The Impossible Burger 2.0, a plant-based vegan burger that tastes like real beef. Copyright © Robyn Beck/AFP/Getty Images
5. Looking Ahead: Considerations for EU Policymakers
As innovation continues in plant-based ‘meat’ and cultured meat, European policymakers will need to consider how the EU positions itself in the nascent global meat analogue industry. Certain European universities and companies have been central in the early development of meat analogue techniques but, with markets in North America, Asia and Israel growing rapidly, further financial investment and the resolution of outstanding regulatory uncertainties will be needed if the EU is to be a significant global player in this space. Perhaps more importantly, EU decision-makers and member states will need to consider if and how meat analogues contribute to the realization of existing policy strategies and priorities, not only in terms of environmental governance but also public health and the transition to a circular economy.
Considering the role of meat analogues in broader food system reform
The strength of incumbent industry and the perception of the livestock sector’s cultural importance have made meat consumption a politically sensitive issue in the EU and, in the absence of effective policy interventions to promote a large-scale shift away from conventional meat production and consumption, public investment in meat alternatives has been relatively muted. Despite the considerable negative externalities associated with meat production and consumption, EU efforts to promote a more sustainable food system are not without political challenges. Environmental concerns have at times clashed with economic and political priorities140 among the many formal and informal actors and networks that interact to define European regulation,141 and the EU’s first draft sustainable food strategy, developed in 2013, was not published.142 Moreover, efforts to reform the Common Agricultural Policy (CAP) have repeatedly been slowed owing to strong economic and political support from EU member states for maintenance of the existing system – the CAP received approximately 38 per cent of the EU budget for 2014–20 (€408.31 billion over that period).143
As the EU looks to meet its ambitious commitments on climate change mitigation, sustainable consumption and public health in the coming decades, it is crucial that public policymakers view meat analogues and their regulation within the broader context of food system reform. Meat analogues have the potential to galvanize the EU’s success in meeting many of its more ambitious policy goals, including the EC’s Food 2030 Initiative.
The EU’s plan to reduce GHG emissions under the UN Framework Convention on Climate Change (UNFCCC), for example, is among the most progressive in the world, and research has illustrated the vital importance of a reduction in meat consumption in the EU in meeting these climate targets.144 In 2018, new analysis from the RISE Foundation found that EU livestock production and consumption are currently exceeding sustainable levels for Europe and identified the substitution of conventional meat for cultured meat and plant-based alternatives are as a potential strategy for adjusting current livestock consumption patterns.145 Further research is needed to assess the resource footprint of cultured meat and plant-based ‘meat’ production at scale, and to develop a low-carbon energy source for the production of cultured meat.146 Early studies indicate that meat analogues could play a key role in satisfying current and future demand for meat in the EU, while significantly reducing the emissions and resource intensity of production and freeing up much-needed land for use in renewable energy production and carbon capture.147
Early studies indicate that meat analogues could play a key role in satisfying current and future demand for meat in the EU, while significantly reducing the emissions and resource intensity of production and freeing up much-needed land for use in renewable energy production and carbon capture.
Meat analogues could play a similar role in delivering improved public health targets at the European and national levels. In 2015, European health ministers committed to the European Food and Nutrition Action Plan 2015–2020, which aims to create healthy food environments and tackle diet-related non-communicable diseases.148 As a result, several EU member states have taken steps to promote reduced consumption of meat in their national dietary guidelines,149 recognizing the links between excessive consumption of red and processed meat and diet-related diseases including obesity, type-2 diabetes, heart disease and certain cancers.150 Theoretically, cultured-meat cells may be engineered to create a healthier product, altering the balance of harmful components – saturated fats, for example – with desirable components such as poly-unsaturated fatty acids, while plant-based ‘meat’ products, unless highly processed, tend to contain relatively low levels of saturated fat, cholesterol and calories.151 At the EU level, the One Health Action Plan against Antimicrobial Resistance seeks to position the EU as a ‘best practice region’ in the fight against unsustainable antibiotic use, including through boosting innovation: if its producers succeed in scaling up production in a sterile environment, cultured meat could offer a means of delivering a product that is healthier for consumers and produced without the need for antibiotics.
More broadly, investment in research, development and innovation in the meat analogue industry could form a keystone of the EU’s Circular Economy Action Plan and its Food 2030 Initiative, which both prioritize research and innovation in circularity and resource efficiency in the food system. Under the Circular Economy Action Plan, the EU has committed to implementing an ambitious package of measures aimed at promoting a ‘sustainable, low carbon, resource efficient and competitive economy’ in which innovative new ways of producing and consuming are promoted as a means of protecting the environment, buffering businesses against resource scarcity and price volatility, and unlocking new jobs.152 The development of a meat analogue industry that encourages the use of plant protein crops for direct human consumption rather than as animal feed, and creates new economic opportunities for European farmers outside conventional livestock production, may boost EU policymakers’ efforts to deliver on the circular economy.
Ensuring a clear regulatory framework and evidence-based decision-making
EU regulation has the potential to affect the nature, scale and pace of innovation, from the research and development stage right through to commercialization.153 Consumer safety and good manufacturing standards must remain the priority of regulators as they consider whether novel meat alternatives should be licensed for sale, and under what conditions. But, with legal definitions of meat and meat-related terms already being debated in European courts, EU policymakers will need to consider the broad range of issues and concerns surrounding meat analogues if they are to ensure a clear, transparent and evidence-based regulatory framework.
As it stands, the Novel Food Regulation provides for a technical assessment of the safety of meat analogues for humans, animals and the environment. The EFSA undertakes an assessment of potential nutritional, toxicological or allergenic hazards and recommends a decision to the Standing Committee, after which the European Commission and member states may raise specific safety concerns as they see fit before a final decision on approval is made. Less transparent is the process for deciding on specific stipulations regarding product labelling that may accompany an approval under the Novel Food Regulation, and on the process for determining legal, customary and descriptive names under the FIC Regulation on product labelling.
Insights from research into the labelling and marketing of vegetarian products and the impact of these activities on sales indicate the importance of labelling decisions and regulation in determining the future of the meat analogue industry. Clear and consistent product packaging and nutritional labels are vital to enabling consumers to make informed decisions and to fostering consumer trust in the European food system, particularly in the wake of the 2013 European horsemeat scandal: many consumers report paying more attention to labels on meat products, while others report a lack of confidence in the honesty and accuracy of labels.154 The European Commission, recognizing that greater clarity is needed for innovators, incumbent industry and consumers, is set to undertake a review of the labelling of vegan and vegetarian food, for which preparatory work will start in 2019.
In order to ensure that product labelling prioritizes consumer information and trust, and is not co-opted by lobbyists from industry or third parties, European consumer watchdogs and government regulators should commission market research to explore consumer attitudes towards plant-based ‘meat’ and cultured meat, their labelling, and the information that consumers need to make an informed purchasing decision. Beyond technical considerations, the future growth of the meat analogue industry will depend on a host of social, economic and political factors.155 Any review process should involve engagement with the public, producers, specialists in environmental and human health, and experts in product labelling and consumer behaviour.
The same process should apply to cultured meat. In recognition of the European Commission’s reactive rather than proactive approach to novel food safety assessments (the process of assessment and approval is initiated only when an application is formally submitted by a producer), it may be necessary to establish an independent advisory committee to ensure timely consideration of the complex regulatory questions concerning cultured-meat products. This committee could be tasked with reviewing developments in the meat analogue space, considering likely safety concerns and labelling requirements arising from new techniques or products, and engaging with producers early on in the approval process to provide support and ensure that policymakers are kept abreast of developments. The generation of research data to support the EFSA assessment of novel foods and their safety will also be important to avoid bottlenecks in the approval process.156
Beyond technical considerations, the future growth of the meat analogue industry will depend on a host of social, economic and political factors.
Furthermore, in taking early action to create a clear regulatory landscape, the EU could pioneer international standards for this new industry, thereby strengthening its position as a hub of innovation and contributing to a supportive global environment for European meat analogue companies wishing to export overseas.
Investing public funds in research and development
The costs associated with meat analogues, at the point of both production and retail, are likely to remain a significant barrier to widespread uptake in Europe in the near to medium term. Investments by traditional meat companies in plant-based ‘meat’ and cultured-meat companies may help to accelerate both innovation and the scale-up of production and distribution infrastructure.157
However, policymakers at the EU and member-state levels have a key role to play, for example, in lowering market barriers to entry for new producers and facilitating the commercialization of research.
As major food companies move into the meat analogue space, public support for non-exclusive research and for the sharing of research findings will be important in keeping the field open to new entrants, particularly to small- and medium-sized enterprises, which have driven innovation to date. Public capital will also be needed to bridge the gap between innovations developed in the laboratory and their commercial exploitation:158 large up-front investments in the infrastructure to support the scale-up of new products or technologies are often difficult to secure from low-risk investors, particularly for small- and medium-scale producers; public capital can help to catalyse the commercialization of new innovations while mitigating against the risk that promising innovations are acquired and developed by actors outside the EU. This will be particularly important if the EU is to retain its position as a global hub of innovation in the meat analogue industry. The use of non-exclusive licensing arrangements with any third parties seeking to commercialize the end product can help ensure that foundational knowledge developed with public finance remains in the public sphere.
The EU has one of the world’s largest public-sector R&D programmes and has already committed significant public funds to supporting meat analogue innovation. Between 2010 and 2013, the EU provided over €1 billion for research into high-quality plant-based ‘meat’ products under the ‘LIKEMEAT’ project159 and, in 2017, it announced a further €1 billion investment in innovation in the agri-food sector under its Horizon 2020 R&D programme,160 including a €32 million budget for innovation in ‘alternative proteins for food and feed’.161 In addition, a number of other budgets could be used to further R&D in the field, including anticipated funds with the explicit aim of supporting high-risk disruptive innovations.162 Existing mechanisms can also support investment in research and innovation, including the European Fund for Strategic Investments (€500 billion), the InvestEU programme (€38 billion) and the Smart Specialisation Strategy (€41 billion).
A coordinated strategy at the EU level will be crucial to ensure that any funding resources channelled into meat analogue innovation are optimized efficiently and transparently and consistent with EU policy priorities. A unified research and innovation strategy for a climate-smart, sustainable food system163 could steer the consolidation of the above funds and target related financing sources, for example, climate-related research (which is due to get 35 per cent of the proposed €100 billion Horizon Europe research and innovation budget for the period 2021–27)164 and innovation under the circular economy and One Health agendas. A core component of such a unified strategy should be the optimization of investment in meat analogues that offer sustainable and healthy alternatives to conventional meat.
Conclusion
Meat production and consumption are highly politicized issues in the EU and globally. Meat analogues, while in their infancy, are already the subject of much speculation and debate among innovators, incumbent industry, civil society and the public. As innovation continues to evolve at pace in Europe and around the world, it is crucial that EU policymakers take stock of this nascent industry and consider its place in EU-wide policy priorities and industrial strategies.
A thriving meat analogue industry in the EU has the potential to contribute to existing policy priorities in a number of areas, including climate mitigation, reduced antibiotic use, improved public health and more circular means of production. To harness this potential, early and sustained public investment is needed in research, development and commercialization to ensure that innovations transition from the laboratory to European markets. Equally important will be a proactive and inclusive approach to resolving outstanding regulatory uncertainties, particularly around product naming and labelling. In the absence of such an approach, there is a risk that key policy decisions – decisions that will likely have a material impact on the response of the public and civil society to novel products and production systems – are made in the courtroom and shaped by third-party interests rather than by policymakers in a timely, transparent and evidence-based manner.
Global efforts to promote sustainable and equitable food system reforms and mitigate the environmental impact of food – particularly meat – production on the environment and on public health are gathering momentum. A timely and coordinated strategy at the EU level to harness the potential of the nascent meat analogue industry within this context, and to promote a regulatory environment that is clear, transparent and inclusive, could help to cement the EU’s place at the forefront of innovation in the sustainable resource economy and as a global leader in the meat industry of tomorrow.