Food safety consulting, can products be manufactured based on new foods?
Can it be manufactured using new foods for export?
As a food safety consultancy, we answer a frequent question from the manufacturers of food supplements. Can it be manufactured using new foods for export?
There is no impediment in the legislation food supplements in manufacturing products based on new foods not authorized in the EU. Which can not be marketed until they go through the relevant process of evaluation and authorization of new foods.
The problem will arise in the Department of Foreign Trade of the Ministry of Health. As we have been able to confirm as a food safety consultancy, two basic problems arise:
- If the raw material or the ingredient that is unauthorized novel food is imported into Spain, customs will not allow its entry. This is because it is a prohibited ingredient in Spain for human consumption.
Nor would it be possible to import it as a product for animal feed (or any other destination other than human consumption) and then export it categorized as food for human consumption. If you do not enter for human consumption, you cannot leave for this purpose.
- If the raw material comes from the EU or directly is a national raw material, the problem is going to be the exit of Spain from the product.
Since being considered a product of animal origin, it requires a sanitary export certificate. This certificate is issued by the competent health authority, and in no case will they certify products that contain unauthorized ingredients in the EU.
Likewise, even if a sanitary export certificate was not necessary, in order to exit the products for human consumption, in customs, the product must be categorized into already defined categories. A product based on insects or parts of them is not contemplated in any of them. So this would be another reason why it could not be exported outside the EU.