Current EU Novel Food regulation

SUMMARY
The commercialization of insects as food is currently not allowed by the European Union, in the absence of a novel food authorization. As of April 2021, no authorization has been granted, although 4 applications for crickets have been submitted and are in the process of being approved. A number of other request have been submitted for other insects too (including mealworms). According to rumors, the EU novel food approval might arrive before the end of 2021 for crickets and mealworms.  In the meanwhile, only a few European countries permit the sales of insects as food, on the grounds of the “transition measures” included in the EU Novel Food law. These countries are Finland, Denmark, Belgium, The Netherlands and Germany. On November 2020 Sweden joined this group. After a one year break, during the Brexit, the UK food agency green lighted again insects as food. Details are here.

In 2019, EU Regulation 2019/626 created a List of Authorized Countries for insect import into the EU. This list is under development and currently (Nov 2020) is composed of only 4 countries: Canada, South Korea, Switzerland and Thailand. Approval for Vietnam is on the way. The questionnaire that countries must send to the EU if they want to be added to the list of authorized exporters is available here.

The list of Novel Food applications submitted to the European Commission Food, Farming and Fisheries is on the EU website and you can see the status of an application searching with keywords here

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DETAILS
As of June 2020, the European Food Safety Authority has received 13 insect-related Novel Food applications. Six of these applications have entered the risk assessment phase (the others are in suitability check):

  • Whole and grinded lesser mealworm (Alphitobius diaperinus) larvae products (NF 2018/0125).
  • Dried crickets (Gryllodes sigillatus) (NF 2018/0260).
  • Dried mealworms (Tenebrio molitor) (NF 2018/0241).
  • Whole and ground mealworms (Tenebrio molitor) larvae (NF 2018/0802)
  • Whole and ground Grasshoppers (Locusta migratoria) (NF 2018/0803)
  • Whole and ground crickets (Acheta domesticus) (NF 2018/0804)

The European Commission (EC) has developed an e-submission system for Novel Food applications. At this webpage you can find the link to the e-submission systems and to the PDF with the explanations.

The timeframe in an hypothetical “ standard” case (where no additional information is requested) should be as follow:
– 1 month (European Commission, for a formal check)
– 30 working days (at the Food Authority, if a technical preliminary verification is needed)
– 9 months (at the Food Authority, for validation of all the data)
– 7 months (at the European Commission, for the draft implementing act)
TOTAL: 1 year and a half. This timeframe is hypothetical. The new Novel Food law is in place since January 2018, so there are not many precedents to refer to in terms of timeline.

When approved by the EU, novel foods are listed here.

OFFICIAL REGULATIONS AND GUIDELINES
Novel Food law, new version 2015/2283 (Nov 2015): PDF
– EFSA food safety risk assessment for the House Cricket: PDF
– guidelines for the Novel Food application (Nov 2016) PDF
– IPIFF FAQ explaining the situation as of February 2021 PDF 
– EU document on the procedural steps of the consultation process for determination of novel food status (July 2017) LINK
– New EU document on the requirements for the entry into the Union of consignments of certain animals and goods PDF

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Note: On October 2020, The European Court of Justice (ECJ) has judged that ‘food consisting of whole animals, such as whole insects, does not fall within the scope of Regulation (EC) No 258/97 on novel food’. It is unclear what are the consequences of this ruling, although it is possible to assume it will make it easier for those countries allowing edible insects to matin them on the market even in the absence of a Novel Food approval.

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