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The National (Scotland)
The National (Scotland)
National
Ross Hunter

The Brexit-era bureaucracy frustrating Scotland's edible insect industry

OVER the past few years insects have been much touted as a protein rich food source largely unburdened by many of the climate-related problems afflicting other areas of animal agriculture.

Yet, there remains a grand total of zero commercial insect farms in Scotland.

This is not due to a lack of enthusiasm or support from the agricultural sector.

It’s not even to do with the repulsion some may feel towards incorporating creepy crawlies into their diet.

It is, as is often the case with burgeoning industries in the UK, a mixture of Brexit, bureaucracy and plain bad luck that has so far prevented the much-promised boom of edible insects.

What are the benefits?

Eating insects is not a new practice.

Humans have eaten insects for thousands of years and people in around 80% of the world’s countries continue to do so.

It is really only in the West where it considered more of a bushtucker trial rather than a normal element of a diet.

But as the we seek to find more sustainable ways of feeding people, insects have once again found their way onto our plates – albeit in a limited way so far.

“They’re farmed indoors,” said Dr William Clark, a circular bioeconomy expert. “So, we don’t have to worry so much about temperatures changing the farming practices too much.

“The amount of land they use in order to produce a similar amount of protein to other animals shrinks by a factor of hundreds.

“Plus, they have the potential to solve other issues we have within our food system. Globally, we waste around one-third of the food we produce.

“But there are particular types of food waste – vegetable material or bread, for example – that can be fed to insects.

“It gives us a way to avoid all food that breaking down and producing methane in landfill”.

So, what’s the problem?

In 2015, the European Union decided to classify edible insects as a “novel food”.

This designation is for food products that have not been consumed to a “significant degree by humans” prior to the introduction of the EU’s first novel food regulation in 1997.

A transition period for edible insect products was introduced to allow businesses to continue trading while they waited for official EU approval as a novel food.

However, the UK Government decided that while edible insects would be treated as a novel food post-Brexit, there would be transposing of the EU’s transition measures.

As such, selling insects for human consumption in the UK effectively became illegal at the end of the Brexit transition period in December 2020 (although some businesses already in operation continued to trade despite the uncertainty).

It wasn’t until October 2022 that the Food Standards Agency introduced transitional measures allowing businesses to continue trading while they applied for a novel food authorisation.

They now have until December 2023 to apply.

But, as Tiziana Di Constanzo, co-founder of Horizon Edible Insects in London, told The National, the entire industry has been set back.

“It took the UK Government two years to correct the mistake of not introducing transitional measures after Brexit,” she said.

“They could have taken Brexit as an opportunity to disentangle the UK from the novel foods regulations of the EU, which are nonsense and favour large corporations.

“For example, in Australia, New Zealand, Canada, Uganda and many other countries insects are regulated under general food law. They don’t have this overkill of a time-consuming, costly novel foods process which favours large corporations.

“Instead, they basically didn’t look into it at all.”

A novel foods application in both the UK and EU must be sought for each individual insect species, with the applicant required to provide a significant amount of complex scientific information that costs a great deal of money acquire.

Di Constanzo estimates that a single application can cost up to £100,000 – a process which effectively prices out smaller producers.

“We know of ten companies that got together and paid around £10,000 each to apply for a novel foods licence for crickets about three years ago, “ she said.

“They were notified last week that it was only in the initial validation phase.

“It just means that by the deadline of December 2023 we might legally be allowed to sell crickets in the UK but every other insect will have to wait.”

When will we see an insect farm in Scotland?

Insects for human consumption evidently represent an opportunity.

However, it is their potential for use in fish and animal feed that could really prove the business case – once the UK eventually regulates their use.

“You’re now allowed to feed processed animal protein from insects to pigs and poultry in the EU,” said Clark.

“But because we didn’t carry over that transitional legislation you can’t do that in the UK.

“Interestingly, though, we can import pigs and poultry fed on insects in the EU into the UK”.

Clark added that uncertainty of the regulatory environment make it difficult for businesses to secure loans or attract investors – meaning that development of insect products isn’t progressing at the same pace as it is in some European countries like The Netherlands.

However, he stressed that there is still a very active community of farmers, chefs, academics and scientists all looking to make the industry work in Scotland.

“Scotland is an incredible place to farm insects,” he said. “We’ve got the aquaculture, we’ve got the animals, we’ve got the interest, we’ve got the academic community.

“But there’s a lot of factors in play and the cost-of-living crisis definitely set things back a bit.

“But we’re getting there. It’s just going to take time for things to reach a critical mass and for everyone to realise how beneficial this industry could be.”

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