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Are plant protein hydrolysates novel foods in the EU?
Beyond Biopharma | Plant Protein Peptide FAQ
Short answer: It depends. Under Regulation (EU) 2015/2283 a food is novel if it was not used for human consumption to a significant degree within the Union before 15 May 1997. Hydrolysates from plant sources that have a long food history may be treated differently from those from sources with little or no history in the Union, so the status of each plant peptide has to be confirmed item by item before import.
What the regulation actually says
Regulation (EU) 2015/2283 replaced the earlier novel food framework and set the current definition and procedures. A food is novel if it was not used for human consumption to a significant degree within the Union before 15 May 1997. Novel foods need authorization before they can be placed on the market, and authorized ones are added to the Union list with the conditions of use. The regulation also provides a consultation route for foods whose status is genuinely unclear, and the Commission maintains a catalogue that records the status of many specific foods and ingredients.
Why plant peptides are not all in the same position
Two variables decide the answer. The first is the source. A protein from a plant that has been eaten widely in Europe for decades is in a different position from a protein from a plant that has little or no history of food use in the Union, whatever its status elsewhere in the world. The second is the process. Hydrolysis is not automatically an irrelevant step: where the process is new, or where it changes the composition or structure of the food in a way that was not used before 1997, the resulting ingredient can be treated as novel even if the starting material clearly is not. That is why producers and importers are expected to describe the source and the process together, not just the raw material.
How to check the status in practice
| Question | What to check |
|---|---|
| What exactly is the ingredient? | Plant source, part used, hydrolysis process, specification and intended use level |
| Is there a pre-1997 history in the Union? | Documented significant use of the same food as such, with evidence rather than assumption |
| Is it already listed? | The Union list of authorized novel foods and the Commission novel food catalogue |
| Still unclear? | Consultation with the competent authority in the member state where the product will be sold |
What importers and brands should do
- Do not assume that a plant peptide is traditional just because the plant is a familiar food, or that it is novel just because the process is modern; check each case on its own facts.
- Collect the source and process description, the specification and the intended use from the supplier before commercial discussions go far.
- Confirm the position for every market separately, because the EU assessment says nothing about the United States, the United Kingdom or other regions.
- Keep the evidence and the conclusion in the product file, so that a query from an authority can be answered from documents.
- Take advice from a regulatory specialist or the relevant competent authority when the answer is not clear, and treat current regulation as the reference since procedures and listings change.
Related reading
For more detail, see the use of plant hydrolysates in pet food and aquafeed, plant peptides in cosmetics and topical products and how bitterness in plant peptides is prevented.
