1. Purpose
This policy sets out Murzo Group’s approach to regulatory awareness, governance, and risk management in relation to novel foods, including insects and insect-derived products, within the United Kingdom and European Union contexts.
The objectives of this policy are to:
- Support lawful market access for novel food products
- Reduce regulatory and commercial risk associated with food innovation
- Clarify responsibility allocation across the food supply chain
- Ensure accurate representation of regulatory status
- Provide a defensible framework for design, advisory, and commercial activities
This policy forms part of Murzo Group’s wider food, insect operations, and compliance framework.
2. Scope
This policy applies to:
- Insects and insect-derived products intended for human consumption
- Novel food ingredients, powders, extracts, or formulations
- Design, development, advisory, and commercial support activities
- UK and EU market access considerations
- Employees, contractors, partners, and authorised third parties
It applies irrespective of whether Murzo Group acts as a designer, supplier, advisor, or commercial counterparty.
3. Regulatory Context
Murzo Group recognises that certain foods, including insects, may be classified as novel foods, that market placement in the UK and EU may require prior authorisation, that authorisation is species-specific, format-specific, and use-specific, and that regulatory frameworks evolve over time.
Murzo Group monitors regulatory developments but does not act as a regulatory authority.
4. Murzo Group’s Regulatory Position
Murzo Group’s position is that only products lawfully authorised for the relevant market should be placed on that market, responsibility for obtaining regulatory approval rests with the entity placing the product on the market, and advisory or design involvement does not constitute regulatory endorsement or authorisation.
Murzo Group does not represent that all insect species, formats, or uses are authorised.
5. Authorisation Awareness
Where relevant, Murzo Group may reference publicly available authorisation lists or guidance, identify whether a product appears to fall within novel food scope, or support clients in understanding regulatory pathways.
Such activities do not constitute legal advice or regulatory approval.
6. Product Scope & Conditions of Use
Murzo Group recognises that novel food authorisations may specify approved insect species, permitted processing methods, product formats, maximum use levels, target consumer groups, and mandatory labelling statements.
Deviation from authorised conditions may result in non-compliance.
7. Labelling, Claims & Marketing
Murzo Group supports responsible representation of novel foods and does not endorse misleading claims regarding authorisation or safety, statements implying regulatory approval where none exists, or claims inconsistent with authorised conditions of use.
Final responsibility for labelling and marketing compliance rests with the product owner or distributor.
8. Allergen & Consumer Information Considerations
Murzo Group recognises that insect-derived products may present allergen risks and that regulatory guidance may require specific consumer warnings.
Murzo Group does not guarantee allergen safety outcomes and does not assume responsibility for consumer risk management beyond contractual scope.
9. International & Cross-Border Considerations
Murzo Group acknowledges that novel food status and authorisation requirements vary by jurisdiction, that UK and EU authorisations are separate regimes, and that authorisation in one market does not imply approval in another.
Murzo Group reserves the right to restrict activities by geography or market.
10. Research, Development & Pre-Market Activity
Research and development activities may precede regulatory authorisation and be conducted for non-commercial or internal purposes.
Murzo Group does not place unauthorised products on the market and does not encourage premature commercialisation.
11. Third Parties & Clients
Clients, partners, and operators remain responsible for determining novel food status, obtaining necessary approvals, engaging with competent authorities, and ensuring lawful market placement.
Murzo Group is not liable for regulatory failures of third parties.
12. Regulatory Change & Uncertainty
Murzo Group recognises that regulatory interpretations may change, authorisations may be amended, suspended, or withdrawn, and guidance may evolve.
Murzo Group does not guarantee continued market access.
13. Right to Restrict or Withdraw
Murzo Group reserves the right to decline participation in projects involving unclear regulatory status, suspend activities where compliance risk arises, or withdraw from markets or engagements without liability.
Such decisions may be taken in Murzo Group’s sole discretion.
14. Legal Position & Limitations
This policy does not constitute legal or regulatory advice, does not guarantee regulatory approval or market access, does not create contractual obligations unless expressly incorporated, and does not transfer regulatory responsibility to Murzo Group.
Nothing in this policy excludes liability that cannot be lawfully excluded.
15. Review & Updates
This policy is reviewed periodically and may be updated to reflect regulatory developments, industry guidance, and strategic or operational changes.
Commitment Statement
Murzo Group recognises the importance of responsible innovation in food systems. By maintaining regulatory awareness and clear responsibility boundaries, we aim to support lawful market access while protecting consumer trust and business integrity.
