Legislation

Novel Food Dossier of Proti-Farm

In accordance with the new EU legislation on ‘novel foods’ (i.e. Regulation (EU) 2015/2283) Proti-Farm is currently preparing an application for the buffalo (Alphitobius Diaperinus) within the European Union. For that purpose, the company is drawing up a scientific dossier which contains comprehensive information & data demonstrating the safety of buffalo for use as food (i.e. for use as final product or as an ingredient). Pending the final validation of this application by the European authorities (i.e. the European Commission, the European Food Safety Authority & the EU Member States) whole parts of buffalo and its preparations can continue to be placed on the market.

Client products in the novel food dossier of Proti-Farm

The EU legislation on ‘novel food’ (i.e. Regulation 2015/2283) does not specifically address if final products should be included in the application for a novel food dossier. A novel food dossier shall cover the ‘novel’ ingredient (e.g. in the case of Proti-Farm buffalo larvae species and defatted insect powder) and not the final product which will be composed of the novel food (e.g. a burger or other food product composed of the buffalo larvae as ingredient). However, information on the future use of the ‘novel food ingredient’ is preferred for evaluation of its dietary and nutritional significance and to carry on the risk characterisation (by EFSA). The EFSA guidance document from November 2016 refers specifically to this question in chapter 2.7. (page 16): As mentioned in 2.7.2, the applicant should notably specify the followings:

  • The form of uses (e.g. as whole or ingredient)
  •  The food category in which the food is proposed for use
  • The maximum amounts in products as consumed

Conclusion: it is good (but not a requirement) to provide detailed information about the existing or future use of the new (buffalo larvae) ingredient in the novel food dossier. Therefore, Proti-Farm welcomes its (existing and new) clients to send in information on their ‘final’ products so it can be evaluated to put in the NFD of Proti-Farm.

Novel Food Legislation

With an increasing number of people interested in eating insects, governments are starting to see that they should adapt regulations to fit this new reality. Regulations should be geared to enable insect foods to be placed on the market while at the same time securing  consumer safety. At Proti-Farm, we understand the importance of such Regulations and closely collaborate with (inter)national authorities and stakeholders in this field. In particular we do this as member of the Dutch Venik association and as Founder & Executive Member of IPIFF (International Platform Insects for Feed and Food) in Brussels.

Existing Novel Food Regulation (in place till 1 January 2018)

In order to place a Novel Food product on the market, a food operator has to demonstrate the product’s safety. They do this by applying for authorization through the procedure outlined in Regulation (EC) 258/97, the list of novel food applications submitted can be found at: Applications under Regulation (EC) 258/97 . The scientific aspects and the presentation of of information necessary to support such applications are given in Commission Recommendation 97/618/EC. Under the existing regulation, applications have to be submitted to the member state of the EU in which the product is to be placed on the market for the first time. It is important to note that it is unclear whether ‘whole insects and their application’ fall within the scope of the current regulation. This had made it possible to sell certain insect products in, e.g. the Netherlands and Belgium. Novel Food list of application submitted, on the EFSA site: Novel Food List

New Novel Food Regulation (in place 1 January 2018)

On 1 January 2018, Regulation EU 2015/2283 on Novel Food enters into application. This is replacing the current rules adopted in 1997. The new regulation will introduce a simpler, clearer and more efficient authorization procedure, centralized at EU level. This should enable safe and innovative food to be placed on the European market faster. From that date onward, applications will be assessed centrally by the European Commission with the help of the European Food Safety Authority (EFSA). The new regulation clarifies that whole animals, such as whole insects (if not consumed to a significant degree in 1997) fall under the definition of Novel Food. Parts of insects (legs, wings) are also considered as Novel Food. So all insect-foods need to be authorized before being sold on the EU Market. However, because in some countries insect products are already ‘lawfully placed on the market’ certain transitional measures apply. This makes it possible for insect-foods to continue being sold until the 2nd of January 2020. An application for authorization of insect foods needs to have been submitted before this date in order for food operators to continue selling insect-foods. For more information about Novel food:

IPIFF position paper on the revision of the EU Novel Foods legislation

IPIFF position paper on the revision of the EU Novel Foods legislation