse gas emissions, less use of water and arable lands, and the use of insect-based bioconversion as a marketable solution for reducing food waste.
What are the next steps?
Following the endorsement by the Member States in October, a Regulation authorising this insect as a food will be adopted by the Commission in the coming weeks.