Understanding the FDA's Stance on Edible Insects
The U.S. Food and Drug Administration (FDA) does not issue a formal "approval" for whole foods like fruits, vegetables, or crickets. Instead, it regulates them under the Federal Food, Drug, and Cosmetic Act (FD&C Act) as "food," provided they are intended for human consumption. This means crickets are treated similarly to other food products, not as drugs or novel substances requiring a unique authorization process.
Crickets raised specifically for food must adhere to strict safety standards, notably the Current Good Manufacturing Practices (cGMPs) and the Food Safety Modernization Act (FSMA) Preventive Controls for Human Food rule. This regulatory framework ensures that crickets are raised in sanitary conditions, processed safely, and properly labeled.
The Critical Distinction: Food vs. Food Additive
A key regulatory point is whether the cricket product is considered a whole food or a food additive. Whole, raw agricultural commodities (RACs) are treated differently than processed ingredients.
- Whole Crickets: If marketed as a whole food, they fall under the general definition of "food."
- Cricket Powder/Flour: When crickets are processed (e.g., ground into powder for protein bars), they are often considered food ingredients, which might be classified as "food additives" unless they are Generally Recognized As Safe (GRAS).
Companies often conduct self-GRAS determinations to ensure their cricket products are safe for their intended use. The FDA can, but has not typically, issued specific GRAS notices for cricket products, allowing the industry to grow under this existing regulatory structure.
Food Safety and Compliance Requirements
For companies producing cricket-based foods, several critical compliance areas must be addressed:
- Sanitation: Facilities must maintain sanitary conditions to prevent contamination.
- Allergen Labeling: Although not one of the "Big 8" allergens, crickets are arthropods, similar to shellfish (like shrimp and lobsters). It is industry best practice to include allergen warnings for individuals with shellfish allergies.
- Preventive Controls: Producers must identify potential hazards (biological, chemical, physical) and implement preventive controls under FSMA.
- Labeling: Products must be clearly and accurately labeled, listing "crickets" or "cricket powder" in the ingredient list.
Comparison: Crickets (Intended Food) vs. Insect Filth
It is important to differentiate between crickets raised intentionally for food and insects that are unintended contaminants (often referred to as "filth" by the FDA's Food Defect Levels Handbook). The FDA permits minute, unavoidable levels of insect parts in common foods (e.g., chocolate or flour) because it is impossible to remove all traces.
However, this has no bearing on crickets produced in cGMP-compliant facilities.
| Feature | Intentionally Raised Crickets (Edible) | Unintended Insect Parts (Filth) |
|---|---|---|
| Regulatory Status | Food/Food Ingredient (under FD&C Act) | Adulterant (under Food Defect Action Levels) |
| Production Environment | cGMP-compliant facilities | Unsanitary conditions or unavoidable field contamination |
| Safety Determination | GRAS (self-determined or FDA-reviewed) | Not considered safe; maximum limits set |
| Labeling | Must be listed as an ingredient (e.g., "Cricket Powder") | Not listed; presence is unintended |
Conclusion
Crickets are not subject to a specific, unique "FDA approval" certificate like new drugs or novel food additives that lack a history of safe use. Instead, they are recognized and regulated as a legitimate food source under the existing Federal Food, Drug, and Cosmetic Act when produced in facilities adhering to Current Good Manufacturing Practices and other modern food safety regulations. Companies manufacturing cricket-based products must ensure the safety of their products, often by undertaking a Generally Recognized as Safe (GRAS) determination, to legally market them in the United States. While regulatory guidance specific to edible insects is limited, the existing framework provides a pathway for compliance. More information on general food safety regulations is available directly from the U.S. Food and Drug Administration.
