As of 2021, the European Union has allowed the introduction of insects into the list of foods suitable for human consumption. This is an absolute innovation, marking a historic transition. The change was promoted under the banner of ecology, the environment, and sustainability. On the other hand, many critical voices have been raised about this decision, and according to the survey conducted in Italy by Coldiretti, at least 54 percent of consumers would oppose insectivorous dishes.

The addition of the novel foods occurs, at the regulatory level, through the approval of EU regulations that change the list of edibles, adding – from time to time – different species of insects.

With the EU Implementing Regulation no. 2021/882 of June 1, 2021, the European Commission amended EU Implementing Regulation No. 2017/2470, introducing the Tenebrio Molitor larva, or yellow flour grub, as a “whole dried insect, in snack form and as a food ingredient.” The process was initiated, on 2/13/2018, upon the application of SAS EAP Group, which then obtained a permit with exclusive rights for a five-year period.

The first insect allowed for human consumption was followed by the second in the following month of November 2021: the Locusta Migratoria, approved through EU Implementing Regulation No. 2021/1975 of November 12, 2021. In this case, the proceeding was initiated on the application of Fair Insects BV, dated 12/28/18, and, as in the previous case, a five-year exclusivity was granted for the marketing of the insect in “frozen, dried and powdered form in snack form and as a food ingredient.”

The third, and so far last in chronological order, insect introduced into the tables of European citizens was the cricket(Acheta Domesticus), at the instance of 24/7/19 Cricket One Co. Ltd.: by EU Implementing Regulation no. 2023/5, the European Commission approved the sale and consumption of domestic cricket, with related five-year exclusivity in favor of the applicant company. More specifically, the authorized use is in the form of “partially defatted powder obtained from whole Acheta domesticus (domestic cricket) in multigrain breads and rolls, crackers and breadsticks, cereal bars, dry premixes for baked goods, cookies, dry stuffed and unstuffed pasta products, sauces, processed potato products, legume and vegetable dishes, pizza in pasta products, in whey powder, in meat substitute products, in soups and concentrated or powdered soups, in cornmeal snacks, in beer-type drinks, in chocolate products, in nuts and oilseeds, in snacks other than chips, and in meat preparations, intended for the general population“.

In all three cases, respectively in Art. 7 Reg. 2021/882, and 8 of Regs. 2021/1975 and 2023/5, it states that the allergy tests and related experimental data are incomplete and “limited,” so much so that the European Food Safety Authority recommended that further testing be conducted. On the other hand, the EU Commission concluded in all three cases that “in view of the fact that, to date, there is no conclusive evidence directly linking the consumption of Acheta domesticus to cases of primary sensitization and allergies, the Commission is of the opinion that it is not appropriate to include in the Union list of authorized novel foods any specific labeling requirement regarding the possibility of Acheta domesticus causing primary sensitization“. Though the studies are still partial, it has already been possible to ascertain that there is a correlation between insects and crustaceans in allergic reactions, so much so that the Commission has predicted that “The labeling of food products containing partially defatted powder from […] indicates that this ingredient may cause allergic reactions in consumers with known allergies to shellfish and shellfish products, shellfish and shellfish products, and dust mites“.

Ultimately, the shadows around insect consumption seem far more than the lights, and while the very institutions that have approved these new “foods” seem to be groping in the dark, elsewhere, for example in Qatar, we are already learning of refusals to bring insects to the table.
The main concerns arise from both the intrinsic characteristics of the animals and the farming conditions, which are breeding grounds for the spread of Salmonella, E. coli and Campylobacter. If the latter can be partially remedied by cooking, not so, however, the presence of chitin and related issues ranging from mere digestive problems, to outright toxicity, feared by some.

Another controversial aspect sometimes pointed out is that the introduction of the flour grub among edible products could open the door wide to the use of contaminated, stale or mold-containing flours, which, precisely, have been a breeding ground for that insect and which, instead of being disposed of, could thus find their way onto the market.

Lawyer Prisco Carlo
Source: Italian Vegetarian Association

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