cuisinopedia

EU Novel Foods Regulation and Regulatory Landscape

Animal & protein

What it is

The legal framework governing insect food in Western markets has been one of the key structural factors shaping the industry's development. The European Union's Novel Foods Regulation (EU 2015/2283) is the central regulatory framework for insect foods in Europe and has been the most consequential regulatory development for the global Western insect food industry.

The EU Framework: The EU Novel Foods Regulation requires that food products that were not commonly consumed in the EU before May 1997 must undergo a formal safety evaluation and receive authorization before they can be placed on the market. Insect species consumed in traditional non-EU food cultures qualified as "novel foods" under this framework. The pathway to authorization involves submission of a safety dossier to the European Food Safety Authority (EFSA), which conducts a scientific risk assessment, followed by a European Commission decision on authorization.

The first authorizations of specific insect species as novel foods in the EU came through between 2021 and 2023, following EFSA assessments:

  • Dried yellow mealworm (Tenebrio molitor larvae) — authorized for use as a snack food, in flour, and as an ingredient in several food categories (January 2022)
  • Migratory locust (Locusta migratoria), frozen, dried, and in powder form — authorized (November 2021)
  • House cricket (Acheta domesticus), frozen, dried, paste, and powder — authorized (January 2023)
  • Lesser mealworm (Alphitobius diaperinus) larvae, frozen, paste, dried, and powder — authorized (January 2023)

These authorizations established the legal basis for insect food products to be sold in EU member states, though individual member states retain some discretion, and labeling requirements (including specific allergen warnings for crustacean and house dust mite cross-reactivity) apply.

The UK Regulatory Position: Following Brexit, the UK's Food Standards Agency established its own novel foods authorization pathway. Several insect species received authorization in the UK, generally aligned with the EU trajectory but through a separate process.

The US Regulatory Position: The FDA in the United States has not issued specific novel food regulations for insects, and the regulatory status has been somewhat ambiguous. Insect species "generally recognized as safe" (GRAS) as food ingredients can be marketed without pre-market approval, and several companies have marketed cricket flour and other insect ingredients under the general food safety framework. There is no specific GRAS designation for edible insect species as a class, but FDA has generally not taken enforcement action against insect food products meeting standard food safety requirements.

Allergen Considerations — The Cross-Reactivity Issue: A significant food safety consideration specific to insect foods is the cross-reactivity between insect proteins and shellfish (crustacean) allergens and house dust mite allergens. The proteins that trigger shellfish allergies (primarily tropomyosin) are structurally similar to proteins present in insects, because insects and crustaceans are arthropods with shared evolutionary heritage. Individuals with shellfish allergies may therefore experience allergic reactions to insect consumption, and this cross-reactivity is the primary food safety concern for insect products in Western markets. EU labeling requirements for authorized insect foods specifically require warning information for individuals with shellfish and house dust mite allergies.

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