The application of Regulation (EU) 2015/2283, on the subject of novel food, continues to expose operators to serious uncertainties. With all due respect to the free movement of goods in the internal market. The case of the microalgae of the family Chlorella.
Chlorella, uses and perspectives
Microalgae Chlorella pyrenoidosa, chlorella vulgaris e Chlorella luteoviridis they are traditionally used in Europe in the production of food and food supplements. The three species are in fact listed in the catalog of novel food held by the European Commission as traditional foods. (1) And precisely because proof of their widespread and safe food consumption was collected before 15.5.97, the application of the regulation on novel foods to these species is excluded (EC reg. 258/97, repealed and replaced by . EU 2015/2283). (2)
The use of microalgae of the family Chlorella, as seenhas also been successfully tested in the bio-decontamination of water and wastewater from organic compounds and pesticide residues. The prospects for their use in environmental remediation and agriculture are therefore also promising. As economic and natural alternatives - as well as compatible with organic farming - to other treatments and substances of chemical synthesis.
chlorella vulgaris e Chlorella protothecoides, historical confusion
Periodic updates of the taxonomy, over the years, have led to the revision of the name of Chlorella luteoviridis, renamed Heterochlorella luteoviridis. Most importantly, the review of analyzes on algal culture collections showed repeated confusion in identifying how chlorella vulgaris some strains of Chlorella pyrenoidosa. This analysis, supported by several scientific studies, suggests that Chlorella pyrenoidosa it may have been consumed as a food ingredient in Europe before 1997.
The CEVA (Center d'Études & de Valorisation des Algues) - in your relationship 'Macroalgues et microalgues alimentaires - Statut règlementaire en France et en Europe, Synthèse CEVA 2019', updated on 19.3.20 - actually recognizes the traditional use of Chlorella pyrenoidosa in the production of food and food supplements (3,4). Given its historical 'incorrect classification' (or confusion) with chlorella vulgaris.
Chlorella protothecoides, uncertainty of status in the internal market
The European Commission, in recent months, has collected evidence of the findings of CEVA. Following an interlocution with the French government, which had forwarded its report to Unit E2- Food processing technologies and novel foods of DG Sante. Nonetheless, Brussels officials have to date refrained from updating the European register of novel food, confirming it status of traditional food of the species in question.
This uncertainty - like others, which we have several times reported, on derivatives of Cannabis Sativa L. - causes a serious obstacle to the free movement of goods in the internal market. In fact, operators, in the absence of a uniform application of the regulation on novel food, are forced to face administrative burdens and risks of disputes whenever they intend to put a food into circulation in the various member countries.
Internal market, SMEs and obstacles to innovation
Legal uncertainty it is the first and most serious obstacle to food innovation. And it causes unacceptable distortions of competition to the detriment of SMEs and micro-enterprises, which represent over 90% of operators in the European Union and generally lack the economic resources to deal with costly regulatory consultancy in the various Member States.
Food innovation, research and development are, among other things, focused on ingredients with peculiar and valuable characteristics from a nutritional point of view. Like the microalgae , hemp, both of which are valuable sources of proteins and essential amino acids, Omega 3 fatty acids and various phytocompounds.
(1) European Commission. Novel Food catalog
(2) European Commission. 'Human Consumption to a Significant Degree'. Information and Guidance Document. https://ec.europa.eu/food/sites/food/files/safety/docs/novel-food_guidance_human-consumption_en.pdf
(3) CEVA. Macroalgues et microalgues alimentaires - Statut règlementaire en France et en Europe, Synthèse CEVA 2019. 19.3.20 update
(4) CEVA also considers the traditional use in the EU of Chlorella sorokiniana e Parachlorella kesleri. Further uncertainties