Correction to mealworm regulation as food: what companies must review

Key data

Companies operating in the alternative food, supplements and insect-derived ingredient sector have an urgent task ahead: to verify whether their products containing Tenebrio molitor larvae comply with the corrected text of Commission Implementing Regulation (EU) 2022/169. The correction published on 8 September 2026 in the Official Journal of the EU rectifies errors or omissions in the original regulation, which dates from 9 February 2022.

This is not a new authorization or a fundamental change in novel food policy: it is a technical correction. However, in matters of labeling and conditions of use, any deviation from the current official text can lead to problems with food control authorities.

What does this regulation establish?

The Commission Implementing Regulation (EU) 2022/169 authorized in February 2022 the marketing of Tenebrio molitor larvae—commonly known as mealworms—in three formats as a novel food within the EU:

• Frozen form
• Dried form
• Powder form

This authorization is framed within Regulation (EU) 2015/2283 on novel foods, which regulates the introduction into the European market of foods that did not have a significant consumption history in the EU before May 1997. Additionally, the 2022 regulation amended Commission Implementing Regulation (EU) 2017/2470, which contains the Union list of authorized novel foods.

The correction now published rectifies errors or omissions detected in the original text published in the Official Journal on 9 February 2022. Although the correction does not publicly detail each specific error corrected, its legal effect is clear: the corrected text is the one with legal validity, and companies must comply with it.

Economic and operational impact

The market for insect-derived ingredients is expanding in Europe. Tenebrio molitor larvae are one of the most widely used insect ingredients in human food and animal feed, and their authorization as a novel food opened the door to a product category with high growth potential.

The correction has a direct operational impact in three areas:

• Labeling: If the corrected text modifies denomination conditions, mandatory statements or use restrictions, current packaging may become outdated and require modification.
• Conditions of use: The technical specifications that define which products can incorporate this ingredient, in what doses and under what conditions must be adjusted to the corrected text.
• Technical specifications of the ingredient: The quality, purity or processing parameters listed in the regulation must be reviewed against the corrected text.

The risk of inaction is concrete: non-compliance with the updated conditions may result in sanctions or market withdrawal by food control authorities in the Member States.

Who does it affect?

• Food manufacturers that incorporate Tenebrio molitor larvae (frozen, dried or powder) in their products.
• Distributors and marketers of this ingredient or final products containing it in the EU market.
• Alternative food and insect protein companies with presence in the European market.
• Nutritional supplement manufacturers that use this ingredient.
• Animal feed sector companies operating in adjacent categories with this type of ingredient.
• Quality, regulatory and labeling departments of any food company with this ingredient in its portfolio.

Practical example

A Spanish company that manufactures protein bars with mealworm flour (Tenebrio molitor powder) and markets them in several EU countries currently has its labels and technical datasheets based on the text of Commission Implementing Regulation (EU) 2022/169 published on 9 February 2022.

With the publication of this correction, that company must:

1. Download the corrected text published on 8 September 2026 in the Official Journal of the EU.
2. Compare point by point the conditions of use, technical specifications and labeling statements of the original text with the corrected text.
3. If differences are detected, update its labels, technical datasheets and regulatory documentation before continuing to market the product.

If this review is not carried out and an inspection by the competent food authority detects that its labeling does not comply with the current corrected text, the company is exposed to sanctions or product withdrawal from the market.

What should companies do now?

1. Download the corrected text from the Official Journal of the EU (published on 8 September 2026) and compare it with the original text of Commission Implementing Regulation (EU) 2022/169 (OJ L 28, 9.2.2022).
2. Review the labeling of all products containing Tenebrio molitor larvae in frozen, dried or powder forms to verify compliance with the corrected text.
3. Update internal conditions of use and technical specifications that regulate the use of this ingredient, aligning them with the corrected text.
4. Inform suppliers and customers in the supply chain about the correction, especially if you supply or receive this ingredient with associated technical documentation.
5. Document the review process to be able to prove it in the event of an inspection by the competent food authority.
6. Consult with a regulatory advisor specialized in novel foods if there are doubts about the specific scope of the corrections or their impact on the authorization of use.

Official source

Consult complete regulation at official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202690755