What counts as a novel food?

The definition is deliberately broad. It covers foods with new or modified molecular structures, foods derived from microorganisms, fungi, algae, insects, or cell cultures, and foods produced using new processing techniques, such as certain extraction or fermentation methods, where those techniques significantly change the food's composition or nutritional value. It also includes foods that have long been eaten outside the EU but are new to European consumers.

Several of the seven protein sources at the heart of the LIKE-A-PRO project fall within this definition, including mealworm protein, microbial protein, and fermented fungal protein.

Is your product already authorised?

Before assuming your product needs a new authorisation, it is worth checking the Union List of Authorised Novel Foods, the official EU register of approved novel foods. If your product is already on the list, it can go to market in accordance with the stated conditions of use and labelling requirements.

Some alternative protein ingredients have already been approved. These include:

• Mung bean protein (Vigna radiata)
• House cricket (Acheta domesticus) in frozen, dried and powder forms
• Pea and rice protein fermented by Shiitake mushroom mycelia
• Partially defatted rapeseed powder
• Duckweed (Wolffia arhiza and Wolffia globosa)

If your product is not on the list, the next step is to determine whether it was consumed to a significant degree in the EU before May 1997. If it was, it is not a novel food, but you should document your evidence carefully.

Two routes to authorisation

If your product does qualify as an unapproved novel food, there are two routes to market.

Standard application — for new or innovative foods. Requires extensive safety data, including toxicological studies, assessed by the European Food Safety Authority (EFSA). The process takes an average of 2.5 years, though some cases have extended to six years or more. The quality and completeness of the submitted application is the single biggest factor in how quickly a decision is reached.

Traditional food notification — for foods with at least 25 years of documented safe consumption in a non-EU country. A lighter-touch route that focuses on demonstrating a history of safe use rather than full toxicological studies. If no safety objections are raised within four months, the food can be authorised.

It is also worth knowing that joint applications are possible, where multiple parties share the time and cost of a submission, and that newly generated safety data can be protected for five years after authorisation, offering some return on the investment made in generating that evidence.

The EU and the US: two very different routes to market

In the United States, the GRAS (Generally Recognised As Safe) framework allows companies to self-determine whether a food ingredient is safe, or submit a voluntary notification to the FDA, a process that typically takes 6 to 18 months. The EU's approach is more rigorous and considerably slower, but it grants access to a single, pan-European market once authorisation is secured.

For alternative protein innovators operating across multiple markets, understanding both systems, and planning regulatory strategy early, is increasingly important.

A core part of making alternative proteins mainstream

Several of the seven protein sources that the LIKE-A-PRO project is working with, including mealworm protein, microbial protein, fermented fungal protein, and certain processing approaches for rapeseed protein, either fall within the scope of the Novel Food Regulation or may require careful assessment to determine their status.

Understanding this regulatory framework is therefore not just a legal formality. It is a core part of making alternative proteins genuinely accessible, scalable, and mainstream, which is exactly what LIKE-A-PRO is working towards.

Download the full Novel Food Regulation document here