What is a Food and Feed Marketing Notice?
A Food and Feed Marketing Notice is a notice which can be submitted to the Food Standards Authority (FSA) following receipt of a 'Precision Bred Confirmation' for a Precision Bred Plant (PBP) from the Department for Environment, Food and Rural Affairs (DEFRA), in response to an earlier Marketing Notice. A successful Food and Feed Marketing Notice will gain Food and Feed Marketing Authorisation from the FSA, allowing the marketer to market their PBP for use as food and/or feed in England.
A Food and Feed Marketing Notice requires:
Proof of a Precision Bred Confirmation in respect of an earlier Marketing Notice for the same PBP
Proof the PBP is of a species with a history of safe food use
Proof the genetic changes introduced will not significantly alter nutritional quality of the PBP in a way disadvantageous to the consumer
Proof the genetic changes introduced will not significantly increase PBP toxixity
Proof the genetic changes introduced will not alter allergenicity of the PBP
Proof the genetic changes introduced will not introduce changes that might affect safety of food or feed resulting from the PBP.
Scientific evidence to demonstrate the above, in the form of, but not limited to, scientific articles, review articles, results from scientific experiments etc.
Details of the applicant
If the applicant is not based in GB, details of an appointed GB based representative
Safety assessments as described below:
Alongside the above, the FSA has implemented a tiered safety assessment system based on history of safe food consumption for the species, and novelty of genes introduced in the PBP to the food and/or feed market.
Tier 1 applications refer to 'low risk' PBP varieties, with similar features to traditionally bred crops, already in the food and feed market. To qualify for Tier 1, a PBP must have no new safety concerns relating to allergenicity, toxicity etc.
Tier 2 applications refer to 'higher risk' PBP varieties, including those with unusual genetic features, or species not currently commonly used for food or feed purposes. Tier 2 applications will be subjected to a bespoke review process by the regulator, and will require additional scientific studies in the dossier, evidencing safety and managing risk. PBPs of altered nutritional quality will also fall into Tier 2, alongside those with potential changes to allergenicity or toxicity.
Note: This post provides a highly simplified view of an incredibly complicated topic for educational purposes. There's a lot more to Food and Feed Marketing Notices that simply won't fit on one post!
At Crop Genetics Regulatory Consulting we can help you get to grips with drafting your Food and Feed Marketing Notice scientific dossier, and submitting it to the regulator, saving you time, and allowing you to focus on novel innovation! We can also act as a GB based representative for overseas applicants.