EU regulation jungle: Guide for producers of novel foods presented
Supported by the Adalbert Raps Foundation, researchers at the University of Bayreuth have developed a guide for innovative food producers. Under the leadership of Prof. Dr. Kai Purnhagen, the EU regulatory environment for products derived from mushrooms and mushroom mycelium was scrutinized. The team of the Food Law research group at the Faculty of Life Sciences: Food, Nutrition & Health, together with the Centre for German & European Food Law at the University of Bayreuth, also identified gaps in EU law as part of this project.
The production of animal proteins is one of the most environmentally impacting industries. Heavy investments are made into the development of plant-based and cell-cultured meat and dairy. Mushrooms provide a source of protein that can substitute proteins originated from animals. Moreover, mushroom-derived products are or will soon be commonly used as food ingredients or additives (e.g. dyes, fermenting agents, bitter blockers, etc.).. Of great importance in this context are food products from fungi and mycelium. Mycelium is their fine, thread-like, mostly invisible cell network in the soil or, in the case of tree fungi, in the wood (mushroom and mycelium products or „MMPs“). The lack of legal certainty in this particular field poses a major problem for food companies wishing to enter the market and engage in this sector. „Innovative food must be safe and sustainable! At the same time, it is important that innovations are not slowed down by a too restrictive food law framework. Especially for start-ups, legal certainty regarding their products is a fundamental prerequisite,“ says Frank Kühne, Chairman of the Board of the Adalbert Raps Foundation, explaining the reason for supporting the research project at the University of Bayreuth.
„The EU legal framework for MMP has never been the subject of a comprehensive study or review so far, which is why we have dedicated ourselves to the topic,“ explains Prof. Dr. Kai Purnhagen, Chair of Food Law in Kulmbach. Among other things, he and his team have worked on the following questions:
– Classification of MMPs as food, medicinal products or agricultural products.
– Novel Food Regulation, as applicable to MMPs.
– Requirements for obtaining authorisation for novel foods
– Use of agricultural by-products as substrates for MMP
– Use of food additives in MMP and use of MMP for the production of food additives
– Labelling of MMPs: mandatory and voluntary information (e.g. correct designation of MMPs; use of nutrition and health claims)
This is the first time that start-ups in the food industry that wish to launch MMPs on the market have been given a guide to navigate the regulatory jungle. Frank Kühne emphasises: „With this study, the Adalbert Raps Foundation has funded an initial research project at the Kulmbach Campus, which has been successfully completed. Not least the fact that the results have met with great interest from the start-ups involved strengthens our desire to continue to work closely with the Kulmbach Campus and the Food Law research group into the future.“
The team in Kulmbach has also uncovered further need for regulation. So far, the regulatory specifics of MMPs as novel foods have only been recognised in relation to their use for food enzymes. „However, there are still uncertainties regarding the appropriate toxicological and allergenic strategies for risk assessment of MMPs. This further complicates experimentation with substrates derived from agricultural by-products,“ reports Prof. Dr. Kai Purnhagen. „The labelling of MMPs in the EU is still fraught with great legal uncertainty.“ The use of food additives in MMP as well as the use of MMP for the production of food additives face comparable regulatory challenges to other food additives. If alternatives to animal proteins, i.e. to mass meat production, are to be brought to market efficiently, the EU regulations must be improved.
The study will be presented and discussed online on 3 December 2021 between 3:30 and 5:00 p.m. During a Q&A session, start-ups and other interested parties can ask questions about the study, which will be answered by staff of the Food Law research group – Alessandro Monaco and Alexandra Molitorisóva. Please register via this link: https://innovatefoodlaw.eventbrite.de/.
Prof. Dr. Kai Purnhagen
Chair of Food Law
University of Bayreuth
Phone: +49 (0)921 55-1020