It’s hard to ignore insects’ status as a highly nutritious and healthy food source, given their high fat, protein, vitamin, fiber and mineral content—not to mention their potential to help address global food insecurity.
But whatever the benefits of entomophagy, incorporation of insects into mass food production—particularly in the United States—is still considered niche, with a few players, among them a cricket protein bar maker. This has to do in part with our culture’s historical frame of reference with insects as an indicator of unsanitary conditions, rather than something edible. Put bluntly, the ick factor.
“When you talk about eating an insect or other arthropod in a recognizable form, our culture has historically been engaged in this battle to keep those types of things out of our food supply—that’s been our lens on it,” said Ricardo Carvajal, FTC and FDA regulatory counsel at Hyman, Phelps & McNamara in Washington, DC.
“If you can figure out a way to essentially de-identify it, then you’re talking about something else. We need to turn that perspective around and start saying ok, we are not talking about something that is an indicator of sanitary conditions, but rather the thing itself. If you can make that mental flip, now can start thinking about the cricket or worm, or whatever it is, as food.”
What's the regulatory status of insects in food?
In a recent entry on the FDA Law Blog, Carvajal called attention to the fact that in the United States, the FDA’s Food Defect Action Levels list allowable percentages of insect fragments in food, yet insects as food do not appear to fall into any category. As such, standards and regulations acknowledging the use of insects as ingredients for food and feed are hard to come by.
“We think the observation that insects don’t fall into any category in the U.S. misses the mark,” Carvajal wrote.
“To the extent that insects are used for food, they are food, and thereby subject to the applicable adulteration and misbranding provisions of the Federal Food, Drug, and Cosmetic Act.”
I’m excited at the prospect of a path forward for establishing market demand for insect-derived food
In other words, reframing the conversation about insects and insect-derived products as food will pave the way for establishing a market, he told FNU.
“Once you start talking about what this thing is nutritionally—which we are really good at in this country—as in, how much fat, protein, what kinds of fat, minerals, vitamins, and all the other things we think of as food constituents, then I’m excited at the prospect of a path forward for establishing market demand for insect-derived food products that do more with our existing technology.”
Once that happens, insects will be subject to the same trials as any other food ingredient, including various methods for achieving Generally Recognized as Safe (GRAS) status, or seeking entry into the market as a food additive. From there, they will have to be produced using good manufacturing practices and meet all the production requirements that apply to any other food.
So in the case of the US, the biggest barrier that remains is still getting past the ick factor.
“Unlike other food ingredients in the US, here we have the added twist—which everybody recognizes—of trying to generate demand for something that historically there has not been a lot of demand for", said Carvajal.
"It seems to me that insects offer a whole lot of nutritional benefits. And in terms of production, they seem to be pretty efficient. So we’re going to have to figure out how to get past the ick factor.”