Flour from insects and whole insects in human food in Europe

In 2023, AIMSIB issued a warning about flour insect in human food^[1]. The article highlighted the toxicity of these products for humans, particularly for people suffering from allergies.

Things are now becoming clearer: according to BFMTV ^[2], from 10 February 2025, mealworm larvae powder (Tenebrio molitor) treated with ultraviolet light will be considered as food. In other words, it can be incorporated into “a certain number of food products” such as bread, cheese, pasta and cakes. In this way, the European Union hopes to reduce meat consumption by offering alternatives to meat products.

According to UFC Que Choisir^[3], four of these insects are currently authorised for consumption:

Yellow mealworm (larva of theTenebrio molitorbeetle )dried in May 2021 (authorisation granted exclusively to the French company Agronutris for a period of 5 years), then frozen or powdered in February 2022.
Migratory locusts (Locusta migratoria), whole or without wings or legs, frozen, dried or powdered, in November 2021 (authorisation granted to the Dutch company Fair Insects/Protix).
Frozen, dried or powdered domestic crickets (Acheta domesticus) in February 2022 (also for Fair Insects/Protix).
Domestic cricket (Acheta domesticus) powder has been partially defatted since 24 January 2023 (authorisation granted to the Vietnamese company Cricket One).
Labelling is compulsory: it must appear in the list of ingredients on the product packaging. Consumers should be particularly aware that it is a potential allergen for people sensitive to shellfish and dust mites. Labelling the composition of ingredients is strictly governed by the 2011 European regulation on consumer information for foodstuffs, known as ” INCO ” ( 1). Atthe same time, insects are subject to the European Novel FoodRegulation of 2015 ( 2).
(1)Regulation (EU) No. 1169/2011, known as ” INCO “, published in the OJEU on 22 November 2011.
(2)Regulation (EU) No 2015/2283, published in the OJEU on 25 November 2015.

As I understand it, 3 insects are authorised ^[4] fully and only one is authorised in the form of flour in foodproducts:

Bread and Rolls (4g of larvae per 100g of product)

cakes (4g of larvae per 100g of product)
pasta-basedproducts (3.5g of larvae per 100g of product)
processed potato products (3g of larvae per 100g of product)
cheese and cheese-based products (1g of larvae per 100g of product)

vegetable purée (3.5g of larvae per 100g of product)
However, I read here^{^[5]} that mealworms (Tenebrio molitor) are authorised for human consumption as whole dried insects in snack form or as an ingredient, particularly in powder form.

And I discover here^[6] that another powdered insect can be used: Alphitobius diaperinus

” Since 5 January 2023, larvae of the small dwarf beetle^{^[7]} – Alphitobius diaperinus – a beetle known to devour insulation panels may also be used, for a period of 5 years, in frozen, freeze-dried, paste or powder form “in a certain number of food products intended for the general population, as well as on the use of its powder form in food supplements” (for more details, see next question). Authorisation has only been granted to the French company Ynsect, which submitted an application to the European Commission. ”

On November 12th in 2021, the European Commission authorised the marketing in the European Union of Locusta migratoria in frozen, dried or powdered form for human consumption, in accordance with the Novel Food EU No 2015/2283 regulation of 2015, which came into force on 1 January 2018. The authorisation concerns the adult insect belonging to the Acrididae family. The marketing concerns food products in the form of snacks or ingredients for another food product. In frozen or dried form, the legs and wings must be removed beforehand by the food manufacturer^{^[8]}. The European Food Safety Authority (EFSA) “concluded that consumption of the insect proteins evaluated may potentially lead to allergic reactions”. This may be the case in particular for people with pre-existing allergies to shellfish, mites and in some cases molluscs. In addition, food allergens (e.g. gluten) may be found in the insect consumed^[9]. ”

Labelling

The European Commission reassures us that we will be informed because these products will be clearly labelled^[10].
But what is the reality?
If the food contains domestic crickets, it must be labelled as follows: “Acheta domesticus (domestic crickets) powder, partially defatted”
If the food contains small dwarf darkling beetles, the list of ingredients on the label will tell you as follows: “Alphitobius diaperinus larvae (small dwarf darkling beetle)”: “Alphitobius diaperinus larvae (small damselfly) frozen/paste” or “Alphitobius diaperinus larvae (small damselfly) freeze-dried/powder”, depending on the form used. I haven’t found anything specific about the labelling of foods containing Tenebrio molitor. On the other hand, if these insect meals are used in food eaten in restaurants or bought in bakeries, for example, it will be very complicated, if not impossible, to find out^[¹¹^].

There is also a code for imported food containing insects, the HS Code 04101099 – processed edible insects, which can be used for an import declaration^{^[12]}. Will these imported foods be correctly labelled?

All the regulations are listed here^[13] on a Luxembourg website.