New European Union Regulation
On January 3rd 2023, regulation was passed allowing companies in Europe to use house crickets (Acheta domesticus) as an ingredient in a variety of food items in the form of powder. The request was made by Cricket One Co. Ltd, a company specialized in farming crickets for consumption. V-Label is the world’s leading vegan and vegetarian trademark, and has well-defined regulations as to when a product can carry a label, and deems this regulation problematic.
The list of products targeted by the regulation includes baked goods such as multigrain bread and rolls, crackers, breadsticks, cereal bars, and biscuits, but also sauces, pizza, processed potato products, soups, chocolate products, nuts and oilseeds, and even beer. “Highly problematic is the inclusion of “meat analogues” in this list, which are food products made from vegetarian or vegan ingredients, produced to approximate qualities of specific types of meat – such as mouthfeel, flavor, appearance, or chemical characteristics – and therefore serve as an alternative,” comments Tim De Smet, V-Label’s international communications manager. According to EU law, insect protein powder is considered a product of animal origin, as this falls under the category of “food consisting of, isolated from or produced from animals or their parts”. They must also be marked accordingly.
The regulation indicates that “(9) […] the Commission considers that no specific labelling requirements concerning the potential of Acheta domesticus to cause primary sensitization should be included in the Union list of authorised novel foods” if “evidence directly linking the consumption of Acheta domesticus to cases of primary sensitisation and allergies is inconclusive.”
“This means that the only requirement to label the product to indicate it contains house crickets would be if there is direct evidence for allergies. The use of crickets might be problematic for consumers allergic to crustaceans, mollusks, and dust mites,” Tim De Smet elaborates. “Consumers are thus left to fend for themselves, having to analyze the ingredients lists on products to see whether Acheta domesticus or other insects are listed.” Even if certain EU member countries currently take the position not to grant the novel food transitional measure to whole insects and/or their derived products, their position might change over time.
EU regulation on the inclusion of insects is not new, however. In June 2021 the company SAS EAP Group was authorized to place dried Tenebrio molitor (yellow mealworm) larva on the market as a novel food, either as a whole or as a food ingredient in a number of food products. Authorization was also given to Fair Insects B.V. in November 2021 for frozen, dried, and powder forms of Locusta migratoria as a novel food, and in February 2022 for Acheta domesticus and Tenebrio molitor. These regulations are all similar in their indication for labeling, stipulating that there is no need for specific requirements, as “few allergic cases have been reported.”
As the terms “vegetarian”, “vegan”, or “plant-based” are not protected terms by EU law or in any EU country, they can be used freely by producers and retailers on any product packaging without the need for quality checks or label accuracy. Products offered as meat analogues can therefore contain Acheta domesticus without any indication apart from the ingredient list. “Although this might be highly unlikely, as this would be clear consumer misdirection, it is not a good foundation for fostering trust,” clarifies De Smet.
The regulation, in this regard, is a step backward when it comes to transparency for producers. Especially as the number of flexitarians (over 40% of the global population), vegetarians, and vegans is on the rise, consumers demand clear indications on whether products are suitable to their dietary preferences.
“In order for products to be licensed,” according to De Smet, “V-Label licensees must provide a clear breakdown of all ingredients and prove whether they are (by the V-Label definition) vegan or vegetarian – even those that ultimately do not have to be shown on the label ingredients list by law.” Therefore, the products licensed by V-Label can be classified as safe for those avoiding animal ingredients.
Consumers might not bite
Furthermore, not all consumers are happy to eat insects. According to the Food Standards Agency survey, where 1,930 adults participated, 67% reported that nothing could make them try edible insects, while only 13% could be persuaded if they knew the insects were safe to eat and 11% if they looked appetizing. Disgust and neophobia (the fear of trying something new, which can especially be present when trying new food) are clearly hurdles to overcome.
Apart from this, the ecological footprint of these insects as food is still significant: for every 1 kg of house crickets, it still requires 1.7kg of feed, and still produces 20% of the methane emitted by beef production. Brands who want to be identified as sustainable and ecologically responsible would do well to focus on providing vegan products instead.
More and more, consumers ask for transparency when it comes to the food they buy. Having to keep an eye out for a new certification to ensure products are cricket-free or having to read through the ingredient list can be cumbersome.
Of all European consumers who have seen the V-Label on products, 60% never or rarely check the ingredients of a product to see if it’s vegetarian or vegan when it is marked with the V-Label symbol. These consumers associate the label to products being free from animal-based ingredients, and deem these products as being healthier (69%) and more trustworthy (59%). [Source: FMCG Gurus – Meat & Plant-Based – Global Report 2022]
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