Mung bean (Vigna radiata) protein is now an authorised novel food in Europe. It can be used in protein analogues or substitutes for standard products, such as meat, fish, or egg.
The authorisation comes just over two years after US-headquartered Eat Just, Inc. submitted its application for approval of the protein – the key ingredient in its plant-based egg substitute JUST Egg – in March 2020, and less than six months after the European Food Safety Authority’s positive opinion of the novel food.
In October last year, the EU agency’s scientific opinion judged protein powder extracted from seeds of the mung bean plant to be ‘not nutritionally disadvantageous’ and safe under the proposed conditions and use levels.
In EFSA’s analyses, it noted that mung beans are widely consumed in Asia, and is structurally related to seed storage proteins in other widely consumed legumes, such as soy, lupin and pea.
Eat Just eyes German and Dutch markets
For Eat Just, the Commission’s market approval represents a ‘landmark’ moment. Mung bean protein is the first novel legume protein to be deemed safe under the EU’s Novel Food regime.
According to the approval, Eat Just’s use of mung bean protein for plant-based egg products cannot be leveraged by other food companies looking to introduce similar products for a period of five years, unless those companies similarly obtain authorisation via the same novel food application process.
Following market approval covering countries belonging to the European Union and the European Free Trade Association, Eat Just expects to launch its JUST Egg product across the pond in the fourth quarter of this year.
“Germany and the Netherlands are key targets for JUST Egg,” explained Andrew Noyes, Head of Global Communications & Public Affairs, Eat Just, Inc.
The UK is also of interest, he revealed. Eat Just is actively engaging with the UK’s Food Standards Agency (FSA) on a regulatory path to market.
Eat Just is considering multiple sales channels. “Our team has been speaking with retail and foodservice partners across the continent who have expressed interest in stocking JUST Egg as soon as we receive regulatory approval and can begin sales and distribution across the continent,” Noyes told this publication.
Nutrition and sourcing
Eat Just’s mung bean protein is isolated from dry mung bean seeds in a sequence of process steps which conclude with a drying process. The end ingredient is made up of around 85% protein, 3-4% fat and 3-5.5% moisture.
In the US, JUST Egg’s ingredients list includes mung bean protein isolate, expeller-pressed canola oil, dehydrated onion, natural carrot and turmeric extractives for colour, and potassium citrate, amongst other ingredients.
One serving contains 70kcal, 5g fat, 5g protein, 170mg sodium, and is devoid of sugars and cholesterol.
The company sources its mung beans from ‘various parts’ of the world, including Asia and Africa. For Europe, the protein processing will be conducted in Germany at a facility Eat Just build in partnership with ingredients supplier Emsland Group.
“This facility will help ensure a manufacturing infrastructure for JUST Egg that is dependable, efficient and expandable as we enter new European markets,” said Noyes.
Can plant-based egg be called ‘egg’ in Europe?
While obtaining approval for its mung bean protein is a ‘monumental step’, it does not mean Europeans should expect to see JUST Egg on supermarket shelves in the coming weeks.
“Our team is working on a couple of remaining regulatory checks as well as packaging design, securing initial sales and distribution partnerships, and other activities as we prepare to bring JUST Egg to our first European countries,” said Noyes.
In Europe, the marketing of plant-based alternatives has caused controversy in recent times. In 2017, the European Court of Justice (ECJ) judged that purely plant-based products could no longer use dairy names, such as ‘milk’, ‘butter’, ‘cheese’, or ‘yogurt’.
In 2020, the European Parliament voted against banning ‘meaty’ terminology for plant-based alternatives, meaning that ‘burger’, ‘sausage’, or ‘steak’ for vegetarian and vegan alternatives can still be used.
So what about ‘egg’? Will Eat Just be able to market its plant-based egg alternative as ‘JUST Egg’? Christofer Eggers, Partner of global law firm Squire Patton Boggs in Frankfurt, Germany, suggested it ‘may be a challenge’.
“The Novel Food approval just says the product is safe for consumption. While the term ‘eggs/Eier’ is not under the same strict protection as the designations of milk products, still Article 7 of the Food Information Regulation applies,” he told FoodNavigator.
“There is a mandatory name for this [product] and they will not be able to call it ‘JUST Eggs’, because it is not an egg-based product.”
Eggers referenced a recent case in the District court of Dusseldorf, in which the name ‘SKYR STYLE’ (Skyr is an Icelandic cultured dairy product) for a soy-based product was banned.
“It may be a challenge to market a ‘JUST Egg’ product without misleading the consumer.”
What about the UK?
As Eat Just’s Head of Global Communications & Public Affairs noted, Eat Just is working through the UK’s own regulatory process in parallel. Since the UK withdrew from the EU, separate novel food approval is required using the FSA’s regulated products application service.
The grant of novel food approval in the EU does not guarantee that the UK’s FSA will also approve the product as safe, explained Director Nicola Smith from Squire Patton Boggs’ Birmingham office, although any opinion from EFSA would ‘typically’ be taken into account as part of the data considered in the FSA’s assessment.
Indeed, the UK’s Advisory Committee on Novel Foods and Processes were due to discuss the application for approval on 24 March 2022, to consider the applicant’s response to its request for further information (the FSA having first received a submission for Eat Just, Inc. for mung bean protein in January 2021), we were told.
“However, the EU’s Food Information for Consumers Regulation continues to apply in the UK as retained law, following the end of the Brexit transition period. As set out [by colleague Eggers], this requires that food information is not misleading (Article 7) and there may be concerns that labelling a vegetable protein as ‘egg’ could be contrary to those provisions.”
Eat Just's Noyes told us the company is still working through this and that ultimately, what it will be able to call its products could vary by country.
‘Significant’ interest from retail and foodservice in Europe
Eat Just is confident that once launched, the product will be well received in the new market. “Forward-thinking consumers in Europe have
been asking for JUST Egg since the day it launched in the US,” according to Josh Tetrick, co-founder and CEO of Eat Just.
“Whether because of climate change, health or a connection to animals, the demand has been significant, as has interest from retail and foodservice partners.
“I’m grateful for the recent approval, which opens the door to begin distribution across Europe before the end of the year.”
Indeed, if US sales are anything to go by, the category is clearly gaining traction. Last year, the plant-based egg category observed a 42% increase in retail dollar sales, according to data from the Plant Based Foods Association, the Good Food Institute (GFI), and SPINS.
Over the past three years, plant-based egg sales in the US have grown more than 1,000%. And Just Egg claims to represent more than 99% of the market.
In Europe, a growing number of plant-based egg replacements have entered the market in recent years. These include egg substitutes from Terra Vegane, Biovegan, Pure Raw, Simply Eggless, and Zero Egg.
However according to a 2021 pan-European survey by ProVeg, in partnership with Innova Market Insights, the University of Copenhagen and Ghent University, flexitarian consumers want more choice in plant-based foods.
“We’ve seen that nearly half of flexitarians think there are not enough plant-based choices in supermarkets and restaurants and Just Egg’s product will help to meet consumer demand and bolster what is already a booming market for plant-based products,” said Stephanie Jaczniakowska-McGirr, Head of Food Industry & Retail at ProVeg International.