Alternative Proteins Factsheet

Background

The United Nations’ Food and Agriculture Organisation (FAO) estimates that consumption levels in meat will increase by more than 50% by 2050, further exacerbating current trends towards an increase in global meat production and consumption. Yet, animal agriculture represents a major source of externalities on the climate as it generates an estimated 14.5% of all anthropogenic greenhouse gas emissions. For this reason, environmental scientists have identified animal agriculture as a strategic sector to reach global warming reduction targets.

Despite the detrimental effects of massive food consumption levels on the environment and animals, the effectiveness of meat reduction campaigns has, so far, remained limited. Offering consumers a replacement for animal-source products under the form of food alternatives can be a solution to achieve a reduction in the number of farmed animals and to reduce animal agriculture’s footprint on the environment. There exist four types of alternatives proteins, each produced by the following methods:

• Plant-based: Plant-based alternative protein products include whole food plants (e.g., legumes, pulses, wholegrains, nuts) or proteins that can be derived from plants which, once processed, result in products that mimic the taste and texture of conventional animal-sourced proteins, such as textured soy protein, seitan or tofu.

• Fermented: Fermented alternative protein products are derived from the efficient growth of microbial organisms to either produce an entire foodstuff, or to use the organism itself as a food ingredient. As ingredients, fermented food products can be used flavourings, enzymes, proteins and fats in hybrid products.

• Precision fermentation: Precision fermentation is a process where microorganisms are genetically modified to produce and express complex organic components such as proteins. Precision fermentation has historically been used for food producing products such as enzymes, vitamins and amino acids. However, precision fermentation is now gaining a huge amount of attention as a way to produce animal proteins, fats and other alternatives.

• Recombinant: Recombinant proteins utilise a host organism, such as a microorganism or plant through precision fermentation or molecular farming, that has been genetically modified to produce complex organic components, such as proteins, that perform specific functions. Precision fermentation has historically been used for food producing products such as enzymes, vitamins and amino acids, including rennet for cheese-making and even insulin to treat diabetes. However, recombinant technologies are now gaining a huge amount of attention as a way to produce animal proteins, fats and other alternatives.

• Cultivated (also called “cultured” or “cell-based”): Cultivated products are food products derived from the cultivation of animal cells. This production method typically uses a bioreactor (or “cultivator”) to enable cell growth and production of tissue that replicates the structure of different cuts of meat or other animal proteins.

These types of alternatives proteins are often considered as “novel foods” in the legislation of certain jurisdictions. A novel food is usually defined as a type of food that does not have a significant history of consumption and whose safety for consumers require a pre-market safety assessment and authorisation before being placed on the market. Not all alternative proteins are classified as novel foods; for instance, certain plant-based products derived from beans and peas are not novel foods, but the definition depends on the manufacturing processes applied and the composition of the final ingredients. Similarly, novel foods are not composed only of alternative proteins; for instance, in some jurisdictions, chia seeds are considered a novel food.

Key Considerations

When evaluating, drafting or comparing laws and policies, local context, political feasibility and the regulatory environment all influence what one considers “Better Practice.” With that caveat in mind, when all else is equal, the following considerations indicate better and worse practices for laws and policies.

1. Naming

The naming of a product indicates the nature and use of a food product to consumers and should be sufficient to ensure that the consumer is not misled and can make an informed decision about what they eat. Considering that alternative proteins aim to substitute conventional animal products, it is thus essential that regulations allow alternative protein producers to properly convey their products’ intended purpose, and how consumers can use them.

To that effect, the legislation should provide non-restrictive rules on the terminology, so there is a level-playing field with animal-based products, especially for cultivated products as they could have the same chemical composition as conventional meat. Therefore, adequate restrictions should apply to the name, package, or visuals in marketing materials. The restrictions in place in certain jurisdictions, such as the EU, and which prohibit the use of certain terms, such as “milk” are examples of a restrictive regulatory framework.

An example of a positive rule is the US FDA draft rule approving the use of certain dairy terms for non- conventional dairy products.

Furthermore, naming rules should require manufacturers of both conventional and alternative protein products to disclose the method of production, to ensure transparency to consumers and enable them to make conscious purchasing choices.

The Australian Alternative Proteins Council’s Guidelines for Labelling is an example of good practice method-of-production labelling rules to the extent that such guidelines are based on a consensus across each alternative protein type.

2. Pathway to Market

Food manufacturers should benefit from a clear regulatory pathway to market to commercialize their products in a given jurisdiction, both in terms of the data food companies should provide and the timeline of the application.

The US and Singapore are positive examples of jurisdictions with clear regulatory frameworks, in a way that manufacturers know what to expect once they apply for an authorization to market their products. Furthermore, both the US and Singapore novel food regulatory framework provide predictable and reasonable timelines. The US FDA also offers pre-submission consultations with applicants.

On the other hand, certain jurisdictions do not provide clear guidance on what companies should provide in terms of data requirements to commercialize their products; which creates uncertainty because they fail to properly define the scope of what qualifies as a novel food under the regulation – it sometimes is the case for algae, mycoprotein, which can be used as ingredients for alternative proteins. Furthermore, other legislation, such as EU and UK law, do not provide transparent information on the progress of the application process, and the timelines in legislation are often exceeded in reality

3. Education to Consumers Policy

To support the undertaking of alternative proteins in the general population, governments’ official nutritional guidelines should include alternative proteins as a source of proteins alongside traditional animal-based proteins.

Alternative proteins should be included in and presented in a positive light in nutritional guidelines, and any materials for public education, including in schools to increase awareness of the option and how they can be used. For that reason, the labelling and classification of alternaitve proteins in the food nomenclature is crucial. For example, naming cultivated meat “lab-grown,” “synthetic,” or in vitro meat will have a negative effect on consumer trust and acceptance.

The consumption of alternative proteins should also be promoted in health policies, especially those policies aiming to shift consumption levels away from meat and towards more plant-based diets, with potential sustainability benefits. Furthrermore, then a rich and varied plant-based diet can offer prevention and treatment of a host of modern lifestyle diseases. Compared to processed animal-based products, plant-based products also offer a healthier option to consumers in terms of saturated fat, cholesterol, fibre, and a range of other nutrients.

At the moment though, national nutritional guidelines tend to only include unprocessed food and vegetables among plant-based options.

4. Research and Development

A 2021 report funded by the UK government found that $10 billion of global public spending should be invested each year to realise the many benefits of alternative proteins. Public funding could come by way of reformed agricultural subsidies, and more specifically by including provisions to enable a just transition for food producers in new policies. Public funding should also support the research and development of new alternative proteins. Currently, the level of private funding supporting the development of alternative proteins greatly outweighs public funding. Private investments in alternative and plant-based proteins reached a record level of almost $5 billion last year. However, the rate of private investment is slowing, and so public investment is now necessary to accelerate the development of alternative proteins, but also to open access to the research. Countries like Canada, the Netherlands the US, and Singapore have respectfully invested more tens to hundreds of thousand dollars in support of the development of alternative proteins.

5. Taxation and Public Procurement Policies

Governments do not tax all food products at the same rate. To ensure fair competition between alternative protein and conventional animal-source product manufacturers, governments should adopt consistent taxation policies, including on the VAT rate. More generally, taxation policies along the food production chain should enable price parity with animal-based products as a way to ensure consumer accessibility.

Considering the potential of public procurement policies in achieving sustainable production and consumption habits, governments should further include alternative proteins into their public procurement policies, so that alternative protein products are accessible to users of public services, such as in State schools, hospitals, or prisons.

6. Food and Protein Strategies

Lastly, governments should undertake policy actions to initiate a reduction in animal-source food production and consumption, and to increase alternative protein availability and uptake. An example of a positive Protein Strategy in that regard in the Dutch Protein Strategy. Similar objectives should also be included in environmental, climate, and land use policies, considering the externalities of conventional animal agriculture on the environment.

References

References

FAO, The Future of Food and Agriculture – Alternative Pathways To 2050 (2018), available online. Our World in Data, Global Meat Consumption, World, 1961 to 2050, available online. FAO, Tackling Climate Through Livestock (2018), available online. FAIRR, Climate Transition Proteins: Flavour of the Future (2022) Global Innovation Needs Assessments, Protein Diversity (2021), available online.

Further Readings

Alternative Proteins Association, Regulation of Cultivated Meat & Recombinant Proteins in the United Kingdom: Recommendations for Ensuring Safety and Embracing Innovation (2022).

Atova Consulting, The Status of Alternative Protein Approvals in the EU, Singapore, UK & the USA (2022).