FSA consultation on transitional arrangements for edible insects in Great Britain

FSA edible insects consultation

Note – this consultation is now closed. We explore the resulting disastrous consequences for the U.K. edible insect industry in our 2023 post.

Please support our quest to save the Edible Insect industry in Great Britain.

Having declared edible insects illegal in Great Britain after Brexit (31st Dec 2020), the Food Standards Agency has only recently (30th June 2022) retracted its earlier ban, admitting it made a mistake.

The FSA is now trying to push through in a hurry (FSA Edible Insects Consultation – deadline for replies 10th August 2022) – regulations that will involve subjecting edible insects to the same  “Novel Food” legislation, which is used, for example, for lab grown meat.  Instead of using Brexit as an opportunity to disentangle the UK from the red tape of the EU, and align with Australia, New Zealand, Canada, and many other countries, where insects are regulated under general food law, the FSA, is now resorting to a quick [bad] copy paste of the EU Novel Food regulations.  Unfortunately these  EU regulations had nothing to do with food safety and a lot to do with protecting the interest of the big food lobbies  , backed by the capital venture sponsored megafarms, that have already monopolised the production of edible insects in the EU.

Our replies to the FSA Edible Insects Consultation available to copy and paste if you wish

Below are our answers to the FSA consultation. If you like them, you can just:

• if you are a business, update answer 5 & 6
• cut and paste 1- 7 and email to Novelfoods@food.gov.uk stating whether you are responding as an private individual or on behalf of an organization/company (including your details)
• add horizoninsects@gmail.com in .bcc to get a £5 discount per person on a cookery class in 2022 (if we can resume trading this year !) 

Full link to the consultation is here.

Dear FSA – here’s my response to your consultation request. I’m responding as an individual

Questions asked in this consultation:
1. What effects do you think there would be from the outlined policy proposal? How could positive effects be increased, or negative effects be mitigated?

This policy contains ambiguities and it will prolong the uncertainty surrounding the legality of edible insects in the Great Britain. The industry has already been brought to its knees and does not need further transitional measures. We object  to further transitional measures and ask for the FSA to reclassify insects at ‘Not Novel’ .  To ensure they meet safety and hygiene standards, edible insects should be regulated under general food law.

2. 3.4.The outlined policy proposal provides a deadline of 31 December 2023 for food business operators (FBOs) to submit their application to the FSA or FSS.  This deadline has been identified as a date which takes into account the need to provide FBOs with sufficient time to prepare an application, and the public interest in novel foods progressing through the relevant authorisation process as quickly as possible.  Do you feel this deadline is appropriate, having regard to the balance between these considerations? If not, please propose the timeframe you consider to be acceptable with a justification.

Should the FSA decide to pursue the Novel Food route for edible insects,  Small and Medium Enterprises will need time to raise funds to be able to afford the lengthy Novel Food Application process. As published by several Local Health Authorities, SMEs will not be able to easily gather the necessary funds. https://www.bromley.gov.uk/leaflet/329070/3/757/d  “The evidence you submit should be specific to your product; therefore gathering together publicly available information will not be sufficient. Any business seeking approval for a novel food will probably need to conduct independent scientific research (which will be beyond the technical / financial means of some small and medium-sized businesses).”  This alone would be a reason to abandon the Novel Food approach. In any case most SMEs will benefit from a longer deadline because of costs – we suggest a date of 31 December 2024. 

5. For businesses producing insect protein, will the policy proposal affect your plans for your business (for example, expansion, or a change in the kinds of products produced)?

n/a

6. Please provide the name and location of your business in your response, noting  the data received will be treated in accordance with the privacy policy.

n/a

7. Please include any other factors that you think should be considered by the FSA or FSS in relation to the regulation of edible insects in GB, or any other feedback.

Rather than over regulate the sector through Novel Food legislation, the FSA should take a more proactive approach. The FSA should define standards to facilitate the commercialization of edible insects. like for example specifying the requirements, sampling and test methods for edible insects. We want to be able to enjoy  eating as many as possible of the 1900 species researchers have identified as edible to date.