de Boer, Alie

Röttger-Wirtz, S.

English

Maastricht University Research Portal

   The limits of legal metamorphosis – the Novel Food Statusof insectsCitation for published version (APA):Röttger-Wirtz, S. (Author), & de Boer, A. (Author). (2020). The limits of legal metamorphosis – the NovelFood Status of insects. Web publication/site, EU Law Live. https://eulawlive.com/op-ed-the-limits-of-legal-metamorphosis-the-novel-food-status-of-insects-by-dr-sabrina-rottger-wirtz-and-dr-alie-de-boer/Document status and date:Published: 05/10/2020Document Version:Publisher's PDF, also known as Version of recordPlease check the document version of this publication:• A submitted manuscript is the version of the article upon submission and before peer-review. There canbe important differences between the submitted version and the official published version of record.People interested in the research are advised to contact the author for the final version of the publication,or visit the DOI to the publisher's website.• The final author version and the galley proof are versions of the publication after peer review.• The final published version features the final layout of the paper including the volume, issue and pagenumbers.Link to publicationGeneral rightsCopyright and moral rights for the publications made accessible in the public portal are retained by the authors and/or other copyrightowners and it is a condition of accessing publications that users recognise and abide by the legal requirements associated with theserights.• Users may download and print one copy of any publication from the public portal for the purpose of private study or research.• You may not further distribute the material or use it for any profit-making activity or commercial gain• You may freely distribute the URL identifying the publication in the public portal.If the publication is distributed under the terms of Article 25fa of the Dutch Copyright Act, indicated by the “Taverne” license above,please follow below link for the End User Agreement:www.umlib.nl/taverne-licenseTake down policyIf you believe that this document breaches copyright please contact us at:repository@maastrichtuniversity.nlproviding details and we will investigate your claim.Download date: 13 Dec. 202305.10.20, 13)24Op-Ed: "The limits of legal metamorphosis – the Novel Food Status o…cts” by Dr Sabrina Röttger-Wirtz and Dr Alie de Boer - EU Law LivePage 1 of 6https://eulawlive.com/op-ed-the-limits-of-legal-metamorphosis-the-no…-status-of-insects-by-dr-sabrina-rottger-wirtz-and-dr-alie-de-boer/OCTOBER 052020 LOGIN ADVANCED SEARCHDAILY CONTENT AREAS OF PRACTICE MORNING AGENDA LIBRARYEVENTS WEEKEND EDITION EU LAW LIVE PODCAST SHARE5TH OCTOBER 2020 CONSUMER, HEALTH & ENVIRONMENTOp-Ed: “The limits of legalmetamorphosis – the Novel FoodStatus of insects” by Dr SabrinaRöttger-Wirtz and Dr Alie de BoerMetamorphosis – an abrupt striking change in form, structure or substance –is generally a phenomenon witnessed in biology or common motif in prose.However, as the Entoma case shows, law also encounters this phenomenon: the novel food status of insects was subject to a potential metamorphosisunder the – by now replaced – Novel Food Regulation 258/97. The Court ofJustice had to examine how far legal interpretation can stretch, before itamounts to completely transforming (and essentially rewriting) a legislativeprovision.In 1997, very much in the wake of the BSE crisis, food safety was high on theagenda in EU Law. It was also a time of radical scientific and technologicaladvancement with the rise of nanotechnologies, cloning and geneticmodification. Against this backdrop the 1997 Novel Food Regulation wasadopted to ensure the safety of all foods, while only introducing a pre-marketprocedure for those products that were significantly changed.# "05.10.20, 13)24Op-Ed: "The limits of legal metamorphosis – the Novel Food Status o…cts” by Dr Sabrina Röttger-Wirtz and Dr Alie de Boer - EU Law LivePage 2 of 6https://eulawlive.com/op-ed-the-limits-of-legal-metamorphosis-the-no…-status-of-insects-by-dr-sabrina-rottger-wirtz-and-dr-alie-de-boer/What was apparently not on the table when drafting the food legislation wasthe consumption of insects in the average European’s diet outside of TVshow challenges. However, in the search for alternative protein sources andthe integration of more exotic foods in European diets, insects slowly crawledon the European market. However, the Member States adopted diverging anddisputed interpretations of the Novel Food Regulation, and some classifiedwhole insects as novel foods, which made their marketing illegal beforehaving obtained a marketing authorisation. Other Member States believedthat whole insects were not considered novel under the Regulation.Ultimately, the seller of whole insects – Entoma – took legal action against aFrench order to withdraw its products from the market due to a lack ofauthorisation. This led to the Entoma preliminary ruling discussed here, inwhich the Court of Justice was asked to settle questions on whether insectsare novel foods under the 1997 Regulation or not.The Novel Food Regulation 258/97 defined novel foods on the basis of a twocumulative criteria: (i) the lack of a significant degree of human consumptionof food and food ingredients in the EU before the Regulation entered intoforce (15 of May 1997) and (ii) if it falls into one of the six categories of foodslisted in Article 1. The relevant category in question was: ‘(e) foods and foodingredients consisting of or isolated from plants and food ingredientsisolated from animals, except for foods and food ingredients obtained bytraditional propagating or breeding practices and having a history of safefood use’.For context, it should be said that Novel Food Regulation 258/97 wasreplaced by the new Novel Food Regulation 2015/2283 which was adopteddue to the need to revise, clarify and update the legal framework. In the newNovel Food Regulation the fact that whole insects are covered by the novelfood definition is absolutely clear, as the relevant category now reads ‘(v)food consisting of, isolated from, or produced from animal or their parts (…)’and Recital 8 confirms that whole insects and their parts are covered by theRegulation.However, the Court of Justice – and the Advocate General – had to disregardthe recent clarification and only examine the scope as applicable at the time.The Opinion of AG Bobek is a textbook-worthy (and highly entertaining)exercise in applying different legal interpretation methods. AG Bobek by nowcertainly is an expert in the judicial interpretation of EU food law in the faceof changing circumstances, given that he also carried out a similar exercise incase C-528/16, arguing that the new gene-editing techniques are notcovered by the GMO Deliberate Release Directive (although the Court did notfollow his interpretation). In Entoma, AG Bobek concludes that neither a05.10.20, 13)24Op-Ed: "The limits of legal metamorphosis – the Novel Food Status o…cts” by Dr Sabrina Röttger-Wirtz and Dr Alie de Boer - EU Law LivePage 3 of 6https://eulawlive.com/op-ed-the-limits-of-legal-metamorphosis-the-no…-status-of-insects-by-dr-sabrina-rottger-wirtz-and-dr-alie-de-boer/textual interpretation, nor systematic or historical interpretation would bringwhole insects into the remit of the provision ‘food ingredients isolated fromanimals’. France also argued for a teleological expansion of the scope of theregulation – based on the idea that if isolates from insects are regulated dueto their risk to human health, then whole insects should be too as theypresent the same or an even greater risk. This dynamic interpretation of theprovision in question was outright denied by AG Bobek – he called it aeuphemism for legislating via ‘ex post interpretative readjustments’, andmade clear that an ‘interpretation cannot be contra legem’.In its judgment, leaning on the Opinion of the AG, the Court also engaged in aliteral interpretation of the provision. It examined the usual meaning of thewords and came to the conclusion that ingredients are not consumed bythemselves but added substances to create food, and that ‘isolated from’refers to an extraction process which excludes the whole animal from itsscope. According to the Court this also holds true when examining thecontext and objectives of the Regulation. Thus, the Court concluded thatwhole insects were not covered by the 1997 Novel Food Regulation. Thisfinding not only has historical value under the 1997 Novel Foods Regulation,but also means that whole insects can benefit from the transitional provisionintroduced in Article 35(2) of Regulation 2015/2283, which allows producersthat marketed insects before 1 January 2018 to keep them on the marketuntil a decision is taken on their authorisation requests that needed to besubmitted until 2 January 2020.What is the moral of this denied metamorphosis story? An often-repeatednarrative is the EU’s cautious regulation of novel products and its allegednegative effects on innovation. Nevertheless, as the case of insects shows,legal uncertainty can be equally damaging to an industry in the making,especially where high R&D investments are required. The costs of legaluncertainty are even more difficult to bear in an industry mostly composed ofSMEs like the insects-food and feed industry. If Member States wereconcerned about risks to the food and feed use of whole insects, they wouldhave had the means to address the problem without (artificially) extendingthe scope of the Regulation. As noted by the Court and the AG, where theNovel Food Regulation would have been deemed not to cover whole insects,the Member States had been free to adopt national measures to protecthuman health under the regular free movement of goods exception scheme(Articles 34 and 36 TFEU). To this we would like to add that the EU has a verydetailed food safety system in place beyond the Novel Food Regulation,providing rules on chemical and biological safety and response mechanismsto emerging risks (like the safeguard clause in the GFL as well as the RASFF).05.10.20, 13)24Op-Ed: "The limits of legal metamorphosis – the Novel Food Status o…cts” by Dr Sabrina Röttger-Wirtz and Dr Alie de Boer - EU Law LivePage 4 of 6https://eulawlive.com/op-ed-the-limits-of-legal-metamorphosis-the-no…-status-of-insects-by-dr-sabrina-rottger-wirtz-and-dr-alie-de-boer/If some Member States were concerned about the risks of whole insectsbefore, calling for EU harmonisation would also have been an option – as thefollowing revision of the Novel Food Regulation has shown. So what are thepotential health risks of consuming insects? In 2015, EFSA published a firstrisk profile concerning insects for food and feed use, in which it was clarifiedthat the main safety concerns arise from microbiological hazards (due to themicrobiota in the intestinal tract and on the surface of insects), chemicalhazards (when the substrate on which insects are reared is contaminated),and allergenicity of insect proteins. And even though some scientificuncertainties were highlighted, five years later no new hazards have beenlinked to insect consumption. However, it is questionable whether there is adifference in risks from consuming whole insects or isolates from insects. Ingeneral, the microbiological and chemical hazards can be controlled byhygienic production, regardless of consumption of the whole animal or itsuse as a food ingredient isolated from the animal. This only changes wherethe consumption concerns an extract that is concentrated, as this wouldnaturally also increase the exposure to potential hazardous substances. Soscientifically speaking, the extended scope of the 2015 Novel FoodRegulation is reasonable, as there is no obvious difference between the risksof whole or isolated insect foods.However, the concerns regarding the whole insect consumption should havebeen explicitly addressed in unambiguous regulatory measures. Conversely,by strictly (over-)interpreting the scope instead of actually taking regulatorymeasures on a national or EU-level, time was lost on the road to alternativeproteins. The 2015 EFSA Opinion stipulates that a lack of information on howthe animals will be farmed and which forms of preparation and consumptionwill be proposed significantly influence the risks. Often the concrete scientificrequirements for authorising a food can only be shaped with actualauthorisation applications reaching the EFSA. Had the legal status beenclarified earlier, then the application of the industry might have alreadyclarified some of these data gaps. It should also be mentioned that theindustry is not opposed to regulation: the relevant industry association IPFFactually provides recommendations on hygiene rules and welcomed the2015 Novel Food Regulation as providing harmonised rules. Currently it iscrunch time for insect regulation, as the first EFSA Opinions on submittedNovel Foods applications are anticipated to be released soon, this will alsoshed more light on the potential different risk profiles of insect productsdepending on species and forms of consumption. Dr Sabrina Röttger-Wirtz is an Assistant Professor of EU Law at the05.10.20, 13)24Op-Ed: "The limits of legal metamorphosis – the Novel Food Status o…cts” by Dr Sabrina Röttger-Wirtz and Dr Alie de Boer - EU Law LivePage 5 of 6https://eulawlive.com/op-ed-the-limits-of-legal-metamorphosis-the-no…-status-of-insects-by-dr-sabrina-rottger-wirtz-and-dr-alie-de-boer/Maastricht Centre for European Law (Maastricht University), working on EUrisk regulation in the fields of pharmaceuticals, foods and pesticides. Dr Alie de Boer is Assistant Professor Nutrition & Food Law at MaastrichtUniversity, where she studies the use of scientific evidence in legislativeprocedures for food safety (such as novel foods) and health effects. Togetherthey recently published the article ‘Personalised Nutrition: The EU’sFragmented Legal Landscape and the Overlooked Implications of EU FoodLaw’ in the European Journal of Risk Regulation(https:/doi.org/10.1017/err.2020.79).  05.10.20, 13)24Op-Ed: "The limits of legal metamorphosis – the Novel Food Status o…cts” by Dr Sabrina Röttger-Wirtz and Dr Alie de Boer - EU Law LivePage 6 of 6https://eulawlive.com/op-ed-the-limits-of-legal-metamorphosis-the-no…-status-of-insects-by-dr-sabrina-rottger-wirtz-and-dr-alie-de-boer/COPYRIGHT - EU LAW LIVE © · ALL RIGHTS RESERVED - PRIVACY POLICY - COOKIE POLICY - TERMS OF USE - ABOUT EU LAWLIVE - ISSN: 2695-9585INSTITUTIONALLAWHUMANRIGHTSINTERNALMARKETEXTERNALRELATIONS& TRADECOMPETITION& STATEAIDEMPLOYMENT&IMMIGRATIONTAXJUSTICE &LITIGATIONBANKING& FINANCECONSUMER,HEALTH &ENVIRONMENTDATA,TECH & IPAreas ofPracticeNEWSANALYSESOP-EDSINSIGHTEDITORIALCOMMENTSDailyContentEventsLibraryWEEKENDEDITIONNº31 OCT2020WEEKENDEDITIONNº30 SEP2020WEEKENDEDITIONNº29 SEP2020VIEW ALLABOUTUSSUBSCRIPTIONSGET INTOUCHSETTINGSWeekendEditionEULawLiveFOLLOW US ON SOCIAL MEDIA# "FREE DOWNLOAD: “DESPITE OURDIFFERENCES” – THE BOOK I HAVE READ AND ACCEPT THEPRIVACY POLICYDownload nowI'm not a robotreCAPTCHAPrivacyType your name ...Type your mail ...

The limits of legal metamorphosis – the Novel Food Status of insects

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   The limits of legal metamorphosis – the Novel FoodStatus of insectsCitation for published version (APA):Röttger-Wirtz, S. (Author), & de Boer, A. (Author). (2020). The limits of legal metamorphosis – the NovelFood Status of insects. Web publication/site, EU Law Live. https://eulawlive.com/op-ed-the-limits-of-legal-metamorphosis-the-novel-food-status-of-insects-by-dr-sabrina-rottger-wirtz-and-dr-alie-de-boer/Document status and date:Published: 05/10/2020Document Version:Publisher's PDF, also known as Version of recordPlease check the document version of this publication:• A submitted manuscript is the version of the article upon submission and before peer-review. There canbe important differences between the submitted version and the official published version of record.People interested in the research are advised to contact the author for the final version of the publication,or visit the DOI to the publisher's website.• The final author version and the galley proof are versions of the publication after peer review.• The final published version features the final layout of the paper including the volume, issue and pagenumbers.Link to publicationGeneral rightsCopyright and moral rights for the publications made accessible in the public portal are retained by the authors and/or other copyrightowners and it is a condition of accessing publications that users recognise and abide by the legal requirements associated with theserights.• Users may download and print one copy of any publication from the public portal for the purpose of private study or research.• You may not further distribute the material or use it for any profit-making activity or commercial gain• You may freely distribute the URL identifying the publication in the public portal.If the publication is distributed under the terms of Article 25fa of the Dutch Copyright Act, indicated by the “Taverne” license above,please follow below link for the End User Agreement:www.umlib.nl/taverne-licenseTake down policyIf you believe that this document breaches copyright please contact us at:repository@maastrichtuniversity.nlproviding details and we will investigate your claim.Download date: 07 Jan. 202105.10.20, 13)24Op-Ed: "The limits of legal metamorphosis – the Novel Food Status o…cts” by Dr Sabrina Röttger-Wirtz and Dr Alie de Boer - EU Law LivePage 1 of 6https://eulawlive.com/op-ed-the-limits-of-legal-metamorphosis-the-no…-status-of-insects-by-dr-sabrina-rottger-wirtz-and-dr-alie-de-boer/OCTOBER 052020 LOGIN ADVANCED SEARCHDAILY CONTENT AREAS OF PRACTICE MORNING AGENDA LIBRARYEVENTS WEEKEND EDITION EU LAW LIVE PODCAST SHARE5TH OCTOBER 2020 CONSUMER, HEALTH & ENVIRONMENTOp-Ed: “The limits of legalmetamorphosis – the Novel FoodStatus of insects” by Dr SabrinaRöttger-Wirtz and Dr Alie de BoerMetamorphosis – an abrupt striking change in form, structure or substance –is generally a phenomenon witnessed in biology or common motif in prose.However, as the Entoma case shows, law also encounters this phenomenon: the novel food status of insects was subject to a potential metamorphosisunder the – by now replaced – Novel Food Regulation 258/97. The Court ofJustice had to examine how far legal interpretation can stretch, before itamounts to completely transforming (and essentially rewriting) a legislativeprovision.In 1997, very much in the wake of the BSE crisis, food safety was high on theagenda in EU Law. It was also a time of radical scientific and technologicaladvancement with the rise of nanotechnologies, cloning and geneticmodification. Against this backdrop the 1997 Novel Food Regulation wasadopted to ensure the safety of all foods, while only introducing a pre-marketprocedure for those products that were significantly changed.# "05.10.20, 13)24Op-Ed: "The limits of legal metamorphosis – the Novel Food Status o…cts” by Dr Sabrina Röttger-Wirtz and Dr Alie de Boer - EU Law LivePage 2 of 6https://eulawlive.com/op-ed-the-limits-of-legal-metamorphosis-the-no…-status-of-insects-by-dr-sabrina-rottger-wirtz-and-dr-alie-de-boer/What was apparently not on the table when drafting the food legislation wasthe consumption of insects in the average European’s diet outside of TVshow challenges. However, in the search for alternative protein sources andthe integration of more exotic foods in European diets, insects slowly crawledon the European market. However, the Member States adopted diverging anddisputed interpretations of the Novel Food Regulation, and some classifiedwhole insects as novel foods, which made their marketing illegal beforehaving obtained a marketing authorisation. Other Member States believedthat whole insects were not considered novel under the Regulation.Ultimately, the seller of whole insects – Entoma – took legal action against aFrench order to withdraw its products from the market due to a lack ofauthorisation. This led to the Entoma preliminary ruling discussed here, inwhich the Court of Justice was asked to settle questions on whether insectsare novel foods under the 1997 Regulation or not.The Novel Food Regulation 258/97 defined novel foods on the basis of a twocumulative criteria: (i) the lack of a significant degree of human consumptionof food and food ingredients in the EU before the Regulation entered intoforce (15 of May 1997) and (ii) if it falls into one of the six categories of foodslisted in Article 1. The relevant category in question was: ‘(e) foods and foodingredients consisting of or isolated from plants and food ingredientsisolated from animals, except for foods and food ingredients obtained bytraditional propagating or breeding practices and having a history of safefood use’.For context, it should be said that Novel Food Regulation 258/97 wasreplaced by the new Novel Food Regulation 2015/2283 which was adopteddue to the need to revise, clarify and update the legal framework. In the newNovel Food Regulation the fact that whole insects are covered by the novelfood definition is absolutely clear, as the relevant category now reads ‘(v)food consisting of, isolated from, or produced from animal or their parts (…)’and Recital 8 confirms that whole insects and their parts are covered by theRegulation.However, the Court of Justice – and the Advocate General – had to disregardthe recent clarification and only examine the scope as applicable at the time.The Opinion of AG Bobek is a textbook-worthy (and highly entertaining)exercise in applying different legal interpretation methods. AG Bobek by nowcertainly is an expert in the judicial interpretation of EU food law in the faceof changing circumstances, given that he also carried out a similar exercise incase C-528/16, arguing that the new gene-editing techniques are notcovered by the GMO Deliberate Release Directive (although the Court did notfollow his interpretation). In Entoma, AG Bobek concludes that neither a05.10.20, 13)24Op-Ed: "The limits of legal metamorphosis – the Novel Food Status o…cts” by Dr Sabrina Röttger-Wirtz and Dr Alie de Boer - EU Law LivePage 3 of 6https://eulawlive.com/op-ed-the-limits-of-legal-metamorphosis-the-no…-status-of-insects-by-dr-sabrina-rottger-wirtz-and-dr-alie-de-boer/textual interpretation, nor systematic or historical interpretation would bringwhole insects into the remit of the provision ‘food ingredients isolated fromanimals’. France also argued for a teleological expansion of the scope of theregulation – based on the idea that if isolates from insects are regulated dueto their risk to human health, then whole insects should be too as theypresent the same or an even greater risk. This dynamic interpretation of theprovision in question was outright denied by AG Bobek – he called it aeuphemism for legislating via ‘ex post interpretative readjustments’, andmade clear that an ‘interpretation cannot be contra legem’.In its judgment, leaning on the Opinion of the AG, the Court also engaged in aliteral interpretation of the provision. It examined the usual meaning of thewords and came to the conclusion that ingredients are not consumed bythemselves but added substances to create food, and that ‘isolated from’refers to an extraction process which excludes the whole animal from itsscope. According to the Court this also holds true when examining thecontext and objectives of the Regulation. Thus, the Court concluded thatwhole insects were not covered by the 1997 Novel Food Regulation. Thisfinding not only has historical value under the 1997 Novel Foods Regulation,but also means that whole insects can benefit from the transitional provisionintroduced in Article 35(2) of Regulation 2015/2283, which allows producersthat marketed insects before 1 January 2018 to keep them on the marketuntil a decision is taken on their authorisation requests that needed to besubmitted until 2 January 2020.What is the moral of this denied metamorphosis story? An often-repeatednarrative is the EU’s cautious regulation of novel products and its allegednegative effects on innovation. Nevertheless, as the case of insects shows,legal uncertainty can be equally damaging to an industry in the making,especially where high R&D investments are required. The costs of legaluncertainty are even more difficult to bear in an industry mostly composed ofSMEs like the insects-food and feed industry. If Member States wereconcerned about risks to the food and feed use of whole insects, they wouldhave had the means to address the problem without (artificially) extendingthe scope of the Regulation. As noted by the Court and the AG, where theNovel Food Regulation would have been deemed not to cover whole insects,the Member States had been free to adopt national measures to protecthuman health under the regular free movement of goods exception scheme(Articles 34 and 36 TFEU). To this we would like to add that the EU has a verydetailed food safety system in place beyond the Novel Food Regulation,providing rules on chemical and biological safety and response mechanismsto emerging risks (like the safeguard clause in the GFL as well as the RASFF).05.10.20, 13)24Op-Ed: "The limits of legal metamorphosis – the Novel Food Status o…cts” by Dr Sabrina Röttger-Wirtz and Dr Alie de Boer - EU Law LivePage 4 of 6https://eulawlive.com/op-ed-the-limits-of-legal-metamorphosis-the-no…-status-of-insects-by-dr-sabrina-rottger-wirtz-and-dr-alie-de-boer/If some Member States were concerned about the risks of whole insectsbefore, calling for EU harmonisation would also have been an option – as thefollowing revision of the Novel Food Regulation has shown. So what are thepotential health risks of consuming insects? In 2015, EFSA published a firstrisk profile concerning insects for food and feed use, in which it was clarifiedthat the main safety concerns arise from microbiological hazards (due to themicrobiota in the intestinal tract and on the surface of insects), chemicalhazards (when the substrate on which insects are reared is contaminated),and allergenicity of insect proteins. And even though some scientificuncertainties were highlighted, five years later no new hazards have beenlinked to insect consumption. However, it is questionable whether there is adifference in risks from consuming whole insects or isolates from insects. Ingeneral, the microbiological and chemical hazards can be controlled byhygienic production, regardless of consumption of the whole animal or itsuse as a food ingredient isolated from the animal. This only changes wherethe consumption concerns an extract that is concentrated, as this wouldnaturally also increase the exposure to potential hazardous substances. Soscientifically speaking, the extended scope of the 2015 Novel FoodRegulation is reasonable, as there is no obvious difference between the risksof whole or isolated insect foods.However, the concerns regarding the whole insect consumption should havebeen explicitly addressed in unambiguous regulatory measures. Conversely,by strictly (over-)interpreting the scope instead of actually taking regulatorymeasures on a national or EU-level, time was lost on the road to alternativeproteins. The 2015 EFSA Opinion stipulates that a lack of information on howthe animals will be farmed and which forms of preparation and consumptionwill be proposed significantly influence the risks. Often the concrete scientificrequirements for authorising a food can only be shaped with actualauthorisation applications reaching the EFSA. Had the legal status beenclarified earlier, then the application of the industry might have alreadyclarified some of these data gaps. It should also be mentioned that theindustry is not opposed to regulation: the relevant industry association IPFFactually provides recommendations on hygiene rules and welcomed the2015 Novel Food Regulation as providing harmonised rules. Currently it iscrunch time for insect regulation, as the first EFSA Opinions on submittedNovel Foods applications are anticipated to be released soon, this will alsoshed more light on the potential different risk profiles of insect productsdepending on species and forms of consumption. Dr Sabrina Röttger-Wirtz is an Assistant Professor of EU Law at the05.10.20, 13)24Op-Ed: "The limits of legal metamorphosis – the Novel Food Status o…cts” by Dr Sabrina Röttger-Wirtz and Dr Alie de Boer - EU Law LivePage 5 of 6https://eulawlive.com/op-ed-the-limits-of-legal-metamorphosis-the-no…-status-of-insects-by-dr-sabrina-rottger-wirtz-and-dr-alie-de-boer/Maastricht Centre for European Law (Maastricht University), working on EUrisk regulation in the fields of pharmaceuticals, foods and pesticides. Dr Alie de Boer is Assistant Professor Nutrition & Food Law at MaastrichtUniversity, where she studies the use of scientific evidence in legislativeprocedures for food safety (such as novel foods) and health effects. Togetherthey recently published the article ‘Personalised Nutrition: The EU’sFragmented Legal Landscape and the Overlooked Implications of EU FoodLaw’ in the European Journal of Risk Regulation(https:/doi.org/10.1017/err.2020.79).  05.10.20, 13)24Op-Ed: "The limits of legal metamorphosis – the Novel Food Status o…cts” by Dr Sabrina Röttger-Wirtz and Dr Alie de Boer - EU Law LivePage 6 of 6https://eulawlive.com/op-ed-the-limits-of-legal-metamorphosis-the-no…-status-of-insects-by-dr-sabrina-rottger-wirtz-and-dr-alie-de-boer/COPYRIGHT - EU LAW LIVE © · ALL RIGHTS RESERVED - PRIVACY POLICY - COOKIE POLICY - TERMS OF USE - ABOUT EU LAWLIVE - ISSN: 2695-9585INSTITUTIONALLAWHUMANRIGHTSINTERNALMARKETEXTERNALRELATIONS& TRADECOMPETITION& STATEAIDEMPLOYMENT&IMMIGRATIONTAXJUSTICE &LITIGATIONBANKING& FINANCECONSUMER,HEALTH &ENVIRONMENTDATA,TECH & IPAreas ofPracticeNEWSANALYSESOP-EDSINSIGHTEDITORIALCOMMENTSDailyContentEventsLibraryWEEKENDEDITIONNº31 OCT2020WEEKENDEDITIONNº30 SEP2020WEEKENDEDITIONNº29 SEP2020VIEW ALLABOUTUSSUBSCRIPTIONSGET INTOUCHSETTINGSWeekendEditionEULawLiveFOLLOW US ON SOCIAL MEDIA# "FREE DOWNLOAD: “DESPITE OURDIFFERENCES” – THE BOOK I HAVE READ AND ACCEPT THEPRIVACY POLICYDownload nowI'm not a robotreCAPTCHAPrivacyType your name ...Type your mail ...

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The limits of legal metamorphosis – the Novel Food Status of insects

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