Let’s face it. Most people aren’t that interested in eating insects. If I extrapolate, most contract manufacturers (co-packers) won’t be that interested in making insect products like cricket bars or cricket soups.
Part of the reason is that they just won’t have the same passion for entomophagy. Entomophagy is considered innovative in western cultures and some people just don’t see the value in it. Secondly, and probably a bigger factor, is that adding a new type of food ingredient in a food facility is a business risk. People connect insects with filth and uncleanliness so their other co-packing customers might balk at the idea of sharing production equipment with crickets or meal worms. Insects are considered allergenic. So would other products sharing production equipment need an allergen warning such as “made in a facility that also process insects”? Another issue is that the regulatory framework is unclear. Insects as food is not specifically mention anywhere in anywhere in US regulations besides the part on action defect levels. A contract manufacture that you find suitable to work with probably has a successful business. Why would they want to do anything to jeopardize business model?
The first step when talking to a contract manufacturer is to explain the benefits of insects as food.There are a lot of great reasons to get into the entomophagy business. This is a home run.
Secondly, be prepared with counter points in case your co-packer has objections. Below are some talking points to appease potential co-packers (Mostly applicable to the US but can be transferable for other regions).
- Insects are already in products. Ingredients like dates, peanut butter, chocolate and cinnamon have insect parts in them. Insects are an unavoidable and inherent in some ingredients.
- Insect cross contamination poses no inherent health risk. The amount from cross contamination would be less that the levels listed in the Defect Levels Handbook. Good manufacturing essentially eliminates cross contamination.
- Disclosure to other co-packer customers is not necessary as it does not affect their product. (Given that the facility/equipment is well maintained).
- A manufacturing warning is not needed. This is based on the assessment that the amount of insects from cross contamination would be negligible compared the action defect level.
- The likelihood of the product being recalled is very low. I wrote a blog post about this Read it here.
- State that the insects being used are food grade. Have documents available indicating that they have been farmed in compliance with FD&C Act Chapter IV: Food and processed in compliance with CFR Title 21 Food
- Minimally process insects can be considered a ‘raw agricultural product’ and there for do not need a GRAS determination. There is a grey area consisting of whole foods that does not get the same scrutiny that additives do.
- As back up, also have information specifically related to making a GRAS determination. Don’t forget, GRAS substances do not require pre-market approval.
- Also mention that regulatory agencies do not consider edible insects a priority. They have much more pressing concerns. Most likely, edible insect businesses will fly under the radar for a while.
I hope this helps.
Please reach out to me if you have any questions. I would love to help.