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Regulatory Situation in the EU on Lab-Grown Ingredients

Focus on Ingredients Imitating Milk Proteins

Amelie de Grahl, Emmanuel Treuil


More and more start-up companies around the world are developing processing technologies to produce ingredients that imitate, for instance, proteins usually found in milk obtained from cows. These ‘lab-grown ingredients’ must undergo a pre-market authorization either according to Regulation (EC) 1829/2003 on genetically modified food and feed or according to Regulation (EU) 2015/2283 on Novel Foods, depending on whether the new product contains host-DNA protein or not. In both cases, the name of the new ingredient must comply with horizontal and vertical EU Regulation. This article aims to give an insight into some of the technologies used as well as the regulatory requirements for the placing on the market of lab-grown ingredients. Regarding the labelling of such ingredients as well as the final products incorporating such ingredients, the authors recall the specific European rules on the absolute protection of dairy terms laid down in Regulation (EU) No 1308/2013 establishing a common organisation of the markets in agricultural products. Accordingly, lab-grown ingredients and products incorporating them are not allowed to use any milk and dairy designations.

Amelie de Grahl and Emmanuel Treuil are co-chairs of the Claims & Labelling Working Group, European Dairy Association. For correspondece: degrahl@milchindustrie.de

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