Gelatin and collagen can be extracted from parts of fish other than skin and bones, with a view to increasing the circular economy performance of the fish supply chain. This type of innovation is part of the EcoeFISHent research project, in Horizon Europe (1,2).
However, the placing of these food ingredients on the European Union market requires an update of Hygiene 2 Regulation (EC) No 853/04, as well as a careful verification of the possible application of the Novel Foods Regulation (EU) No 2015/2283 (3,4).
Below, the opinion expressed by the European Commission, DG Sante, in response to the specific questions formulated by our Wiise benefit team which participates in the EcoeFISHent consortium to follow the regulatory aspects and diffusion. (5)
1) Gelatin and collagen from fish parts other than fish and bones
‘The production of gelatin and collagen for human consumption from sources other than fish skin and bones would effectively require an amendment of Annex III, Sections XIV and XV, Chapter 1.1.g through a Commission Delegated Regulation before any placing on the market.
Black gelatin and collagen meeting the conditions of those sections may be placed on the market for human consumption.
In case of publication of scientific evidence demonstrating the safety of alternative production processes for gelatine and collagen, the Commission is likely to submit this data to EFSA for a risk assessment before proposing a possible amendment to the relevant sections of Annex III of the Regulation (EC) no. 853/2004′. (5)
2) Novel Foods Regulation
‘Novel Foods Regulation (EU) No 2015/2283 requires food business operators to check whether the food they intend to place on the EU market falls within the scope of the Novel Foods Regulation, i.e. whether the food is new or not (Article 4).
‘The operators in the food sector who – after having considered all available information – are still unsure about the possible qualification of a food as Novel Food, must consult the competent authorities of the EU Member States where they intend to place the food on the market for the first time ‘.
Commission Implementing Regulation (EU) 2018/456 establishes the information requirements that must be included in the request for consultation, including provisions on the confidentiality of the request, as well as the procedure to be followed by industry operators for the consultation process'(5,6).
3) Use of enzymes in the production of fish oil
One further question submitted to the European Commission concerns the possibility of using enzymes in fish oil production processes.
Chapter IV B(2) of section VIII of Annex III of Regulation (EC) no. 853/2004 does not prohibit the use of enzymes in the production of fish oil intended for human consumption.”
4) Upcycling prospects in the seafood supply chain
The rejects (sidestream materials) represent a significant share of the material flows (output) in the fish supply chain, in the fishing and aquaculture phases as well as in the processing industry and distribution.
The EcoeFISHent project aspires to optimize technologies to reduce the volumes of materials still intended for disposal, thanks to its partner Themis, and their upcycling to produce food ingredients, medicines and cosmetics.
The perspectives of reducing ‘food loss and waste’ (FLW) in this supply chain are promising, also in the perspective of significantly contributing to food security, and the validation of the studies may lead to the need for reforms.
Dario Dongo
Footnotes
(1) Dario Dongo, Andrea Adelmo Della Penna. EcoeFISHent, upcycling and blue economy in the fish supply chain. The EU research project. GIFT (Great Italian Food Trade).
(2) Dario Dongo, Alessandra Mei. Aquaculture, reduction and upcycling of fish waste in proteins, Omega-3 and micronutrients. GIFT (Great Italian Food Trade).
(3) Reg. (EC) No 853/04 laying down specific hygiene rules for food of animal origin. Latest consolidated version 9.5.24 https://tinyurl.com/zhat2hzh
(4) Dario Dongo, Andrea Adelmo Della Penna. Novel foods, the state of the art in the European Union. GIFT (Great Italian Food Trade).
(5) European Commission, DG Sante. Answer No #4489966, 20.8.24
(6) Commission Implementing Regulation (EU) 2018/456 on the procedural steps of the consultation process for determination of novel food status in accordance with Regulation (EU) 2015/2283 on novel foods https://tinyurl.com/k4e7drft
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
