What are the key points in UK cultivated meat guidance? Summary
- UK issues first guidance for cultivated meat novel food applications
- Cultivated meat defined as animal origin but not classified as meat
- Nutritional profile should match conventional meat including key vitamins and minerals
- Manufacturers required to ensure batch consistency across at least five representative samples
- Cell sourcing must avoid contamination and verify withdrawal periods for medications given to livestock
One of the biggest barriers facing cultivated meat is regulation. In many markets, cultivated meat must go through a lengthy novel food assessment before entering the market.
In the UK and EU, the stringency of these assessments, and subsequent long waiting times have meant that no cultivated meat product has yet made it to market.
In the EU, these long waiting times could soon be cut. The new director of the European Food Safety Authority (EFSA), Dr Nikolaus Kriz, has said that quicker assessments are his “lighthouse” and has pledged to speed them up.
In the UK, a regulatory sandbox is already in place for cultivated meat, allowing businesses to test their products out without the regulatory burden.
Now, the UK’s Food Standards Agency (FSA) and Food Standards Scotland (FSS) have released their first guidance on submitting a novel food application for cultivated meat.
1. Cultivated meat defined as product ‘of animal origin’ but not ‘meat’
While debates around the labelling of meat alternatives rage on the European mainland, in the UK cultivated meat is defined as a product “of animal origin”, as specified under the EU’s regulation on animal origin products (which the UK inherited).
Specifically, the guidance refers to cells cultivated from meat, seafood (fish and shellfish), fat, offal, or fertilised eggs.
This means that existing food safety regulations apply during the production process.
Conversely, the FSA and FSS do not consider these products “meat”, which are defined by EU regulation as the “edible parts of animals, including blood”.
Food that is considered an allergen, such as shellfish, will also be considered an allergen in its cultivated form.
2. Nutrition will be compared to conventional meat
The nutritional content of the cultivated meat and seafood, particularly the protein profile, will be compared with its conventional meat counterpart.
In particular, applicants should compare the nutritional content of their products with conventional meat or seafood, specifically in reference to zinc, iron, selenium, vitamin D, vitamin B12, riboflavin, folate, creatine, essential amino acids, and long-chain fatty acids (such as omega-3).
It should also consider the digestibility and bioavailability of certain nutrients (e.g. haem iron, found mostly in animal foods, is more bioavailable than non-haem iron, which is often found in plant-based foods). The quality of protein, meanwhile, will be assessed by the common measure Digestible Indispensable Amino Acid Score (DIAAS).
If the nutritional profile compares in any way adversely to the conventional meat counterpart, this must be justified to assure regulators it will not adversely affect consumer health.
3. Batch consistency must be maintained
Manufacturers must perform analysis on at least five representative batches. If they undertake analysis on fewer than this, they must explain the reasons.
If continuous production is used, at least two independent starting cell stocks must be represented in analysis.
Consistency across batches must be observed. If there is variability, manufacturers must explain where this comes from and how it will be controlled.
Analysis must be done on both the novel food as submitted (for example, the cell biomass) and the finished product, if applicable.
4. Care must be taken in cell line sourcing and sampling
Manufacturers must take care in sourcing the cell line, as well as the process of sampling cells.
As the production of cultivated meat does not involve live animals, traditional hazards associated with meat, such as microbial contamination from the gastrointestinal tract and faeces, will not apply.
Instead, manufacturers must pay particular attention to the identity of the cell line which they are using.
Care must also be taken when sampling cells. If the animal from which the cells are sampled has been on medicines or antimicrobials, there must be evidence of a withdrawal period before the sample was taken, or data showing the residual levels within the product. This applies to both live and slaughtered animals.
Manufacturers should also consider the potential for allergens to be introduced in all stages of production, from the source of the cells, through to the post-harvesting stage.
