What can we learn from the recent questions on alternative proteins put to the European Parliament?
In this article, we summarise recent questions surrounding the topic of proteins submitted to the European Parliament by Members of the European Parliament (MEPs) between November 2022 and April 2023.
Twenty questions were submitted during this time, some of which had incredibly provocative titles, such as “No to synthetic food: call on the Commission to stop funding for artificial food and to protect agriculture, livestock farming and traditional sectors” and “EU forcing us to eat insects”.
The questions are formatted to make an opening statement (mostly well researched and in reference to current EU legislation) about the topic of choice before asking several questions relating to these statements.
The Commission’s answers to the questions can be a little vague and general, often signposting to relevant legislation or current projects rather than answering directly, nonetheless they hold interesting and relevant information.
We summarise some of the key highlights below.
Out of the twenty questions summarised, four were related to the EU’s overall protein strategy. In these questions, the MEPs referred to the EU’s Farm to Fork strategy and Green Deal objectives and wanted to know what steps the EU are taking to;
Improve food security by reducing dependence on imported agricultural products and inputs by increasing EU production of plant proteins.
Increase the cultivation of crops for human consumption, not only for animal feed within Europe.
Reduce dependence on critical feed materials, including soy, by focusing on EU-grown plant proteins and on alternative feed materials such as insects, marine feed stocks (e.g. algae) and bioeconomy by-products (e.g. fish waste).
Increase the availability and number of sources of alternative proteins such as plant, microbial, marine and insect-based proteins and meat substitutes.
Publish a legal framework for plants produced using targeted mutagenesis and cisgenesis and for their food and feed products.
In response to these questions, The Commission stated that it is performing a comprehensive review of its Protein Policy, which it plans to deliver during the first quarter 2024.
They said that ‘The aim is to further investigate all sources of plant-based proteins, including for human consumption and alternative ones, as well as ways to increase their production in the EU. Stakeholders and Member States will be in a continuous dialogue during 2023, including with Civil Dialogue Groups on agricultural markets, crops market observatory or other specialised expert groups.
The review will have a comprehensive scope, looking at import dependencies, promoting the production of plant-based and alternative proteins in the EU, analysing the demand for protein in the livestock sector and considering ways to increase plant-based protein in the human diet.
The aim is to increase food security while reducing the impact on the environment and climate both in the EU and globally.
Therefore, the review will go beyond the Common Agricultural Policy and will encompass the full spectrum of feed and food production in a systemic way identifying drivers, levers and policy pathways. The Commission review will include a dialogue with stakeholders and Member States.’
Regarding a framework for plants produced using targeted mutagenesis and cisgenesis, The Commission plans to adopt the new proposal in June 2023.
Insect related questions
There’s been quite a buzz around insect proteins in Europe since we saw the first six products gain approval as novel foods (Acheta domesticus (house cricket) partially defatted powder, Frozen, dried and powder forms of Locusta migratoria , Frozen, dried and powder forms of yellow mealworm (Tenebrio molitor larva), Frozen, dried and powder forms of Acheta domesticus , Dried Tenebrio molitor larva , and Frozen, paste, dried and powder forms of Alphitobius diaperinus larvae (lesser mealworm). Out of the twenty questions summarised here, twelve were related to insect consumption, with an overall feeling of fear surrounding the safety of insect products and transparency with labelling. The key themes that came up within the questions were;
What has changed since 2015 when EFSA published a document stating that much more research is needed to ensure the safety of insect consumption and highlighted the concern that antibiotics used in the breeding of insects could contribute to the development of resistance. This report also stated that the environmental impact of insect farming is roughly comparable to those of other forms of stockbreeding.
How do we know that insects are safe to eat?
How will the labelling of products containing insects be clearly labelled? Will there be a logo or an image of the insect?
Why is it not possible to view the safety data for recently approved insect ingredients?
Why are insect products being approved as food within Europe? Are we blindly following World Economic Forum (WEF) propaganda? Is it in the name of saving the planet and reducing meat consumption, all while ending world hunger? And if this is the case, what is the EU doing to combat food wastage?
In response to these questions, The Commission stated that it is currently processing eight applications for insects in different forms, which are being subject to a safety evaluation by the European Food Safety Authority (EFSA). Until now, six insect products have already been authorised as novel foods in the EU. The Commission stressed that the risk assessment and risk management process is thorough, and no product would be approved for the EU market if it was not considered to be safe.
To demonstrate that they are taking these safety concerns seriously, The Commission stated that ‘Policy making in the area of food safety needs to be underpinned by strong technical and scientific evidence. The epidemiological evidence on the potential of insects to provoke primary sensitisation that could lead to allergic reactions when insects are consumed is limited and equivocal.
The Commission is currently exploring ways to carry out the necessary research on the allergenicity of insects under the Horizon Europe Framework Programme for Research and Innovation. For example, the project Giant Leaps (September 2022-August 2026) will study five innovative protein ingredients, including insects.
While one work package will specifically focus on health and digestion, the question of allergenicity will also be investigated in a work package dedicated to the optimisation of the dietary shift.’
When it comes to labelling, The Commission answered that all food placed on the EU market must comply with the labelling requirements of Regulation (EU) No 1169/2011 (the FIC Regulation) which the European Parliament feel is rigorous enough to ensure clear product information to consumers. In the case of food containing insects, the name of the insect needs to be clearly labelled using scientific name followed by the common name in brackets. This name must be included in the list of ingredients. In addition, a statement, near the list of ingredients, must indicate that this ingredient may cause allergic reactions. There is no intention of making it a requirement to include an image of the insect ingredient.
The Commission highlighted that the reason for safety data not being accessible to the general public for insect authorisations approved to date, is because the applications were submitted prior to the Transparency Regulation. The data, however, may be accessed via the public access to documents request as outlined in Regulation (EC) No 1049/2001. The non-confidential version of the novel food dossier including supporting information submitted after 27 March 2021 is now made public.
In response to being asked whether the EU is blindly following WEF ‘propaganda’, The Commission made clear that they are aware of the campaigns of various organisations and stakeholders, and of scientific evidence that consider that the current food consumption patterns are unsustainable. They are also aware that a broad food systems approach is necessary, as captured in The Commission’s Farm to Fork Strategy, but that this does not influence their decisions.
Regarding food waste - with one third of all food produced not being eaten - the response assured that the EU is taking the matter of food waste seriously and that The Commission has carried out important steps to prevent food waste since 2015, such as elaborating a common EU methodology to measure food waste consistently; establishing the EU Platform on Food Losses and Food Waste and taking measures to clarify EU legislation related to waste food and feed, and examining ways to improve the use of date marking. A citizens’ panel was convened to discuss how-to step-up action to reduce food waste in the EU.
Three of the questions were concerned with cultured meat and ‘synthetic’ food, again with a fearful and negative tone surrounding safety, freedom of choice and also concerns for animal welfare when it comes to using FBS in cultivated meat production. One question asserted that “Artificial food severs the age-old relationship between food and nature. Test-tube food will jeopardise the jobs of millions of farmers, stockbreeders and supply chain operators, as well as the socio-economic cohesion of farming areas”. The main points from the questions were;
There is a lack of comprehensive lifecycle analysis, and it is not clear whether cultivated meat is truly better for the environment. What is the EU’s position on new forms of meat and is it performing independent (non-biased) studies?
How will the EU protect consumers to clearly distinguish between conventional meat and the ‘alternatives’?
Is the EU considering the impact of synthetic meat on conventional meat production chains?
How much general funding goes to support research into synthetic food?
Does the EU know how many bovine foetuses are used to produce FBS in the EU each year and which facilities they are being collected in? And can it explain what measures are currently being taken to ensure that foetal suffering is reduced to a minimum?
Similar to the responses to the questions surrounding the safety of insect consumption, The Commission reassured that according to the General Food Law, food shall not be placed on the market if it is unsafe. When alternative sources of proteins fall within the scope of the novel food Regulation, they can only be placed on the EU market after a pre-market authorisation has been granted by The Commission, based on a safety assessment performed by EFSA, this also applies to imported products. So far, no cultivated meat product has been authorised in the EU.
In regard to preventing consumers from being misled, they said “It is a principle of the General Food Law to provide a basis for consumers to make informed choices in relation to the food they consume, and to prevent any practice that might mislead them. In the framework of rules on the hygiene of food of animal origin, the term ‘meat’ is defined as being edible parts of domestic ungulates, poultry, lagomorphs, wild game or farmed game. Moreover, the Food Information to Consumers Regulation has laid down provisions that prohibit the use of information that would mislead the consumer. In the absence of authorisations for these products as novel foods in the EU, such labelling provisions have not been developed.”
The Commission agreed that data on cellular agriculture and its potential impact are still scarce so there is a need for more knowledge and understanding of its ability to contribute to the objectives of the Farm to Fork Strategy and represent a viable source of proteins. They guaranteed that Horizon Europe, the EU’s funding programme for Research and Innovation (2021-2027) will look into these issues further. For example, the project Giant Leaps that started in September 2022 will study the nutritional, safety, allergenicity and environmental impact of alternative sources of food proteins.
The Commission is supporting research to improve knowledge on potential environmental and health impacts of cultured meat and cultured seafood products under Horizon Europe. In the 2023-2024 work programme for Cluster 6 ‘Food, Bioeconomy, Natural Resources, Agriculture and Environment’, it launched a EUR 7 million topic entitled ‘Cultured meat and cultured seafood – state of play and future prospects in the EU’. As clearly stated in the topic, the objective is to develop a knowledge and evidence-base on the potential sustainability aspects of these food products.
They said that few companies involved in the manufacture of cell cultured meat/milk have received EU funding for research and innovation. Under Horizon 2020, about EUR 4.5 million were provided to four projects focusing on cultured meat and one topic (EUR 7 million) will directly focus on cultured meat. Another topic funded one project (Giant Leaps, EUR 10.3 million) through the Cluster 6 Work Programme 2021-2022, where cultured meat is addressed only to a limited extent. The objective of these topics is to fill knowledge gaps and explore opportunities and drawbacks of such food products, with the aim to supply the needed evidence-base.
In regard to the questions about FBS, The Commission stated that it does not have information on the annual production of foetal bovine serum (FBS) in the EU. FBS is considered an animal by-product and is subject to rules laid down in Regulation (EC) No 1069/2009 (‘Animal by-products Regulation’) which does not require collection of data on the production of animal by-products in the EU.
Member States are responsible for the implementation of the above EU law and may keep the aforementioned information on the production of FBS. An approved slaughterhouse may perform any slaughtering operation, including production of animal by-products. All animals in the EU are slaughtered in accordance with Regulation (EC) No. 1099/2009 to prevent suffering of animals during slaughtering.
Unfortunately, the Commission did not stress that most cultured meat companies have already replaced or are looking to replace FBS in their production process.
In conclusion, it would appear that there is some fear and negativity surrounding the area of alternative proteins and new food technology within Europe. This highlights the importance of educating the public and politicians about these products and processes and reassuring them about the safety.
Alternative proteins, specifically insects and cultivated meat are being presented by MEPs for discission at the European Parliament.
Many of the questions are posed in a negative or inflammatory way.
The EU is undertaking a comprehensive protein policy review, which it plans to deliver during the first quarter 2024.
There is no plan to amend current labelling legislation for insect products.
Under HORIZON the EU are funding more research in to the safety of alternative proteins including insects and cultivated meat.
The Giant Leaps project is studying the nutritional, safety, allergenicity and environmental impact of alternative sources of food proteins.
Table 1. List of questions summarised in this article