As the UN’s 26th climate conference is about to begin, several British companies innovating the sustainable industry of edible insects can no longer operate due to government bureaucracy. This comes after the UK government has poured millions of pounds of public funds into the industry, invited edible insect producers to provide food at the conference, and government bodies will be discussing it as a solution to climate change at the conference.
The United Nations has predicted that the market for edible insects could be worth $6.3 billion (£4.6 billion) by 2030, and 2 billion people already eat them around the globe as part of their diet.
Edible insects are seen as a potential solution to climate change by the United Nations, who in 2013 released a report stating that eating insects could help boost nutrition and reduce pollution.
On Tuesday at COP26, the UK Research & Innovation, a non-departmental public body of the government, will be hosting a talk on climate change solutions in which they will discuss edible insects and the work UK scientists and innovators are doing in the industry.
But new food laws have left some UK companies facing closure after banning what was previously perfectly legal food production.
Tiziana di Costanzo, who co-founded Horizon Insects in London, was originally asked to supply edible insects to be eaten at COP26 which starts on Sunday. But her company faces closure after the new rules post Brexit have made edible insect production now completely unauthorised in the UK. Her insurers said they could no longer certify her after the British Food Standards Agency (FSA) announced in August that transitional measures which had been upheld in European law had now ended officially.
“The situation at the moment is tragic. You can’t get public liability insurance anymore, not even companies who have been insuring us since 2017,” she says. “We’ve started culling mealworms. We’ve suspended our classes and visits to schools.”
It’s all the more ironic, given that it was only in the last few years that public money was given to Horizon Insects specifically to invest in edible insects. The company got funding from the Greater London Authority’s Better Futures Programme, which supports companies who reduce negative impacts on the environment. Millions of public funds from Innovate UK, part of a non-departmental public body of the Government of the United Kingdom that directs research and innovation funding, were also given to small to medium sized enterprises investing in edible insects.
The legal limbo that edible insect providers are now in is all down to two legislative changes in recent years. In 2017, the EU introduced “novel food” regulation, which required each new insect to pass onerous risk assessments. When Brexit happened, existing EU rules were copied and pasted into British law, but without the transitional measures that were there in the meantime to support businesses through this new legislation.
It meant British companies were suddenly excluded from the progress being made in the EU to authorise edible insects with the European Food Standards Agency, and had to start from scratch with the British Food Standards Agency.
The nightmare of having to go through another round of British bureaucracy so shortly after jumping through the EU’s hoops is making producing edible insect food unaffordable for many companies, and uninsurable for many providers.
“There has been no transparency going forward,” says Tiziana di Costanzo, describing the process now that there are no transitional measures in place. “UK companies now have to re-apply for authorisation of food processes which will take 12-16 months to deliver, and about £80,000 per insect species. Small and medium-sized enterprises (SMEs) will not be able to afford this, and in the UK the industry is 100 percent made of SMEs!”
Dr Nick Rousseau, founder and Managing Director of Woven Network CIC, a network focused on supporting UK entrepreneurs and researchers around insects for food and feed, told VICE World News that he knows of two companies who have fallen through, and four or five start-ups who have failed to lift off due to government uncertainty.
Rousseau points out that the authorities are accommodating CBD products, which find themselves in a similar post-Brexit bureaucratic tangle, but not edible insects.
“The Food Standards Agency (FSA) has been very careful in its choice of words in communication with us that these are unregulated food products classified as novel foods, but we know the same is true of CBD products. And the FSA has granted a transition arrangement for their products pending approval. I don’t know how they’ve decided CBD products are less harmful than ours,” he says.
`Rousseau says that supermarkets are also hesitant to put edible insects on shelves until their legal status is clear. “There were members that were in advanced discussions with major high street chains about creating products for their shelves. They were going to go mainstream. But obviously they aren’t going to put anything on the shelves not fully supported by the government.”
It seems that the government itself is not aware of the crisis facing many of the British companies involved; Innovate UK recently asked di Costanzo if Horizon Insects would be able to provide edible insects at COP26.
She called the scenario “a mess.”
A YouGov poll in 2019 of just over 2,000 UK adults found that nearly two in five thought the consumption of insects would increase in the next ten years, rising to nearly half (48 percent) among the 18-24-year-old age group. But di Constanzo fears that there won’t be a British supply to support this demand for sustainable food like edible insects.
Globally, the most commonly eaten insects are beetles, caterpillars, and bees, wasps and ants, according to a report on edible insects from the United Nations’ Food and Agriculture Organization.
Mealworms, which were farmed by Horizon Insects, are described as having a similar composition of unsaturated omega-3 and six fatty acids to that in fish, higher than that in cattle and pigs. The report adds that insect production emits considerably fewer greenhouse gases and ammonia emissions than most livestock, does not require land-clearing to expand productions, and needs 12 times less feed than cattle.
Di Costanzo also said that the novel food regulation the UK is pursuing post-Brexit contrasts sharply with that of other countries like Australia and New Zealand, which use regular food law to define the processes for the rearing of insects.
“The craziness of the novel food route is not just the quantity, it’s the process. Everything results in different sets of scientific data to provide. If I make a cookie and use freeze dried crickets, and you use oven dried crickets, we’d need different sets of toxicology, excretion, genotoxicity etc. which is really an absolutely overkill. If I put 10gms and you put 50gms, different authorisation is required.”
The confusion has left other producers of edible insect foods doubting their future, as well as the government’s commitment to sustainable food production–but have been told by their local authorities to move forward with “business as usual” in the meantime.
Tim Boote, director of Protein Rebel, who make a plant and cricket protein powder, are also eager for clarity from the Food Standards Agency (FSA). “It is still not clear with the Environmental Health Officials saying they are happy for us to trade.”
“In these times of climate crisis and COP26 imminent, it would be detrimental to our goal of net zero to ignore this low environmental impact superfood.”
Crunchy Critters managing director Nick Cooper would also like a model more like that of Australia and New Zealand. He says that at the end of 2018 they had sold insects and arachnids all over the world; as the EU novel food legislation came in, overnight they lost 75 percent of their product range.
They made every effort to stay compliant and did a complete rebrand. “Then the pandemic came. And Brexit. It’s worrying,” he says. They have not been told anything by their local authority’s Environmental Health Officer that may change their business, but experiences like Horizon Insects have not reassured Cooper.
“We want to keep doing what we’re doing, we’ve got great feedback, great customers. I’ve got customers up and down the country.”
Cooper says it was also suggested to him that Crunchy Critters could supply food at COP26 “but then the budget disappeared. Make of that what you will.”
He references I’m A Celebrity, Get Me Out of Here, a British TV gameshow in which celebrities live in a jungle and often eat insects in challenges.
“What’s going to happen when that comes back on? It’s staggering we’re even talking about this, to be honest with you.”
Dr Tilly Collins, senior fellow at the Centre for Environmental Policy at Imperial College London, told VICE World News: “A range of small to medium sized enterprises producing insect-based foods is vital to understand which products the public will most enjoy, which marketing will produce a thriving and diverse industry. Many of the existing UK companies which were established with government support are now threatened by a barrage of regulation and cost that can only serve to reduce the business-ecological diversity of this growing industry.”
In response to the concerns raised by these businesses, Paul Tossell, who leads the Radiological, GM and Novel Foods Team for the Food Standards Agency, told VICE World News that they continue to support the industry through the process of achieving authorisation to sell edible insects in the UK.
“Businesses which applied to the EU before January 2020 for permission to sell insects for human consumption were allowed to continue, as they awaited a decision on authorisation, as part of transitional measures provided under EU Regulation 2285/2015.”
“However, due to the EU not authorising these applications before January 2021, submissions need redirecting to the UK’s own regulated products process for them to become authorised. The FSA is conducting its own review into whether interim measures can be introduced until authorisation decisions are made.”
They added: “There is no fee for the authorisation application. Costs may be incurred from toxicological studies, etc that are needed for the risk assessment element of the process.”
For di Costanzo, a final decision on measures from the FSA may come too late. “Three years ago I put my career on hold because I wanted to do something for the environment and planet, so I launched myself into edible insect farming which hasn’t been extremely profitable.”
“So basically now my husband as well we’ve been looking to go to our old careers.”
If edible insects do appear at COP26, it is likely that they may be imported in from abroad – adding a carbon footprint to an otherwise sustainable industry.