Is it legal to use Indonesian Cricket Powder in the EU?
We have to differentiate European Union entry regulations and European Union food consumption and production regulations.
(Imports need separation under the legislation and regulations for Novel Food.)
European Union entry regulations
According to the Regulation (EU), 2019/626 (source) and its appendixes REGULATION (EU) 2020/1572 (source) and (EU) 2019/1981 (source) there are only 4 countries (Canada, South Korea, Switzerland, and Thailand) that have permission for insects products entry into the Union.
On the other hand, Regulation (EU) 2019/1981(source) in regard to all the other laws (please find the full list below) describes other official importing procedures for insect products and novel food from developing countries.
In summary: We have import legislation that describes different import procedures, and it is our right to choose which one to use. Successful customs clearance in Germany this autumn after the Regulation (EU) 2019/626 came into force proves this statement.
European Union food consumption and production regulations. Novel food
Part 1. Our production Standards
Regulation (EU) 2015/2283 (source) informs us the following: «Union legislation applicable to food is also applicable to novel foods placed on the market within the Union, including novel foods imported from developing countries.» The origin is not important. What matters is following all the EU production standards or equal.»
Product, farming, and production quality are our strong points, and they provide us with a competitive advantage. We confirm this statement with our certificates: GMP, GAP, and SICI. We have Premium Cricket Powder, and it’s better than most products from European farms.
There is no prohibitive legislation based on the product origin.
In summary: It is legal to use our Indonesian Cricket Powder in the EU.
Part 2. Product origin
he Novel Food Regulation and Regulation (EU) 2015/2283 obliges with product verification, and only then it can be placed on the market. Here is the full list of the submitted applications (source) and you can find an Acheta Domesticus (Cricket) too.
The most obvious conclusion is that nobody can use Cricket products right now. But there are a lot of companies that already work with novel food and cricket powder.
The main question is: how is it possible?
We made a request directly to the European Commission (https://ec.europa.eu/info/index_en) to overcome our doubts.
Here is the answer they gave us: “you have to follow the EU Novel Food Regulation and also you shall consult the Member State where we first intend to place the novel food.” So we have to follow the EU Legislation or Member State Legislation.
You are already using Cricket Powder, so according to your member state legislation, it is allowed to use cricket products despite the EU Novel Food Regulation.
For example, we have SENS Foods based in the Czech Republic and their supplier Cricket Lab based in Thailand. Despite all the Novel Food Regulation, their position is: “There is still a transitional measures period, which is in place now, and these transitional measures are fully accepted for our market operations in Germany and the Czech Republic.” (source)
In summary: It is not illegal to use our product based on origin.
Part 3. Thailand is on the permitted list
The European Parliament and the Council of the European Union implemented Regulation (EU) 2020/1572 of 28 October 2020 (source).
New Regulation defines that we can import insect products for human consumption if such foods have originated in and consigned from Thailand.
We have farms in Indonesia and Thailand. We are flexible to provide you with the product originated in whether Thailand or Indonesia. We are open to provide you with any requested certificates, laboratory reports, and documents.
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