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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!