Supporting you in your alternative protein and novel food product regulatory approval journey

A recent UK Government report titled The Benefits of Brexit: How the UK is taking advantage of leaving the EU, states in the UK it will no longer be necessary to follow the EU process for approving novel foods. Instead, the UK will have a system specifically designed to “support innovation in the sustainable protein sector”.

According to the report, the government will work with the Food Standards Agency (FSA) to update the regulatory framework, creating a system that is “the best in the world for innovators, investors, and consumers”.

As a leading advisor to UK Government across food safety policy and regulatory landscapes in the alternative proteins and novel food arena, indeed one of our principal scientists Dr Adrian Charlton has been asked to respond to the consultation on edible insects as novel foods to ensure the proposed regulatory framework is appropriate, we are your ideal partner to support you bring your product to market under the Novel Food Regulations.

The UK’s novel foods regulations will be reviewed to make them more “transparent and effective”.

What requirements must be met by the novel food in order to be authorised?

Without an authorisation, cultured meat, cell-based dairy or egg alternatives, or other alternative protein products falling under a novel food category may not be placed on the UK market. In summary, the novel food must meet three basic requirements to be authorised.

1. Firstly, only those novel foods, on the basis of scientific evidence available do not pose a safety risk to human health, are authorised. 
2. Secondly, the novel food’s intended use may not mislead the consumer.
3. Thirdly, where the food is intended to replace another food, it may not differ from that food in such a way that its normal consumption would be nutritionally disadvantageous for the consumer.
   
   The authorisation is granted with regard to a specific novel food and not with regard to the product of a specific applicant. This means that an authorised novel food may in principle be put on the UK market by any food business operator and not just the applicant. This would be annoying for applicants, as carrying out the authorisation procedure and providing the necessary scientific studies involves considerable effort and costs.
   To recognise these efforts regulators under certain conditions and upon request grants the applicant not only an exclusive right with regard to the authorised novel food but also protection with regard to the scientific data on which the application is based. To be granted protection the application must be based on newly developed and proprietary scientific evidence and data.
   If protection is granted, for a period of five years only the applicant may place the authorised novel food on the UK market.