Export of dried cricket and cricket powder

Dear gentlemen, i have a cricket farm in Cambodia, it's field cricket and Jamaican field cricket. The production has been successful. We are producing 4 tons per month and are planning to scale up production. The products are in frozen, dried and powdered form.

I am thinking of exporting our product to the US or Europe for human use and pet food. But i am not sure if this is possible. I will be grateful if you can clarify : (1) if it is possible to export cricked related product to US and EU for pet and human use under current regulation? (2) what certificates do I need to have to qualify? (3) where can i research the country regulation? all comments are invaluable Sincerely

Comments

  • Regarding USA: "Edible insects:future prospects for food and feed security" stated there are ".... unclear regulations and legislation on farming and selling insects for human consumption and feed the FDA’s Food Defect Action Levels lists allowable percentages of insect fragments in food, yet insects as food do not seem to fall into any category...."

    Food & Drug Administration (FDA) in USA makes it's own regulations concerning potential food born illness in animals & humans. All pet & livestock food manufacturers have to follow approved food safety processes, keep records ready & must comply with any imposition of new procedures regarding sanitary handling.

    To operate on a commercial level the U.S.A. Food and Drug Administration (FDA) requires you to file a "Prior Notice" (PN) with them. They then give you a "PN number" & that PN number must be included with the "bill of lading" ( or an airway bill) documents accompanying the insects when it enters the U.S.A. Customs and Border Protection inspection control.

    If you sent them frozen cold then I think the U.S.A. Food Safety Inspection Service would be called in & they can set regulations on if the shipment is allowed to be imported or rejected. Dried crickets are probably simpler to get through Customs.

    Andrew has stated elsewhere in the Forum that "... in the US, in order to sell insects for human consumption, they must be designated (in farming) for human consumption, and the farming and processing must follow the same 'Good Manufacturing Practices' designated for raising and processing other meat products."

    His links to US regulations regarding animal feed and pet food FDA pet food regulations = fda.gov/animalveterinary/products/AnimalFoodFeeds/PetFood/default.htm animal feed regulations ... & ... fda.gov/AnimalVeterinary/ResourcesforYou/AnimalHealthLiteracy/ucm191891.htm

    European Parliament Regulation Nr 258/1997 deals with "novel foods/novel ingredients) & there was Recommendation 97/618/CE which created a requirement for "premarket risk assessment". But some posit that insects are not covered as a "Novel Food".

    Quote: "As a result of this interpretation, insects are allowed into the UK market and, given the way the community market is organized, are consequently allowed into the EU. The British position probably is not well known or accepted."

    As per (2013) "Edible Insects in a Food Safety and Nutritional Perspective: A Critical Review"; free full text = http://onlinelibrary.wiley.com/doi/10.1111/1541-4337.12014/full

    To file request for insects as novel food in Belgium from Federal Public Service, link = http://www.health.belgium.be/en/request-novel-food-status

    Belgian "Elevage et commercialisation d’insectes et de denrées à base d’insectes pour la consommation humaine" discusses "... les règles générales qui sont d’application pour l’élevage et la commercialisation des insectes et des denrées à base d’insectes pour la consommation humaine ...."; Link to PDF = http://www.afsca.be/denreesalimentaires/circulaires/_documents/2016-04-26_circ-ob_FR_insectes_V2_clean.pdf ... & .... http://www.afsca.be/denreesalimentaires/circulaires/_documents/2016-04-26_circ-ob_FR_insectes_V2_TC.pdf

    European Union : " ... A novel food or ingredient may be marketed through a simplified procedure called "notification" (Article 5 of Regulation (EC) No 258/97). The company notifies the Commission about their intention to place on the market a novel food or ingredient based on the opinion of a Member State food assessment body that has established "substantial equivalence" to an already authorised novel food...." = http://ec.europa.eu/food/safety/novel_food/authorisations_en ... & ... where to apply for specific countries = https://ec.europa.eu/food/sites/food/files/safety/docs/novel-food_ms-authority-list_en.pdf

    See "Placing on the market of insects and insect-based foods intended for human consumption", link = http://www.afsca.be/foodstuffs/insects/

    For European Union pay attention to subject "MANDATORY FOOD INFORMATION" (Chapter 4), Section 2, item Article 21: " Labelling of certain substances or products causing allergies or intolerances"; Full document link = http://eur-lex.europa.eu/legal-content/EN/TXT/ qid=1437646910397&uri=CELEX:02011R1169-20140219

    (2014) Scientific Committee and the Superior Health Council published "Food safety aspects of insects intended for human consumption"; link = http://www.afsca.be/scientificcommittee/opinions/2014/_documents/Advice14-2014_ENG_DOSSIER2014-04.pdf ... cites Federal Agency for the Safety of the Food Chain "Circular concerning the breeding and marketing of insects and insect based food for human consumption"; link = http://www.afsca.be/foodstuffs/insects/_documents/2014-05-21_Circular_insects_version11_EN.pdf ... & refers to existing animal product management techniques for insect product regulations "Aliments pour bétail: produits d’origine animale", link

    = http://www.favv-afsca.fgov.be/productionanimale/alimentation/produits/

    (2013) "... the current situation regarding legislation and regulation in Europe, Africa and China concerning the use of ‘processed animal protein’ (PAP) from insects and by implication from household flies and black soldier flies the focus of PROteINSECT research, for use in animal feed for pigs, poultry and fish." Link : R.Smith & R. Pryor's "Enabling the exploitation of Insects as a Sustainable Source of Protein for Animal Feed and Human Nutrition." = http://www.proteinsect.eu/fileadmin/user_upload/deliverables/D5.1t-FINAL.pdf

  • @gringojay thanks so much, the comment is very helpful

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