EFSA asks for more information on toxicity and allergenicity. Report by Claire Robinson

Impossible Foods' GMO "fake meat" ingredient, soy leghemoglobin (SLH for short), is currently being considered for approval for food use in the EU and the UK.

This summer, the European Food Safety Authority (EFSA) asked the company to provide more information that was clearly missing from its application, including details on possible toxicity and allergenicity.

The company submitted its application to EFSA in September 2019. EFSA recently asked the company to provide the EU's GMO detection lab with additional information on SLH.

If EFSA issues a favourable opinion on SLH, the matter then passes to the EU Member States for a vote. If they vote to approve the GMO, it will be allowed to be used in Impossible Burgers, which Impossible Foods wants to market in the bloc. If, as is virtually always the case with votes on GMOs, no qualified majority is reached, the Commission can approve it unilaterally (but undemocratically) via a process called comitology.

The GMO SLH is the key ingredient that make the fake meat burgers "bleed" a red substance that resembles the blood that oozes from rare beef.

SLH in its natural state exists in the roots of soybeans and has never been a part of the human diet. So it does not have a history of safe use in food. In addition, Impossible Foods’ SLH is derived from a genetically engineered strain of Pichia pastoris yeast. Pichia pastoris, whether GMO or not, also has no history of safe use in food.

Allergenicity and toxicity information requested

In June this year, EFSA asked the company to provide additional information on a number of important aspects of SLH, including compositional analyses, identity of the genetically engineered yeast strain that is used to produce it, and SLH's nutritional value, allergenicity, and toxicity.

It is worrying that Impossible Foods has to be prompted to supply the necessary information, which should form a standard part of any application for a GMO authorisation in the EU.

We don't have the benefit of seeing the precise wording of EFSA's requests, which remain confidential. At first glance it seems that EFSA asking the right questions to form a sound preliminary assessment of the risks to consumers. However, the full risks will not be known until the product has been out there in the marketplace for some time and enough consumers have tried an Impossible Burger.

Anecdotal reports communicated to us informally in the US suggest that some people can suffer toxic or allergic reactions to the Impossible Burger, though we don't have the evidence needed to endorse or refute this possibility. Any consumer reactions that do occur would need to be recorded and published in a peer-reviewed study to stand a chance of being taken seriously by regulators. 

Impossible Foods should use non-GMO ingredients in the EU – law expert

A report for Bloomberg quotes Katia Merten-Lentz, a partner at regulatory law specialists Keller and Heckman LLP in Brussels, as saying that due to EU consumers' hostility to eating GM foods, it may make more sense for Impossible Foods to use a non-GM ingredient in the EU.

“The spirit of the European countries is not really against innovation, but, for sure, not in favour of GMOs,” she said. “A GMOs [sic] ingredient which appears on the ingredients list could be a bad start in terms of marketing. If I were Impossible Foods, I would do my best to change the heme ingredient.”  

Indeed, analyses show that the market for plant-based fake meat products – the GMO issue apart – has peaked and is now in decline. Reasons cited include disappointing taste and high prices.

But Arlin Wasserman, founder of food strategy consultancy Changing Tastes, primarily blames "the long list of ingredients with unfamiliar names for making the product look like highly processed food and acting as a barrier to repeat purchases". He said, “Consumers may buy it once, but after reading the label, slow down their purchases."

Plant-based meat is commonly made from proteins processed from various plants (including fungal spores), colouring, flavouring, texturing agents, binders, and added vitamins and minerals that are naturally present in real meat.

Given these trends, the Impossible Burger may go down like a lead balloon in the EU. Impossible Foods should withdraw its application to EFSA and change its business model to focus on healthy, minimally processed foods with a transparent provenance.