• Joseph Ndondo

Post-Brexit: The death of edible insect farming in the UK?



The concept of insect farming has witnessed significant global interest since 2013 when the Food and Agriculture Organisation touted insects as a potentially sustainable solution to challenges in food security amidst a surging global population. The world’s population is estimated to reach about 9 billion people by the year 2050 according to the United Nations (UN). The expectation is that there will be an increase in the demand for meat and protein products, however current conventional agricultural and food production systems will not be able to match this demand, and newer innovative production systems are needed in order to ensure food security and sustainability. Insect farming has been proposed as one of the possible solutions to curb food insecurity. Insects are proven to be more nutritious than most plants such as beans and soybean. In addition, insects are cheaper to produce, require less land and water for their mass production than livestock, and emit fewer greenhouse gases as compared to livestock.


The FAO 2013 report changes the perspective


The publication of a 2013 report titled “Edible Insects: Future Prospects for Food and Feed Security” by the Food and Agriculture Organisation (FAO) culminated in the identification of insects as a viable prospect for food security. The European Union, through its European Food Safety Authority (EFSA), in turn, repealed and amended its prohibitive food regulations in 2017 permitting insect meal in aquaculture. With growing interest in insect farming since 2013, a number of insect farming startups have been established around the world and the global edible insect industry has been forecasted to rapidly grow at a Compound Annual Growth Rate (CAGR) of 28.5% to reach $3.01 billion by the year 2027. This is according to an edible industry forecast report published by Meticulous Research, a leading provider of premium market intelligence. This growth is expected to be driven by factors such as the growing outcry on greenhouse gas emissions, the high nutritional value of insects, the low environmental impact of insects over their entire life cycle, and the low risk of transmitting zoonotic diseases. Insects may also play a big role in waste management and recycling of food waste. By feeding on waste material, insects are able to convert “waste” into useful products such as highly nutritious feed or food, a concept known as upcycling. The feeding activity of insects on waste drastically reduces the amount of waste while producing valuable products and raw materials in the animal feed industry. Waste management using insects will likely benefit low and middle income countries who still struggle with urban solid waste management.


The United Kingdom government is one of a few governments that have committed itself to develop the insect industry sector. In 2020, through its Industrial Strategy Challenge Fund (ISCF), the UK government invested £10 million to help build the country’s first large-scale industrial insect farm. This project was tasked to be spearheaded by Entocycle, an insect farming startup together with other startups such as Better Origin and Beta Bugs. The priority of this large-scale insect farming project in the United Kingdom was in rearing specifically, the Black Soldier Fly insect on a large scale. The UK has a world-renowned reputation in agricultural innovation, which has been based on long-established farming industries. There is increasing interest in using insects in animal feeds especially aquaculture, as well as their use as a source of fuel products such as biodiesel. France and the Netherlands already have established insect farms in the EU and have been market leaders in this sector. France’s Ynest, an insect startup, was one of the highly funded insect startups in the whole world in 2020, as it netted a massive US$372 million from investors. The authorization of insect protein as an ingredient in aquafeed in 2017 by the European Union, stimulated capital investments in the insect sector, with total disclosed investments nearing €1billlion in 2020 as reported by AgFunderNews.


Figure 1: The Exponential Increase in Capital flowing to insect farming companies

Image source: Crunchbase, Dealroom, Rabobank, 2021


The insect market outlook


The edible insects market is divided into five global regions: North America, Europe, Asia-Pacific, Latin America, and the Middle East & Africa. In terms of market value, Europe commands the largest share of the edible insects market as of 2020. This is according to a report by Meticulous Research. According to this report, the EU's substantial market share can be ascribed to it’s well-established edible insect processing capability, insect diversity, abundant availability, optimistic prospects for product approval and commercial launch, and the presence of important market competitors in the region.


The regulatory framework on insect production (UK and EU)


The production and marketing of insects as food in Europe is regulated by the “Novel Foods” legislation: (EU) No 2015/2283. This piece of legislation applies to insects and all categories of foods that were not used for human consumption to a significant degree within the European Union before 15 May 1997. Under this regulation, “Novel Food” describes the various situations of foods originating from plants, animals, microorganisms, cell cultures, minerals, specific categories of foods (insects, vitamins, minerals, food supplements, etc.), foods resulting from production processes and practices, and state of the art technologies such as intentionally modified or new molecular structure, nanomaterials, which were not produced or used before 1997.


The UK’s Food Standards Agency has defined “Novel Foods” as foods that have not been widely consumed by people in the UK or European Union (EU) before May 1997. All foods classified as Novel foods need to be authorised before they can be placed on the market in Great Britain. There are two authorization routes under the retained EU law on novel food:

  • Traditional food notification

  • Full application

The traditional food notification is a simplified route to authorise products that have 25 years of continuous use by a significant number of people in a country outside the UK or EU (Food Standards Agency, 2020). This route has reduced data requirements reflecting their wide use in other parts of the world. There is a four-month period within which the review is conducted. If there are no objections the product is authorised and placed on the authorised list. Applicants seeking authorisation for the full application route need to submit a full set of information that consists of a dossier that will detail information pertaining to the applicant, the product, production process, specifications, and other relevant information. This route applies to all foods classified as novel foods with the exception of those that are classified as traditional foods.


BREXIT, Transitional measures and ‘novel status’ of insects


The regulation of insects in animal feed and in food in the United Kingdom predominantly derives from European Union law. The domestic position of the United Kingdom has historically reflected the European Union’s position and the general expectation was that most laws and regulations would be adopted as domestic law in the United Kingdom, post-Brexit. With regards to edible insects, all edible insect companies in the UK operated under transitional measures set out in the EU’s “novel food” regulation, prior to Brexit. post-Brexit, the UK may take different legal positions from that of the EU, as it is no longer bound by and tied to the EU following Brexit. The UK is now able to promulgate its own amendments to current law, or promulgate new laws, and regulations, at its own discretion. What this means is that any future amendments to EU law on novel foods will not apply to the UK unless the latter chooses to adopt and implement the similar amendments. The implication of this is that this is likely to have a greater impact on the insect farming businesses in the UK, many of whom had been accustomed to EU regulations.


One such impact has already started to be felt in the insect industry. In a guidance document by the UK’s Food Safety Authority (FSA), dated December 2020, producers of edible insects, who had all been legally trading insects up until Brexit, were now asked to resubmit a novel food application supported by a scientific dossier to demonstrate insect food safety. Getting such a legal authorization has been estimated to cost between £70,000 and £85,000, well beyond the financial resources of most British edible insect companies, many of whom are start-ups that are in essence looking for capital investment to boost their infant businesses. These companies have been urging the UK government to recognize insects as “traditional foods”. This would largely presume insects as safe as long as their farming and processing follow appropriate hygiene and safety practices. Insect companies have argued that classifying insects as “novel foods” renders them to undergo costly tests and laboratory analysis to prove their safety.


The future and prospects of the insect industry in the UK strongly depend more on how the legislative and regulatory framework of this sector will be shaped. The UK’s Food Standards Agency will be at the centre of this. The Food Standards Agency has recently released its Strategy for 2022-2027. In this strategy, the agency acknowledged that the climate crisis is driving innovation in food, as more companies are investing in alternative protein sources. In that context, the FSA emphasised that it aspires to make it easier for food businesses to meet their obligations and do the right thing to protect public health. It reaffirmed that science and evidence will inform and guide its work and operations with a commitment towards transparency, proportionality and innovation. It remains to be seen however how the agency will balance both public health needs and food businesses’ concerns.


Reaching that balance will be the holy grail in sustaining the insect industry in the UK and at the same time mitigating risk in public health while safeguarding consumer interest. Public health and food safety concerns are undoubtedly a justified cause in any country, especially as the world has just had a rough experience with COVID-19, however, there is a need for authorities to avoid overregulating the insect industry. This would subsequently suffocate the budding insect industry. There is a need for authorities to strike a balance between ensuring public health and promoting businesses. There is always that need to create an enabling environment that stimulates growth in the insect sector. In its five-year strategy (2022-2027), released on the 18th of March 2022, the Food Standards Agency in the UK, reflected on its greater responsibilities post-Brexit. The agency stated that it took into account the growing public concern about health and climate change. Emily Miles, the Chief Executive of the Food Standards Agency, was reported as saying:


Leaving the EU has changed the FSA’s role. We have taken on new functions, like approving new types of food that come on sale here and setting rules for checks of imported food. Today the FSA, therefore, plays a more critical role than ever in supporting governments in England, Wales and Northern Ireland on matters relating to food. The strategy commits us to put consumer interests at the heart of our work so that food is safe and what it claims to be as well as being healthier and more sustainable.”

It remains to be seen how this new strategy by the UK’s Food Safety Agency will impact the insect industry. The last strategy by this agency was back in 2015 when the UK was still part of the European Union. It will be interesting to see how the UK will transform and shape its food regulatory space and how businesses will respond to these changes. The FSA affirms that it is ready to adapt to any major unforeseeable shocks to the food system that may affect supply chains, staffing, and operating models.


Conclusion


The growing interest in insect farming has been boosted by an endorsement from global organisations such as the Food and Agriculture Organisation of the United Nations and other regional bodies such as the European Union. The growing global population is expected to push up the demand for meat and protein products around the world. This surge in protein demand is unlikely to be met by conventional agricultural systems which have shown signs of susceptibility to climate change, pests, diseases, and natural limitations of water resources and land. Newer innovative production systems are needed in order to ensure food security and sustainability. Insect farming has been proposed as one of the possible solutions to this challenge and the buzz on insect farming has seen insect companies sprouting around the world including in the United Kingdom where the government had initially taken a proactive role in investing in this sector.


With Brexit, the UK will not be expected to align to EU regulations despite having traditionally done so before Brexit. Following Brexit, the UK is now at will to amend current food laws, or promulgate new laws, and regulations, at its own discretion. This will likely impact greatly the insect sector which had until Brexit, been accustomed to European Union regulations, in particular, the “Novel Foods” legislation: (EU) No 2015/2283. How the UK government shapes its domestic laws on novel foods will determine the future of the insect industry. Legislation will likely play a bigger role in either enabling or suffocating this budding industry which has the potential of providing sustainable solutions in the food and feed industry.



Bibliography


AgFunderNews, 2020. AgFunderNews. [Online] Available at: https://agfundernews.com/uk-government-earmarks-10m-for-industrial-insect-farming [Accessed 26 2022 2020].


Ellis, J., 2022. AgFunderNews. [Online] Available at: https://agfundernews.com/innovafeed-adm-enter-insect-protein-partnership [Accessed 22 March 2022].


Food Standards Agency, 2020. Food Standards Agency. [Online] Available at: https://www.food.gov.uk/business-guidance/regulated-products/novel-foods-guidance [Accessed 23 March 2022].


Food Standards Agency, 2022. Food Standards Agency. [Online]