The European association for the promotion of insect foods, IPFF (International Platform of Insects for Food and Fee) has published an extensive guidance document covering the labelling requirements applicable to insect foods.
Note that at present there is no general authorization yet for any insect food or food ingredient under EU law. Currently, several novel food applications for insect foods are still pending with the European Commission. There are however a number of EU Member States which do permit the use of a limited number of insect foods. Belgium for instance allows the use of 10 different types of insects for human consumption (for more information, click the following link [Dutch/French only]).
The Guidance elaborates on the main EU instruments that regulate the labelling of foods in general, the Food Information to Consumers Regulation (Regulation 2011/1169) and the Regulation on the use of Nutrition and Health Claims (Regulation 2006/1924). In case insect foods find novel food authorization, the applicable legal name is likely to be captured in the authorization and the Union List of Novel Foods.
The Guidance includes practical examples to illustrate the application of EU food labelling principles to show for instance what would be considered misleading information or what could constitute an unauthorized health claim.
Two important considerations on the declaration of allergens for insect foods are included in the Guidance. First, potential allergenicity may derive from the feed materials given to insects which are destined for human consumption. When insects eat wheat-based feed, there may be gluten present in the insects. Accordingly, in such case the presence of gluten as an allergen should be labelled. Secondly, insects as such are not considered allergens but there is evidence of links with allergenic reactions to crustaceans. The allergenicity of an insect food does forms part of the novel food assessment, so potentially insect protein may be considered an allergen. As this currently not yet the case, the guidance advises as a precautionary measure to include a statement in the labelling of insect foods which highlights the similarity between the allergenicity of insects and that to crustaceans and dust mites.
IPIFF – Guidance: the provision of food information to consumers - link