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Review of U.S. State-Level Entomophagy Regulation 2015

From the International Food Protection Training Institute (Link)

PDF of Review

Review of U.S. State-Level Entomophagy Regulation 2015

Adam Lewis
Agricultural Consultant
Minnesota Department of Agriculture
International Food Protection Training Institute (IFPTI)
2015 Fellow in Applied Science, Law, and Policy: Fellowship in Food Protection

Abstract

This study examined state-level food safety regulatory response to the use of insects for human consumption, or “entomophagy.” Interviews were conducted with state regulatory officials from the 50 states; multiple interviews were conducted in states where regulation of retail and manufacturing of food are carried out by different agencies or delegated to a local agency. The study identified states where insects are sold at retail and the number of insect manufacturers; current regulations; types of insect food products; regulatory challenges regarding manufacturing facilities; and perceived food safety risks. Twenty states either reported receiving inquiries related to beginning an entomophagy-based business within their state; had previously regulated entomophagy facilities; or currently regulate entomophagy at the manufacturing or retail level. However, while the Food and Drug Administration (FDA) has jurisdiction over food being made using insects that is wholesaled and crosses state lines, there is no clearly-defined guidance at present for state regulators from the FDA. The study concludes that present state-level food safety regulation is fragmented, inconsistent, and does not address the current widespread use of insects as food. Recommendations include increased FDA-industry collaboration in order to create an entomophagy guidance document for the successful implementation of a preventive control system in order to provide consistent regulation of entomophagy processing and manufacturing facilities.

Keywords: 50 states, approved source, crickets, food safety, Food Safety Modernization Act (FSMA), guidance document, hazards, insects as food, insects for human consumption, Preventive Controls for Human Food (PCHF)

Background

People throughout the world have been eating insects as a regular part of their diets for millennia (van Huis et al., 2013, p.1). More than 1900 species are regarded as edible, including beetles, caterpillars, bees, wasps, ants, grasshoppers, locusts, crickets, cicadas, leaf- and planthoppers, scale insects, termites, dragonflies, and flies (van Huis et al., 2013, p.1). The benefits of entomophagy include utilizing a nutrition source that is high in calcium, zinc, and iron; environmental friendliness (e.g., requiring 12 times less feed than cattle to convert feed into the same amount of protein); and economic benefit, as the cost of start-up is significantly less than traditional farm-raised animals (van Huis et al., 2013, p.2).

Insect food producers are currently regulated by the FDA using Good Manufacturing Practices (GMPs) (Halloran & Munke, 2014); however, these GMPs are subject to a variety of interpretations. The FDA has published guidance documents and provided regulations for seafood and juice processors incorporating hazard analysis and critical control point (HACCP) principles which provide industry and regulators with consistent, sound scientific evidence to ensure the product and process is safe. However, the FDA has not provided guidance for insect food processors.

The Food Safety Modernization Act (FSMA) Preventive Controls for Human Food (PCHF) rule is now final (U. S. Food and Drug Administration [FDA], 2016) and uses HACCP-based principles that food facilities must follow unless the facilities are covered by an exemption. If not, the firm has the responsibility for: conducting a hazard analysis, preventive controls, monitoring, verification, corrective actions, and making corrections. Farms are exempt from the preventive controls rule unless raw agricultural commodities (RACs) are changed into a processed food. The FDA identifies multiple activities that change an RAC to a processed food, including slaughtering of animals and freezing. Insect farms would be exempt from the new FSMA PCHF rule unless facilities are slaughtering insects, freezing them, or conducting activities that would change the product into a processed food. FDA is developing guidance documents addressing the following: hazard analysis and preventive controls, environmental monitoring, food allergen controls, and validation of process controls. However, no guidance document currently exists for insect processors despite the fact that insects are rich in nutrients and moisture, and provide a favorable environment for microbial survival and growth (van Huis et al., 2013, p.117).

Problem Statement

At present, there is no comprehensive description of the state regulation of the processing and sale of insects for human consumption.

Research Questions

  1. What types of insects are most commonly being processed and consumed for human consumption?
  2. What types of foods are produced using insects?
  3. What are the challenges associated with the regulation of insect-processing facilities?
  4. What are the food safety risks related to insect processing and consumption based on the current understanding of state food safety regulators?

Methodology

A telephone survey of state agriculture and local health officials was carried out using the Directory of State and Local Officials (Association of Food and Drug Officials [AFDO], 2015). An introductory e-mail provided the subjects with thirteen questions to be asked in the telephone survey. Eight questions focused on the subject’s regulatory framework and five questions related to the regulatory process. Responses to the survey questions were analyzed to address the four research questions above.

Results

All 50 states responded to the survey. Twenty states indicated that they had either received inquiries related to beginning an entomophagy-based business within their state; had previously regulated entomophagy facilities; or currently regulate entomophagy at the manufacturing or retail level. Six of the 20 states were currently regulating crickets or cricket products using Good Manufacturing Practices (GMPs) (see Table 1). Two of the 20 states had previously regulated cricket entomophagy products using the GMPs (Louisiana and Utah); nine of the 20 states had received inquiries related to cricket entomophagy (Alaska, Idaho, Maine, Michigan, Minnesota, South Carolina, Texas, Vermont, and Washington); and two states (Arizona and New York) reported currently regulating entomophagy at the retail level.

Several responses to the survey questions illustrate the diversity of regulatory experiences related to entomophagy. A Montana regulatory official stated, “There has been talk and phone calls about insects for human food, and we have seen insects used for human food that fall under our temporary food exemption.” An Arizona regulatory official said, “The State Fair is primarily where insects for human consumption are offered for sale, and the insects used at the State Fair are primarily from California. There are also numerous retail stores selling packaged entomophagy products including novelty items such as lollipops with an edible insect such as scorpions inside of the lollipop.” From Kansas, a regulatory official commented that “There was a startup for mealworm flour, and at this point the start-up operation falls under the cottage food retail exemption.”

The widespread nature of entomophagy is illustrated by two manufacturers: Chapul and Exo. Chapul produces cricket bars using cricket protein powder that is dairy- and soy-free. Exo produces protein bars using cricket flour and claims that the bars are all natural, dairy-free, gluten-free, paleo-friendly, soy-free, and contain 10g of protein. These two companies distribute products to 42 of the 50 states, primarily to retail establishments (Exo, n.d.; Chapul Bars, n.d.).

All of the states using the GMPs (or a modified form of the GMPs) to regulate entomophagy facilities identified crickets as an ingredient, or sold as a whole insect as shown in Table 1.

alewis-figure-1The potential size and evolution of large producers is illustrated by two other manufacturers: Big Cricket Farms in Ohio and Aspire, located in Texas. According to its website, Aspire has the capacity to process up to 7 million crickets on a weekly basis (Aspire Food Group, 2016). Big Cricket Farms, whose mission statement starts with “To drive the edible insect industry forward” also raises crickets specifically for human consumption; the company bills itself on its website as “the first American insect farm to obtain food-grade certification from their state Department of Agriculture and the FDA.” The firm raises Gryllodes sigillatus, a.k.a. the Tropical Banded Cricket (Big Cricket Farms, 2014). An Ohio regulatory official who has been to the facility identified jurisdiction as one of the biggest challenges in regulating insect facilities, as the Ohio Department of Agriculture does not have jurisdiction until the crickets are dead—in effect, after an important part of the manufacturing process has already taken place.

California was the lone state in the survey to regulate products other than crickets or cricket products using the GMPs. A California regulatory official identified insects in hard candies such as ants and scorpions (which are regulated under the GMPs) and chocolate-covered grasshoppers during the interview. Products found on the website of California’s Hotlix Candy Store include ant wafers and whole crickets flavored with bacon and cheddar, sour cream and onion, and salt and vinegar. Worm snacks were also offered in BBQ, Mexican spice, and cheddar cheese flavors (Hotlix Candy Store, 2015).

During each interview, state representatives were asked to identify challenges related to regulating entomophagy facilities. Table 2 shows what challenges were identified for all states participating in the survey. Approved source, understanding the process, and understanding the hazards accounted for 66% of challenges identified. Of the six states indicating that entomophagy regulation was occurring and applying the GMPs in Table 1, ten responses to challenges were noted. The challenges identified (from the states listed in Table 1) included understanding the process (40%), determining approved source (20%), understanding the hazards (20%), the unknown (10%), and establishing jurisdiction (10%).

alewis-figure-2Of the eight states that regulated entomophagy firms or had previously regulated entomophagy firms using the GMPs, none indicated that any hazards were identified during inspection work. A New York State regulatory official pointed to a 2001 incident where approximately 15 people became ill following the annual Explorers Club dinner in New York City. The primary symptom was burning mouth/throat due to the mechanical irritation caused by the urticating hairs of tarantula. A food prep review found that some of the tarantulas may not have been adequately singed to remove the hairs. The tarantula example illustrates the hazards within entomophagy which could easily be overlooked without scientific guidance provided to industry and regulators.

A Georgia regulatory official shared information received from the FDA that there is a growing body of scientific literature that people who are allergic to shellfish (shrimp, lobster, etc.) may also be allergic to insects either as food or as adulterants in foods.

The FDA has provided e-mail guidance to a Pennsylvania regulatory official that states there is no specific FDA regulation that either prohibits or condones the use of insects as food. The Food, Drug, and Cosmetic Act requires food products to be “fit for food” (FDA, 1938). In general, “fit for food” means the product is safe and wholesome and does not present a health hazard. Firms, not the FDA, must determine if this is the case and FDA’s role should be to oversee that firms meet this charge.

Conclusions

Entomophagy regulation lacks national standardization and existing regulation is fragmentary and often ad hoc. However, entomophagy is found in most states; nationally, the volume of product is increasing. States are currently regulating entomophagy manufacturers using GMPs, which is not a food process- or product-specific regulation. Insect processors may fall under the Preventive Controls for Human Food (PCHF) rules, in which case regulators would rely on industry to provide information related to hazards in the product and process. The PCHF rules will also require manufacturers to identify hazards in their operation and validate and verify control of these hazards based on scientific data. Additionally, the FDA has not provided guidance to state regulators or to industry regarding hazards, processes, and sources. As a result, there is a current and significant need for increased guidance for consistent entomophagy regulation.

Recommendations

The FDA should work with the manufacturers of entomophagy products to provide a guidance document for entomophagy. The guide would be used as a resource for industry and regulators to provide consistent, sound, scientific evidence ensuring the product and process is safe.

An expanded study should be conducted to identify potential hazards associated with the production of insect-based foods in order to assist in the continued effort to achieve a comprehensive description of the regulation and sale of insects for human consumption.

Acknowledgments

I would like to thank Dr. Benjamin Miller, Division Director; Valerie Gamble, Outreach and Delegation Coordinator/Previous Supervisor, and Lorna Girard, Supervisor for giving me the appropriate time to complete this project and for encouraging me to apply to the program. Thank you to the International Food Protection Training Institute (IFPTI) for giving me the opportunity to complete the Fellowship Program and be a part of Cohort V. More specifically, I want to thank the following individuals from IFPTI: Dr. Craig Kaml, Senior Vice President, and Gerald Wojtala, Executive Director, for providing valuable feedback during our presentations and on my journal article and expressing his ideas and suggestions to make our projects successful; Dr. Paul Dezendorf, IFPTI Research Subject Matter Expert, for all of the guidance provided throughout the process and taking time out of his busy schedule to help assist me in the development of my project; Mr. Cameron Smoak, Mentor, for his professional guidance throughout the program; Ms. Suzanne Kidder, Curriculum Delivery Coordinator, for all of the work she has done in providing and setting up the food and lodging accommodations and working with me during the application process; and Ms. Denise Miller, Staff Writer, for making a batch of cricket flour cookies for the Fellows to sample. I would also like to thank all of the state and local officials who participated in the survey. Lastly, I would like to thank my family for all of their support during this process, including my wife Becky, my mother Suzanne, my father Darold, and my sister Gina.

References

Aspire Food Group. (2016). Frequently asked questions about cricket nutrition and farming. Retrieved from Aketta.com Website: http://www.aketta.com/aketta-crickets/faq.aspx

Association of Food and Drug Officials. (2015). Directory of State and Local Officials. Retrieved from http://dslo.afdo.org/

Big Cricket Farms. (2014). F.A.Q.: Frequently asked questions. Retrieved from http://bigcricketfarms.com/faq.html

Chapul Bars. (n.d.). Find a Store. Retrieved from http://www.chapul.com/find-a-store

Exo. (n.d.). Find a Store. Retrieved from https://www.exoprotein.com/pages/store-locator

Halloran, A. & Munke, C. (2014). Discussion paper: Regulatory frameworks influencing insects as food and feed. Retrieved from http://www.fao.org/forestry/39620-04ee142dbb758d9a521c619f31e28b004.pdf

Hotlix Candy Store. (2015). Hotlix candy. Retrieved from http://www.hotlix.com/candy/ http://www.fao.org/docrep/018/i3253e/i3253e00.htm

U. S. Food and Drug Administration. (1938). Federal Food, Drug, and Cosmetic Act FD&C Act: 21 U.S.C. 342 – adulterated food. Retrieved from https://www.gpo.gov/fdsys/granule/USCODE-2011-title21/USCODE-2011-title21-chap9-subchapIV-sec342/content-detail.html

U. S. Food and Drug Administration. (2016). FSMA final rule for preventive controls for human food. Retrieved from http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm334115.htm

van Huis, A., Van Itterbeeck, J., Klunder, H., Mertens, E., Halloran, A., Muir, G., & Vantomme, P. (2013). Edible insects: Future prospects for food and feed security. (FAO Forestry Paper 171). Retrieved from Food and Agriculture Organization of the United Nations website:

What I learned from the Eat Insects Detroit conference

Eat Insects Detroit was the first conference in North America solely dedicated to edible insects. It was held at Wayne State University from May 20-28, 2016.

Consumer Perception:

Improving consumer perception is a huge area of focus.

Only about 30% of the people polled in North America were willing to try edible insects. I took away 2 main hurdles.       stats

Consumer perception is that insects are not safe to eat. They largely associate insect with pests. The general public is not aware of how insect are farmed, processed and used as food. The lack of knowledge leads to the consumers feeling that the products are unsafe. They also don’t know that humans have been eating insects for thousands of years. How can this obstacle be address? Little Herds and educational groups are doing a great job educating people about the benefits of eating insects. A key message for consumers is that insects are just like any other food we eat.

The other hurdle I would like to mention is taste. One study (I don’t believe it is published yet) reported that people did not want to eat insect because they taste bad, even though they never have tried them. Insects do have their own unique flavor that people may be unaccustomed to. Who can people trust? Chefs are a great resource for the industry. People would be relatively more comfortable eating insects at a local restaurant that they have been at before and enjoyed their food. Chefs know how to make food taste great. Startups should get chefs involved with their product development to ensure the flavors are balanced and have just the right amount of seasoning.  The #1 deciding factor for why people choose what to eat is taste. If it doesn’t taste delicious, people won’t want to eat it.

Special thanks to ‘The Bug Chef’ David George Gordon for years of excellent work with edible insects.bug chef

‘Insect Cuisine’ as an alternative to ‘Edible Insects‘ was presented by Kiah Brasch. “‘Edible insect’ sounds like they are just barley acceptable as food”. I think ‘insect cuisine’ is great for consumer facing communications. #InsectCuisine!

Regulations

Featured speaker, Ricardo Carvajal, provided an overview of the regulatory frame work in the US. He had a post on his blog from 2013 that really jumped out at the industry. Move Over, Cricket! Lickets: Edible Insects are On the March

His advice was to work with in the current regulatory frame work. More regulations are not needed and should not be wanted.IMG_0919

Ricardo referenced the definition for food from the Food Drug and Cosmetic Act (Title 21 sec. 321(f))

The term “food” means (1) articles used for food or drink for man or other animals

The must be a “reasonable certainty of no harm” according to Ricardo. I searched the Food Drug and Cosmetic Act and did not find this phrase. What it does relate to is the definition for adulterated food in sec. 402.

‘A food shall be deemed to be adulterated… If it bears or contains any poisonous or deleterious substance which may render it injurious to health’

My assessment is that the phrase “reasonable certainty of no harm” is a succinct interpretation of the law.

I felt a collective sigh of relief from the attendee’s after the presentation. There was a general consensus that we don’t need edible insect specific regulations in the US.

Incredible Foods: Sal de CricketIMG_0940

I was signed up as a vendor with Incredible Foods! It was a lot of fun having a booth at the expo. I received a lot of positive feedback on Sal de Cricket. The concept was well liked and everyone loved the flavor. I had samples of seasoned beer cup and also on tortilla chips.

Thank you every one who organized, presented and attended. It was really great meeting everyone.

IMG_0922

Sal de Cricket Technical Bulletin

inspection gradeEdible insects are sensitive to regulator disapproval so it is especially import to have documentation on your edible insect products readily available. Insect are not commonly consumed in western cultures so auditors my be surprised to discover that they are being intentionally added to food. I hear this an issue that occurs at restaurants. Local health inspectors may need to be educated on insect cuisine.

There are two types of documents that I recommend that establishments have in their foods safety dossier. First is an executive summary about insects as food (which I will talk more about in a later post). Second is product specific documentation on each edible insect item being used. As an example, I drafted a technical bulletin for Sal de Cricket.

Key items: Product name, Company name, Contact information, Statement of regulatory compliance. I also suggest some specific information about the insects.

Technical Bulletin

Product Name: Sal de Cricket, 3 oz jar

Product Number: 1001

1001 sal de cricket jar seasoning

Description:

An edible insect seasoning made with organic roasted crickets and blended with sea salt, chili peppers and other spices/ingredients.

This product shall meet standards for food and comply with all provisions of the Federal Food, Drug and Cosmetic Act and Amendments.

Ingredient Declaration:

Sea Salt, Organic Roasted Cricket Powder (Acheta domesticus), Chili Pepper, Smoked Paprika, Lime Peel, Spices

Allergen Information:

Contains Crickets (people who are allergic to crustacean shellfish may also be allergic to crickets)

Pack Size

Net weight – 3 oz (83 g)

Gross weight – 0.5 lbs

Master case – 24 jars

Storage:

Store in a cool dry place away from direct light (50 – 70°F).

Shelf Life:

Best if used by date shall be on the bottom of the jar.

Manufacturing Location:

Produced in Texas.

Insect Information:

The insects shall be clean and wholesome, and produced/packed/stored under sanitary conditions. The insects shall be farmed, harvested and processed using Good Manufacturing Practices (GMPs). The insects shall be farmed specifically for human consumption in the US.

Contact Information

Mark

Incredible Foods

Fort Worth, Texas 76137

Mark@incrediblefoodscompany.com

Phone:  (817) 945-3117

That is it for now!

Sal de Cricket

Sal de Cricket is almost ready to launch. Here is snap shot of the decisions and details that went into the commercialization process.

The Primary Packaging-

Capture jar

I looked at a few different bottles and sized. The straight sided 4 oz volume-metric jar was selected in part because its different than the typical seasoning/ spice jar. Sal de Cricket is a premium product so glass was chosen over a plastic option. Glass looks really nice but also weighs more. Fortunately, my estimates puts it in the lowest weight class, even when full, for pre-paid shipping. Products geared toward online sales tend to have minimalist packaging. I do aspire to distribute via whole sale and I also feel the packaging adds value for the consumer.

Smaller bottles have constraints with the amount of info that can be on the label. There are other options like a secondary tag or box but it does added a step to production.

A white cap was selected by family vote. I’m also using a clear shrink band and a 1 x 0.375 in. label on the bottom for the expiration date.

The display panel  is approximately 15 sq. in. and provides just enough space for product branding and communication.

The Label Artwork –

The primary display panel contains the brand and product name, general description, potential uses and the mandatory pack weight.

Capture sal de cricket draft label

The right panel has additional product information.. the what and why, how to use it, and where to get more information. Also a bar code. I selected to purchase the bar code through a reputable re-seller instead of through GS-1 to save on the initial commercialization costs.

The left panel contains the nutrition fact panel, ingredient declaration and the company identification. The nutrition panel is the linear format to save space on the label. This is allowed as the label surface area is less than 40 sq. in. The simplified format and “Not a significant source of ____”exceptions are used. The other option was to not include a nutrition facts panel because sales are below the quota but I choose to include it as its more professional to do so.

Bob the Cricket was designed by a freelance artist and I added the Incredible Foods banner and the rest of the artwork.

I spent a lot of time and revisions to get it just right!

FullSizeRender(2)

The Seasoning –

Cricket powder, the key ingredient, is currently being sourced from Aspire in Austin, Texas. The drivers for selecting Aspire is that its a regional supplier to where I am located and it is also organic. I was also satisfied with their answers to the edible insect supplier questionnaire. I had also sampled from Entomo Farms and Cricket Flours and found them to be comparable in flavor and particle size.

Unlike most ento products on the market, Sal de Cricket celebrates the unique flavor of dry roasted ground crickets. Flavors of earthy, brothy notes and slight crustacean aroma are prevalent. Cricket powder is high in protein which adds rich umami taste.

seasoned rim sal de cricket crop 2

Sea salt makes the bulk of the blend. The salt has a medium particle size distribution that will work well for a variety of applications. A relatively bright chili was selected for the spice component. Cricket powder has a deep earthy note so a bright chili compliments it well. Additional paprika was added to provide additional pepper and natural smoke notes with out heat. Lime peel for additional brightness and bulk. A small amount of ground spices finish the blend for added character.

Legal –

Business registration is complete!

I also compiled a food safety dossier for Sal de Cricket.

Manufacturing –

An initial run is set up with a local food manufacturer.

Website –

See more about Sal de Cricket at IncredibleFoodsCompany.com

Distribution –

3rd party logistics is set up. Because its a food product, storing at my home is not permitted.

Marketing –

  • Visit me on twitter at twitter.com/incrediblefoods
  • I’m setting up a vendor booth at Eat Insects Detroit May 26-28, 2016
  • Local specialty store sales visits
  • Friends and Family calls seeking ambassadors
  • I have a lot more to learn in this area!

 

Follow Incredible Foods on twitter to stay in touch.

FDA Guidance on Edible Insects as Foods

I just want to follow up with a more detailed analysis of the FDA’s response to inquiry on edible insects. The documents are very helpful to the industry and provide insight into the FDA’s perspective.

One thing to keep in mind when referencing the documents is that they are Guidance Documents (even though that is not explicitly stated). In other words, the statements represent the FDA’s current think on the topic. As a reference, the FDA’s seafood guidance document has the following language in the preface and throughout the document:

This guidance represents the Food and Drug Administration’s (FDA’s) current thinking on this topic. It does not create or confer any rights for or on any person and does not operate to bind FDA or the public. You can use an alternative approach if the approach satisfies the requirements of the applicable statutes and regulations. If you want to discuss an alternative approach, contact the FDA staff responsible for implementing this guidance. If you cannot identify the appropriate FDA staff, call the telephone number listed on the title page of this guidance.

Secondly, some of the statements in the response do not appear as thoroughly research as one would expect from the FDA. Or maybe the statements reflect a conservative stance due to a lack of information on edibles insects and their novelty in the U.S. My comments are below.pic122

  • “bugs/insects are considered food if that is the intended use” – This checks out! Here is the actual verbiage in the code for Sec. 201(f): The term “food” means (1) articles used for food or drink for man or other animals, (2) chewing gum, and (3) articles used for components of any such article.
  • “The label should include scientific name” – Unfounded in law. Listing crickets as ‘Cricket’ or ‘Crickets’ or ‘Cricket Powder’ on the ingredient declaration is not false or misleading and it does not fail to meet any of the other criteria listed in Sec. 403. Shrimp, for comparison, is listed as ‘Shrimp’ on most ingredient declarations even though there are hundreds of different species.
  • “must be raised specifically for human food following current Good Manufacturing Practices” – I don’t think its coincidence that raised for human food and GMP’s are grouped together. My understanding is that most farms raise insects for pet feed and do not follow GMP’s. Keep in mind they are not mutually exclusive. If you follow GMP’s for human food, you are OK to distribute for food or feed. Commodity corn is diverted every which way. If current insect farms use GMP’s they can distribute insect for food and divert to feed if needed. To recap: Must use GMPs? – Yes, and therefore it is suitable for human consumption a long as other requirements are met.
  • “They cannot be ‘wildcrafted’ – Unfounded in science. Regulations state that food must be wholesome and not contain any deleterious substances. Disease and pesticides can be measured analytically, and if found, the product can be removed from the supply stream. Specifically, a risk assessment can be performed for common hazards such as pathogens, natural toxins, pesticides, and other contaminants and a monitoring program can be established. Seafood provides another great point of reference. There are a lot of hazards associated with wild caught fish and the risks are managed accordingly. The Fish and Fishery Products Hazards and Controls Guidance document can be applied to wild insects! For example: a plot of land can be disengaged for wild grasshopper farming. With the surrounding area monitored for pesticides, a farmer can reason that there are not any pesticides in the cultivated area or in their grasshoppers.
  • “The manufacturer also needs to demonstrate the “wholesomeness” of the product” – Yes… insects have an outstanding nutritional profile.
  • Allergens comment – Unfounded in law. The FDA requires only the ‘Big 8’ allergens be stated on the label. It is not scientifically conclusive that insects are an allergen. But because they likely are, the industry best practice is to include an allergy warning statement.

Next Step: As I feel that the FDA’s responses are akin to a guidance document, Im going to email the FDA and request an update. I think you should too.

80+ Edible Insect Products You Can Buy Now

Hotlix has been around for many years. Until recently, the only other source for edible insects in the U.S. was to buy live insects directly from farms (where they raise bugs for feed, not food). Now, there are a variety of sources and products available. I put together a list of products that are produced in the U.S., Canada or Mexico and available for sale.

Hotlix

Chocolate Covered (4 varieties)

HotLix chocolate

Snacks – Whole insects (6 varieties)

hotlix candy

Candy (4 varieties – multiple flavors)

hotlix lolipop

Suckers (4 varieties – multiple flavors)

hotlix candy

Chapul

Bars (4 flavors)

chapul bars

Cricket Baking Powder

 chapul baking powder

Cricket Powder (pure)

Chapul Protein Powder

Exo

Bars – Classic (5 varieties)

exo classic bars

Bars – Savory (4 varieties)

exo savory bars

Jungle Bar

Bars (1 flavor, multi-pack)

Screen_Shot_2016-02-04_at_12.50.25_grande

Hopper

Granola (3 flavors)

Cacao&Cayenne_cropped Crenberry&Almond Toasted+Coconut_cropped

uKa Proteine

Bars (2 flavors)

barre-cerise-the-ukaproteine

Bitty

Cookies (3 flavors)

bitty_3cookie_large

Baking Powder

41F32EmgcjL._AC_UL160_SR80,160_

SixFoods

Chirps – Chips (3 flavors)

all three

Crickers

Cracker (3 flavors)

IMG_4021_Seasalt_8oz

Entomo Farms (Independent Farm and Processor)

Powders – Pure (4 varieties)

entomo powder

Whole Roasted (5 varieties including meal worms and super worms)

entomo whole roaste

Whole Roasted Seasoned (6 varieties)

entomo whole seasoned

Aspire US (Independent Farm and Processor)

Cricket Powder Pure

IMG_0460

Frozen Raw Crickets

IMG_3503_large

Whole Dry Crickets

IMG_2848_large

Cricket Flours

Cricket Powder

7c5177d794df519009c150c53bc0efc0_Cricket-Flours-100-Pure-Qtrlb-Packaging-370-600-c

Cricket Oatmeal

b8098e99b2a8792ca7180970fe04b4eb_Cricket-Instant-Oatmeal-Single-370-600-c

Meal Replacer (crickets, 2 flavors)

95ca9ad2abee4cc3320f057574405384_Cricket-Fuel-CPB-5-Pack-370-600-c

Cricket All Purpose Flour

f2e43661be487de9ab8092c81103fb57_1lb-All-Purpose-Baking-Flour-370-600-c

Bug Eater Foods

Jump – Cricket Protein Shake (2 flavors)

sampler+isolation

Crik Nutrition

Protein Shake Dy Mix (1 flavor)

Vanilla-Cricket-Protein-Powder-Front

Don Bugito

Seasoned/Chocolate Covered (5 varieties)

il_170x135.590355912_3fqv il_170x135.590353296_qos6

Sal de Gusano

il_570xN.684750783_igqd

Almond and Cricket Flour

il_170x135.782570049_k0ej

Gran Milta

Sal de Gusano (worm salt)

100grams

Sal de Chaplulin (grasshopper salt)

100-Chapulin

EntoVida

Whole sale but available on Ento Market

ento vida

Ento Market

Ento Market has just about all of the above available in one place!

Honorable Mentions

Gryllies

pastajar

Bugsolutely

Bugsolutely-6OK

All Things Bugs – Cricket powder, domestic, whole sale only

Big Cricket Farms

Thinksects – cricket powder from Thailand

Wild Bakery – cricket powder from Thailand

Thailand Unique – They offer variety of imported products

LEAP – North American cricket Powder via Amazon but I could not find their website

Critter Bitter – available for pre-order

What else is out there?

Let us know on twitter!