The report for a project (FA0197) funded by the UK Department for Environment, Food and Rural Affairs (Defra) on the Implications of emerging novel proteins for food authenticity and labelling has been published.
The project focused on potential emerging risks regarding authenticity and labelling of alternative protein products, how these products may fit under the current regulatory framework for food labelling and how current testing capability can support product authentication and detection of emerging fraud risks in this sector.
The report has been added to the Research section of this website.
Authenticity and fraud
According to the sources consulted for this review, little consideration has been given to potential food fraud in the alternative protein sector, especially by innovators and producers. However, the developments in the field inevitably will carry associated risks of food fraud. Situations that might act as drivers of food fraud such as the alternative protein being more expensive or harder to source than the equivalent animal protein can be envisaged, especially with new technologies/sources that may not yet be well established and require pre-market regulatory approval. Ingredient substitution can occur in any
category and direction, alternative for conventional and vice versa.
For some novel products, the supply chain may be more complicated and fragmented, and this may make them more vulnerable to fraud. Adulteration of proteins in powder forms has been identified as high risk, and verification of recombinant animal proteins produced by precision fermentation (as distinct from animal-derived proteins) as a challenge.
Current analytical methods for food authentication will face issues such as a lack of genome data for novel species, the effect of novel processing techniques on biomolecules, identification of animal proteins produced by precision fermentation or identification of cell lines used for cultivated meat products.
Since the extent of processing can affect the efficacy of analytical methodologies, some existing methods may require updating to be effective on materials due to the more highly processed nature of many novel foods. Genomic information for the species used as sources of protein is required along with proteomics and metabolomics databases and bioinformatics tools to support analytical methods. Spectroscopy techniques and orthogonal methods that integrate data from different technologies are regarded as powerful tools that will support verification of alternative protein products.
Additional tools to support authenticity of alternative proteins
In addition to analytical methods, the wider food supply chain control systems must evolve to accommodate emerging complexities. Areas identified as potentially promising to mitigate food fraud risks include:
• Computational solutions: block chain, big data, artificial intelligence
• Integration of computational tools with analytical technologies such as sensors or molecular markers
• Standards and certification schemes
Labelling of alternative proteins
There are two main points of debate around labelling of alternative proteins globally: (i) the concern about the use of descriptors traditionally used for animal-derived products to label and market substitutes made of non-animal protein, and (ii) the question of transparency about the methods of production. Regarding names, as well as imagery used on labels, the regulations vary across countries and, with the fast development of novel products, the issue is a current topic of debate. In the UK, food information and labelling are governed by the Food Information to Consumers Regulation 1169/2011. This regulation outlines the general requirement for labelling to be clear, easy to understand, visible and not misleading as to the characteristics and nature of the food. Additionally, the Common Market Organisation (CMO) regulations, retained from EU legislation dealing with sales descriptions for dairy, reserves the term milk, and various milk product terms exclusively for dairy. However, meat terms do not have the same degree of protection, and descriptors such as ‘burger’ or ‘sausage’, as well as related imagery are used in the alternative protein sector.
Regarding methods of production, in some cases, there may be a conflict between providing transparency and the technical complexities of the methods. Using terminology that is clear for consumers may be difficult, for example, there is debate about the most appropriate name for meat produced in vitro, as terms like ‘cultured’, ‘cultivated’, ‘synthetic’, ‘lab-grown’, etc, may be viewed by consumers as unclear or negative. The evidence found during this project (stakeholder interviews, early consumer research found in literature, comments from conference) mostly supports the use of terms that refer
to the format of the product (burger, sausage, etc) as long as the label clearly states the non-animal source, although further research into consumer perceptions of APs is needed to fully understand this emerging area.
Future research needs
Short-term (0 – 3 years)
• Impact of new processing technologies on performance of existing authenticity tests.
o Survey of existing AP products for which DNA or protein-based speciation methods exist to assess performance.
o Studies on products and techniques under development, e.g, 3-D printing, new extraction methods.
• Identify and address points of vulnerability in the supply chain.
• Methods for detection of adulteration with nitrogen compounds.
• Investigate biomarkers to support authenticity testing of APs (plant-based, mycoproteins, precision fermentation).
• Support databases as tools for authenticity testing – genome, proteome, metabolome, spectral data, isotope ratios. Collaboration and data sharing are essential.
• Research into allergenicity potential and allergen detection in APs. Although this falls under the safety assessment of foods and therefore outside Defra’s remit, it is tightly linked to food authenticity and labelling, and the ability to verify food composition.
Medium-term (3-5 years)
• Build on learnings and develop new detection methods using biomarkers identified, new databases, knowledge of how new technologies may alter biomolecules.
• Develop reference materials to support testing of AP.
• Validate testing methods across laboratories.
• Build on biomarkers and methods to cover other categories of AP such as insect protein, algae protein.
• Continue to work on databases expanding to new sources of proteins - genome, proteome, metabolome, spectral data, isotope ratios.
• Engage with big data, artificial intelligence, block chain initiatives and research into application to food authenticity.
• Identify and address points of vulnerability in the supply chain.
• Analyse fraud in the AP sector to inform improvements to control and development of testing tools to support risk mitigation.
Long-term (5+ years)
• Continue to build on biomarkers and methods to cover other categories of AP such as cultivated meat and seafood, novel microorganisms grown for biomass.
• Continue to assess the AP food supply chain to adapt to increasing complexities (new sources of raw materials, novel technologies, sourcing ingredients from different countries, etc). Additional research on traceability and authenticity of new ingredients.
• Continue to develop big data and computational tools and integration with testing methodologies.