December 2021 Newsletter No 45

Progress during this year

2021 has been a very significant year for the UK insects for food and feed sector, with a number of defining developments, some more positive than others.
In this newsletter we have a review of a few of these and bring you all up to date on some key areas of progress. We also offer some comments on what 2022 and 2023 could bring.

Developments in the Insect for Food and Feed Sector

Overseas, a number of countries have been developing their respective strategic approaches and engaging in consultation and review. Australia has published its strategic roadmap and Unconventional Connections (Nick Rousseau’s consultancy) carried out a review of the global landscape for Spectrum an NGO in Myanmar that is looking to support the development of an insect farming sector there.
During 2021, the UK Insect Bioconversion Forum (formerly Insect Biomass Task and Finish Group) under the chairmanship of William Clark at Zero Waste Scotland has been working on achieving growth in the farmed insects for livestock feed sector. In parallel a roadmap was published for the insects as feed sector in the UK, funded by WWF and Tesco, setting out its potential and the key challenges it faces, with recommendations for action by the different stakeholders.
Regarding the edible insects sector, the developments have been more challenging with the Food Standards Agency clarifying that they will require separate dossiers of evidence of safety to be submitted to them, irrespective of any outcomes from the European FSA Novel Food applications. The UK has imported European Novel Food Regulations and, to date, no insects have been approved. This has resulted in something of a crisis for the UK edible insect sector and could have resulted in its complete closure given that there are no companies with the resources to spend upwards of £70k on the laboratory testing and analysis as well as compilation of the evidence required.
At a time when the edible insect sector in the UK is experiencing considerable and rapid growth, this would have been ridiculous, especially in the year when the UK has hosted COP26. There is increasing evidence that our global food system needs to increase rapidly its sustainability. The FSA commissioned a report from University of Cambridge into future food types and this highlighted the potential that insects could play in offering more alternative sources of protein. Given that insect farms are popping up around the UK holding out the prospect of domestically sourced insect protein offering farmers and others new and highly sustainable means of meeting our food needs, this all points to the UK taking advantage of Brexit to break away from the European model of Novel Food Regulations and finding a new way to balance the risks that consumers be exposed to unsafe food products with the global risks arising from Climate Change.

Present UK status for marketing edible insects

The impact of the FSA position is being felt across the country, but different Local Authorities (LAs) and National FSA equivalents are all taking their own line, which makes for a complex picture. It's up to the LA to enforce food regulations. Two LAs have said no so far - N Somerset and one in London. One of our Director’s Local Authority is prepared for them to continue trading despite the FSA saying that insects are an 'unauthorised novel food', and have not granted the industry a transitional period to allow products to stay on the market. The reason this Local Authority has said they can continue is because they have not received an 'FSA Smarter Communications Platform' notification to say that local Food Business Operators should not be marketing insect based products. This is the official communication channel that the FSA uses to communicate with local authorities. 
In addition, some of our members are having trouble renewing their Safe And Local Supplier Approval. Despite passing all the requirements of the audit, Local Authorities have been reluctant to grant approval for human food until there has been a confirmation from the FSA on the situation. This further illustrates the damaging impact of the FSA position despite our members all being fully in compliance with good practice for food production.
If any of you are keen to get started selling insects then we recommend that you first contact your local Environmental Health Officer (or your copacker's local EHO if someone else is distributing your product) and ask them if you are all right to sell products containing Acheta domesticus crickets or Tenebrio molitor mealworms. They should say yes, but may not. If they say yes, then you are good to go. Just note that the FSA could, at any time, send a communication to local authorities instructing them to enforce a policy which would take insect based products off the market.
It would also be worth you checking that your product and public liability insurers are aware of what you are doing and will cover the risk. Some of our members have had some issues in this regard. 

The Woven Board is of the opinion that we should make hay whilst the sun shines - but it is your decision if you want to take the risk.

Woven Network transformation - Woven 2.0

The Woven Network response to changed circumstances has been to develop a way forward for the sector. This has meant Woven changing fundamentally its nature and focus. Up until this year, Woven has been run as an informal, volunteer-run Community Interest Company (CIC) catering to a diverse international membership of parties who have interest in the insect farming sector. On 15 December 2021, by unanimous agreement, the members voted for the Woven Network CIC to change its aims to:
Supporting and meeting the needs of businesses with a base in the UK involved in the insects for human consumption domain.”
In addition, the Memoranda and Articles have been revised so that the Woven will be led by an elected board voted from its membership which will be responsible for setting the agenda for the Woven Network, managing contracts with a professionally delivered Executive (initially delivered by Unconventional Connections Ltd).
On 15 December 2021, we also saw a new set of Directors being voted in unanimously:
We shall shortly load profiles of the directors onto the Woven website. This group has already set out their vision for how Woven can serve better the sector and we look forward to seeing these coming to fruition.

Working with the FSA and Novel Food applications

While these formalities have been progressing, the Woven Network has been acting increasingly as a convener and voice for the edible insects sector in the UK. This has involved five main strands:
  • Dialogue with the FSA and DEFRA regarding the status of edible insects in the UK, emphasising the considerable evidence that the products in the market now and in the recent past are entirely safe and the potential contribution the sector could make to the UK economy and food sustainability if it can be allowed to operate
  • Guided by our members, engaging with the media regarding the situation to ensure clarity of messages and avoid raising concerns amongst the public regarding the safety of food products containing insect material
  • Building an agreement with the Belgian Insect Industry Federation on sharing the costs of producing material to prepare Novel Food dossiers to submit to the EFSA and FSA – BiiF have been working on this for a number of years for the EFSA
  • Building “clubs” of members in UK edible insect sector to collectively cover the costs of this and develop Novel Food dossiers for the FSA, based on the Belgian material
  • Throughout this, providing a platform for sharing of information amongst members and keeping our members informed and able to make their own decisions regarding trading in edible insect products, and explaining the situation to the growing number of new entrepreneurs coming into the sector and welcoming them into Woven.
As a result, we are very pleased to report that:
  • With many thanks to Geoff and the team at Hop, the Woven Network submitted a Novel Food dossier to the FSA on 16 December for Acheta domesticus. This reflects the range of products that companies wish to bring to the UK market
    • o   Instar Farming

      o  Monkfield Nutrition

      o   Eat Grub

      o   HOP

      o   Nutribug

      o   The Grub Kitchen / Bug Farm Foods

      o   Protein Rebel

      o   Yum Bug

      o   Prosects

      o   Throne Farm

      o   Saved Food

      o   UK Tiny Farms

  • Thanks to the work of Alex Capel at Mini Feasts, we are also close to submitting a Novel Food dossier for Tenebrio Molitor.
    • o   Mini Feasts

      o   Monkfield Nutrition

      o   The Grub Kitchen / Bug Farm Foods

      o   Yum Bug

      o   Saved Food

  • These dossiers will be publicly available, and will enable others to enter the market in the coming years, provided they are selling products that fall within the range set out.
  • We believe the FSA has taken on board the considerable evidence in the two reports that we submitted regarding the potential of the sector and the safety of insect products. While they have notified Local Authorities of the situation regarding the requirement for Novel Food approval of insect products, they have not demanded that all such products be withdrawn from the market. We believe this shows that they accept that our members’ products do not pose any risk to consumers. Further, the FSA is commissioning a study of other Regulatory models for food products around the world which we interpret as meaning that they accept that the Novel Food Regulations imported from the EU are not fit for purpose given the considerable dampening impact they have on innovation.
  • This progress is reflected in our growing membership which stands currently at 34, including 19 organisational members within a sector that is growing rapidly, as set out in our report on the state of the sector.
  • New companies can still join groups working on these two dossiers. This will help ensure that the dossiers reflect your products, your company's needs, add to our ability to cover all the costs of further research that may be needed to respond to questions that the FSA raises, and ensure we secure approval. Email if you are interested.

Prospects for 2022 and beyond

We have been advised to expect that it can take around 18 months for Novel Food approval to be granted. We also know that the FSA is under huge strain with large numbers of Novel Food applications. However, we are committed to continuing to work with them towards securing the approval we need, under the current legislation. We look forward to an interesting period as we build our joint understanding of all the evidence of safety of insect products. We are 100% confident that the outcome will be to grant approval of Acheta domesticus and Tenebrio molitor for the UK market.
We retain an interest in other insects being allowed into the market and will work with the sector to find ways to secure this. We have yet to explore fully the potential for the alternative route allowed under Novel Food Regulations based on evidence of a history of consumption within non-EU countries. Also, should there be proposals for changes in the legislation regarding food innovation, we will be happy to engage in the debate.
The Woven Network is a member of a small consortium that has submitted a funding bid to UKRI under the Transforming the Food System programme for a 2-year project investigating the barriers to growth for the farmed insect sector in the UK. Should we be successful in securing the funding, that will provide resources to carry out consultations and research to develop evidence that we hope can be converted into a roadmap for the growth of the edible insect sector with concrete recommendations for Government and other bodies.
This all presents a really strong, positive prospect for the edible insect sector in the medium term future. However, we also need to focus on the more immediate situation during this period before Novel Food approval is granted.  The Woven Network will continue to engage with the FSA and wider stakeholders to press for transitional arrangements that can allow products containing edible insects to be fully accepted within the UK market.
In the meantime, we will, guided by our new Directors, continue to support the sector’s growth, internal connections and collaborations and positive perception by consumers. Edible insect products have evolved enormously from when I started out on this journey in 2015 with a small group of fellow enthusiasts. The UK is at the forefront of innovation in new product development. We are very excited to offer the full diversity of what insects can offer the consumer!
Currently, we are working on a webinar on UK-EU trade in edible insects and associated products, in partnership with IPIFF and BiiF.  Email if you are interested to receive further details.

Our next newsletter will set out our plans for 2022 in more detail, so watch this space.
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