We will post more information on each dish and the research behind them in the new year.
After this fateful Sunday, we felt the need to dig deeper into the EU Novel Foods Legislation to understand a bit more how it had led to this unfortunate series of events, and what all of us who are working ‘on the frontier’ of what is considered legal are dealing with.
The grounds upon which the workshop was shut down seem to revolve around the European Commission law EC 258/97 on Novel Foods. The Commission signed the law into effect in 1997, stating that “foods and food ingredients that have not been used to a significant degree in the EU before 15 May 1997 [are] novel foods and novel food ingredients” and that “they must be safe for consumers [and] properly labelled to not mislead consumers.”[EC 258/97]
The impulse behind the legislation seems noble enough – probably a desire to protect EU lands from an onslaught of untested, potentially harmful new food additives. Yet going a little deeper into the legislation reveals a more complex situation. The Review of Regulation (EC) 258/97 describes itself as related “in particular to food produced using new techniques and technologies, such as nanomaterials.” [EC 258/97 Review] Furthermore, there are relevant areas which the Novel Food Regulation nonetheless explicitly does not cover – “food and ingredients for which an approval exists, [namely:]
§ Food additives within Regulation EC 1333/2008;
§ Flavourings for use in foods within Regulation EC 1334/2004;
§ Extraction solvents used in the production of foods within Directive 2009/32/EC - approximating EU countries' laws;
§ GMOs for food and feed - Regulation EC 1829/2003;
§ If foods and/or food ingredients were used exclusively in food supplements, new uses in other foods require authorisation under the Novel Food Regulation e.g. food fortification require authorisation.”
Morever, particulary since 2009, the Novel Food Regulation seems to concern itself strongly with cloning and food from cloned organisms (ibid.).
All this had us wondering: shouldn’t a class of foods as diverse, as widespread, as traditional and as celebrated as insects be treated under slightly different legislation than that which concerns itself primarily with food additivies, artificial flavourings, extraction solvents, clones, and GMOs?
One year ago, in December 2013, the Commission adopted new proposals to the legislation, among which were “special provisions… made for food which has not been marketed in the EU but which has a history of safe use in non-EU countries. This creates a more balanced system and a positive environment for trade.” One would expect certain insect species to be included in these provisions – but perhaps only in the event one submits an application for authorisation.
This authorisation is given by individual EU member states. Our situation occurred in the grey area when member states have different standards for authorisation – and different attitudes towards the same ‘novel’ food product. These different standards are further complicated by the large cultural variation in the legislative criteria for establishing “a history of human consumption to a significant degree,” such as valid types of documentation, geographical scale of consumption, ‘appropriate’ quantity of use, intended purpose (eg. crossover with medicinal and cosmetic functions), methods of processing, different properties among parts of the same organism, prevalence in private vs. public domains, and commerical value, among others.
All of this variation in criteria standards means that despite the goals of the legislation to provide safe foodstuffs and transparent information to consumers and businesses, there is still a lot of room for misinformation and unfounded cultural biases to generate fear of ‘novelty’ where there is no need for it.
There does exist a centralised “Novel Food Catalogue”, which “lists products of plant and animal origin and other substances subject to the Novel Food Regulation, after EU countries and the Commission agree in the Novel Food Working Group.” However, “it is non-exhaustive, and serves as orientation on whether a product will need authorisation under the Novel Food Regulation. EU countries may restrict the marketing of a product through specific legislation. For information, businesses should address their national authorities.”
The salient point in Torino was the different ways that different member states respond to foods that are not explicitly authorised by the Novel Foods Regulation, but that have compelling evidence for their consideration – such as widespread, culturally and ecologically contextual, and safe use for centuries in other places in the world. In Denmark, for example, no insect species are officially authorised but we have never encountered such pushback. Nor have we in the Netherlands, Sweden, Norway, Germany, or the UK, where we have also shared some of our work.
It was of course a disappointment to be shut down – but it was also fruitful, opening our eyes again to the challenges of this work and bringing us to commit ourselves again to the battle of diversifying food systems through taste. We saw the depth of the psychological barriers to such unknown foods in action, and experienced firsthand the necessity for better, more informed legislation and its execution. We need to give this support not just to insects but to all sorts of traditional, wholesome foods with the potential to diversify our taste and our food systems, which are prevented from doing so in part due to unclear legislation and its misapplication.
But we didn’t let the day get us completely down. We still had almost all of our mise en place (we had managed to salvage and stash most of it from those who would have thrown it away) and ended up arranging an impromptu dinner party tasting for about fifteen of our friends. Gold stars for the evening go to our newfound Salone friend Steven Satterfield, chef of Miller Union in Atlanta, Georgia, who let us use his rented apartment in Torino and cooked with us, and Enrico Cirilli, Roberto’s good friend from Sardegna and our unfailing sous-chef for the whole weekend. We couldn’t have made it happen without them.
The menu from the evening ended up looking something like this.
Grapes, ants, anty gin
Cured tuna heart, olive oil, grasshopper garum
Culurgiones (Sardinian ravioli with pecorino, potato and mint), broth of house crickets and termite mound mushroom
Chestnut soup, bee larvae, fermented pollen
Poached egg and grits, country ham and redeye gravy
Radicchio, Kale, Savoy cabbage with orange and grana padano
(the Southern flair from Steven)
Here are some photos: