1. Edible insects and missing legislation: the EU outlook 1. ISTITUTO ZOOPROFILATTICO SPERIMENTALE DELLE VENEZIE, Legnaro (PD), ITALY sbelluco@izsvenezie.it; aricci@izsvenezie.itsbelluco@izsvenezie.itaricci@izsvenezie.it 2. Department of Nutrition, Exercise and Sports, University of Copenhagen, Rolighedsvej 26, 1958 Frederiksberg C, Denmark aha@nexs.ku.dkaha@nexs.ku.dk 3. University of Padua, Department of Animal Medicine, Production and Health, Campus Agripolis, 35120 Legnaro (PD) Belluco, S 1,3, Halloran, A 2, Ricci, A 1. COMMENTS CURRENT LEGISLATION Reg. 258/1997 “Novel food” refers to foods and food ingredients which have not been used for human consumption to a significant degree within the Community before 15 May 1997 AND “foods and food ingredients consisting of or isolated from plants and food ingredients isolated from animals …”. Whole insects are exempted from the regulation because the word “consisting” is missing as regards animals There are no EU rules regarding insects as food National rules are legitimate (Concurent legislation) Belgium, UK Whole insects are not exempted since the word “consisting” is missing only for hystorical reasons Insects are NOVEL FOOD Approval pathway needed EU, Italy IMPORT Import of insects fit for human consumption from outside the EU is prevented by the lack of rules and consequently the impossibility for third countries to follow the FVO approval pathway. Personal import (from countries outside the EU) limited quantities of edible insects, are allowed according to Reg, 206/2009 but rather they seem to be subject to veterinary checks. Thus, import feasibility varies among countries. Insects quantities below 2 kg/person can be imported according to Reg. 206/2009 Edible insects need to be checked by veterinarian. Absence of official requirements, impossibility to perform checking. DEFRA (UK) personal import rule database. Italy, Germany Notification: INFO A Commission EU Applicant Union list update Safety objections (within 4 months) Market authorization No Market authorization No Union list update Application INFO A + INFO B Applicant INFO B: documented data relating to the reasoned safety objections submitted in accordance with Article 14 Commission EU EFSA Member states EVALUATE (six months) -whether the history of safe food use in a third country is substantiated by reliable data submitted by the applicant in accordance with Articles 13 and 15; -whether the composition of the food and the conditions of its use, do not pose a safety risk to human health in the Union. Supplementary information OPINION ApplicantCommission EUMember state Draft implementing act to authorise the placing on the market within the Union of the traditional food from a third country and to update the Union list taking into account INFO C. INFO A (art 13) -the name and a description of the traditional food -its composition -its country of origin -documented data demonstrating the history of safe food use in a third country -where applicable, the conditions of use and specific labelling requirements, which do not mislead the consumer INFO C (a) the conditions provided for in Article 6 where applicable; (b) any relevant provisions of Union law; (c) the EFSA's opinion; (d) any other legitimate factors relevant to the application EFSA No authorisation, no union list update EU legislative outlook New EU Reg. under discussion COM(2013) 894 final Lack of harmonization between member states Scientific data needed Consumer protection? ALLOWEDNOT ALLOWED ALLOWED NOT ALLOWED LEGAL FRAMEWORK EXPECTED Reg. 853/2004 Food of animal origin Reg. 2073/2005 Microbiological criteria Reg. 1881/2006 Chemicals Reg. 1069/2009 By-products Reg. 1/2005 Transport of live animals Not required? Reg.1099/2009 Stunning Not required? WORD CLOUD Reg. 853/2004 Guarantees for producers?