Singapore Clarifies the Requirements to Export Insects for Food Consumption

On July 8, 2024, the Singapore Food Agency (SFA) released guidelines[1] pertaining to the import of insects and insect products for food consumption. This marks another significant step made by the Singapore government to build up a regulatory environment promoting diverse food sources and ensuring food security, given that edible insects have been known as a new alternative protein source.    
 
The guidelines provide a list of insects deemed safe for human consumption, e.g., house cricket, silkworm, and European honeybee, etc., by their order, common name, life stage(s) permitted, as well as species name. Industry may export these listed insects to Singapore for food use without obtaining additional product approvals from SFA. However, the requirements for exporting insects set forth in the guidelines must be met, which include registration of the importer with SFA, pre-registration of the overseas insect processing establishment, and application for a cargo clearance permit. A health certificate for every consignment is also required by SFA. The pre-registration of the overseas insect processing establishment is to be completed online via QR code by submitting supporting documents such as a proper food safety management system or Hazard Analysis Critical Control (HACCP) plan at the facility. It is unclear whether SFA may visit the overseas facility to conduct the on-site inspection.  
 
For insects for food use but not listed in the guidelines, one must first submit an evaluation to SFA for review and approval. The required information for evaluation of new insect species includes the scientific name of the insect and intended life stage(s) that are meant for human consumption, details of the farming and/or processing method, evidence of history of use as a human food in a country other than Singapore, etc. The evaluation will be carried out in accordance with the existing novel food framework in Singapore. 
 
With regard to labeling requirements, SFA instructed[2] that companies selling pre-packaged food, including those containing insects as an ingredient, are required to label the product packaging to indicate the true nature of the product. However, so far, no specific name or product description is expressly recommended by SFA. Companies should determine an appropriate product name for the food based on the general food labeling requirements in Singapore.  
 
We also should note that other than insects for food consumption, in the guidelines, SFA has specified the requirements for the import of insects and insect products used as animal feed for food-producing animals, as well as the import of live insects for local farming (for human consumption). Industry may find more details in the guidelines if such applications are of interest.[3] 
 
Keller and Heckman assists companies in regulatory matters involving alternative proteins (e.g., cultured meat, non-animal protein made via precision fermentation), including submissions to clear products with the food authorities such as SFA and other markets around the world. If you need any assistance or have any questions about the application process or data requirements, please do not hesitate to contact David Ettinger (ettinger@khlaw.com), Jenny Xin Li (li@khlaw.com), or your existing contact at Keller and Heckman LLP. Please sign up for our newsletters here to keep up with the most recent updates in this space. 

[1] https://www.sfa.gov.sg/docs/default-source/circulars/2024/trade-circular-on-import-of-insects.pdf?sfvrsn=3bdccb94_1 

[2] https://www.sfa.gov.sg/food-information/insect-regulatory-framework/

[3] https://www.sfa.gov.sg/food-information/insect-regulatory-framework/local-production-of-insects-for-food-and-for-animal-feed-for-food-producing-animals