Foodlaw-Reading
Dr David Jukes, The University of Reading, UK
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FSA Enforcement Letter (IMPEN20011), 11 March 2020
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FSA Enforcment Letter: Changes to Import Authorisations for Insects into the European Unionement Letter A copy of the letter and accompanying Annex is available on this site (click on image). Provided uder the Open Government Licence. The original publication accessed from: |
The following is the text of the letter:
The conditions for the importation into the UK of most products of animal origin for human consumption are set out in EU legislation. Enforcement of import controls at the border is laid down the Trade in Animals and Related Products Regulation 2011 as amended. Regulation 15.5 of those Regulations states:
(5) If there are no legislative requirements relating to the consignment, the official veterinary surgeon must not issue a CHED unless the importation has been authorised in writing under this paragraph by— (a) the Food Standards Agency, for any product for which only public health requirements apply; or (b) the Secretary of State, for any other product.
As there were no legislative requirements for imports of insect meat, the Animal and Plant Health Agency issued authorisations permitting imports of insect products subject to appropriate import conditions. The European Union has now implemented harmonised rules for the importation of insect meat/products and as such an import authorisation is no longer required. However, you must ensure that imports comply with the import conditions laid down in the legislation.
Commission Implementing Regulation (EU) 2019/1981 has amended Article 20 of Implementing Regulation (EU) 2019/626 so that consignments of insects intended for human consumption shall only be authorised for the entry into the Union if such foods have originated in and been consigned from a third country or region thereof, listed in Annex IIIa of Regulation (EU) 2019/1981.
To date, only three countries have given the EU sufficient guarantee that they comply with the requirements and should therefore be listed as authorised for the entry into the Union of insects.
The countries currently listed in Annex IIIa of Regulation (EU) 2019/1981 are Canada, Switzerland and South Korea.
In summary, to import insects for human consumption you need to ensure that:
Note: To help understanding as to how these changes may impact a business, a flow chart and accompanying notes are provided in the Annex to the letter.
