Product update and the Novel Foods EU regulation
Recently, some MAJOR things have been happening that have sapped all our time and efforts. Having reached a key milestone, we can now update you on everything we’ve been working on.
To get started, let’s recap what’s happened since our campaign in March 2021:
Spring - your amazing support helped us raise £11k and we kickstarted our new HOP BAR® product development.
Summer - technical problems and global supply chain issues caused production delays. Problems solved, we finalised flavours, packaging designs and had a first production run of HOP BAR® Salted Caramel.
Autumn - unfortunately, the quality of the first bars fell short of our standards, so we approved reproduction.
So what's the issue?
Since our last update, we have been hit by EU regulations that create new problems for us and completely scupper our schedule. It all gets a bit complicated, but the short of it is that edible insects fall under ‘Novel Food’ EU regulations introduced in 2015. This means that if insect breeders, processors and traders want to sell insects in food in Europe, they must apply for authorisation from the EFSA (European Food Standards Agency).
Before Brexit, we (UK insect start ups) and the FSA had their own clear interpretation of the EU law, which meant that we could sell insect-based foods in the UK. We retained these ‘Novel Food’ rules post-Brexit, but now the interpretation of the law is much less clear. (If you want to learn more about the specifics, comment below and I may post another update on this topic.)
The consequences of these inherited regulations have only become clear over the last few months. Essentially, insects are now not ‘authorised’ for sale in the UK nor are they a regulated product. This means we cannot secure the insurance coverage we need for our products because insects are ‘unregulated’. We cannot sell in the UK right now.
I want to clarify two things:
Edible insects aren’t illegal, they’re just not ‘authorised’ or ‘regulated’ (it’s a bit of grey area and gets complicated very fast).
This is not a health and safety issue – it’s purely a legislative hurdle we need to jump through following Brexit.
What does this mean for HOP and our customers?
We have taken the extremely tough decision to pause production to focus on removing the regulatory barriers.
We’re absolutely gutted that you won’t be able to enjoy your HOP BAR® just yet. We’ve been looking forward to sharing our bars with you, and this latest development has been incredibly frustrating.
What we have been doing about it
HOP has joined forces with twelve UK insect startups and set up a trade association, the Woven Network CiC. With their help, I have been writing an application to the government to authorise house crickets (Acheta domesticus) in the UK.
This report explains what the new food is, it’s history of consumption around the world, how it’s grown and processed, it’s nutritional composition, and explains the types of products we want to create and sell. Overall, the report was 100 pages long, included 20+ laboratory reports and 200+ scientific articles.
We have now submitted this application to the Food Standards Agency in the UK. In doing so, I think HOP and Woven have sent the FIRST EVER edible insect application to the UK Government.
No one really knows how long the authorisation process takes. We’ve been working with the Belgian Insect Industry Federation who are two years into their review process with the EFSA, but best guesses are around 18 months (!) - I have reasons to believe it won’t take anywhere near this long.
What I think about the situation
Quite frankly I think the inherited regulation is a bit stupid - it stifles food innovation, inhibits new business growth, and blocks exciting start ups from developing a healthier and more sustainable food system. There are already well established and suitable health, safety and food processing standards we follow, and the UK enjoys some of the highest food standards in the world.
The negative effects of all of this uncertainty are already causing grave consequences for our fellow insect startups across the whole UK from Scotland, England and Wales, who are having to close their farms, cease trading, and discontinue insect dishes. It’s a really sad situation.
We consider ourselves extremely lucky compared to the other insect start ups. Lucky to have your support and the silver lining from delayed HOP BAR production: we’re not sitting on thousands of pounds worth of expiring stock that we can’t sell.
But overall, I’m feeling optimistic about the outcome of the application. Over this past year, the FSA and local authorities seem quite pro-insect. In fact, a recent University of Cambridge report “Emerging Technologies that will impact on the UK food system” commissioned by the FSA, specifically recommended for edible insects that:
“FSA needs to be closely involved in the development of this sector introducing regulation and guidelines to assist in changing consumers’ attitudes towards the products, and creating an environment in which industry can prosper. This means addressing the current restrictions around novel food classification” (page 61)
My gut feeling is that the FSA has a lot on their plate at the moment - I believe they've received over 500 novel food applications since January 2021.
What's next?
Despite all the pains and difficulties, we are unwavering in our mission to bring edible insects to you and the mainstream. We know their potential to transform our food and drink for the better.
As soon as the FSA authorises house cricket in the UK we’ll resume operations. We don’t currently have a timeline from the FSA, but we’ll keep in close contact with them regarding the status of our application and in the meantime negotiate a transition arrangement along the lines of: “While we [FSA] review your house cricket application, you can sell your insect products”.
We’re launching our #BringBackCrickets campaign in the New Year to apply pressure to the UK Government to approve our innovative products and cultivate this emerging market. Keep an eye out for this on social media. We'd love to hear your thoughts and comments.
I will of course keep you updated as soon as I hear more. We want to thank you all for your patience and support in this.
Thanks,
Geoff.
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