Further Information on “Approval” of Cultivated Meat for Pet Food, the Story Continues

Three weeks ago, we published a report describing the events surrounding Czech startup Bene Meat’s self-reported regulatory approval of cultivated meat for pet food.

Following the article’s publication, Bene Meat reached out to provide further clarification into the matter, requesting that we publish a provided Q&A on the subject (as below).

So, in the week that saw interesting moves in the world of alt pet food including: Biocraft Pet Nutrition posting a video on social channels of Oliver the cat making history by sampling a recipe containing cultivated mouse meat; and Paleo announcing the “world-first” patent application for animal-free heme in pet food, to effectively make plants taste like meat; here we provide an update to the complicated story of Bene Meat and the race to market with cultivated meat for pet food.

Bene Meat’s perspective

Says a representative from the Prague-based Biotech: “We agree with the statement present in the article: that the EU Feed Materials Register does not grant any certifications or pre-market approvals. That is correct. On the other hand, we would like to add that the registration in the Feed Materials Register is not open to just anyone, and only subjects authorized to produce feeds and satisfying all of the regulations for the production of feeds are able to register. Bene Meat has indeed satisfied all of these requirements.

“We sincerely regret that the particular word certification appeared in the English translation of our initial press release, whose writing was not handled by a person sufficiently versed in legal language. This is something we promptly corrected in all of our releases and communication. It was never our intention to miscommunicate. However, we would like to emphasize that we fully stand behind the core of our message: We have satisfied all of the legal requirements to put the cultured meat-based feed ingredient on the EU market. We have a production capacity to produce cultured meat-based feed ingredients.”

“First in the world to meet all of the legislative requirements”

In its follow-up communication, BMT stated that it “would like to be transparent with its customers, authorities, manufacturers, and other entities, and its priority is to sell a completely safe raw material that will bring joy to cat and dog owners who would like to give their pets high-quality protein that doesn’t necessitate having to kill another animal,” and that it wanted to properly respond to questions raised in connection with the fact that it was the “first in the world to meet all of the legislative requirements, and thereby become the only company in the world to produce and sell cultured cells to animal feed manufacturers.”

Vegconomist asked BMT to clarify how it is objectively the world’s first in this respect, when there are a handful of existing competitors. The company responded, “Meatly of the UK (formerly Good Dog Food) is our closest European competitor and is close to entering market, but it is not yet there according to this very recent article. Biocraft of the US (formerly Because Animals) is our closest competitor in the US. However, we have found no public information regarding their timeline to market. We do not have much information about Everything But, we would assume that should they have a marketable product, there would be more information.

The follow-up questions and answers

What follows are the provided questions and answers sent by Bene Meat in order to provide further clarification to those interested in the space.

On 7.11.2023, the BMT product “Cultured cells of mammalian origin” was listed in the European Feed Materials Register. There are objections that it’s not about registration, but rather about the fact that BMT created the record itself. So can BMT produce and sell cultured cells in the EU as a pet food ingredient?
Yes, BMT has met all of the legislative requirements, and can legally manufacture and sell cultured cells for pet food in the EU. Food and feed safety falls under the so-called “shared competence” of the EU and the member states. The Feed Materials Register has the character of an EU-wide register of approved feed materials, serves as an information source for producers and consumers from all EU countries, and is an important tool implementing the principle of transparency, as it follows from the Treaty on the European Union and the Treaty on the Functioning of the European Union. Companies registering products in the Feed Materials Register must meet a number of requirements regarding the safety of product production.

So is the BMT product safe, and has any authority checked its safety?
Yes, BMT’s “cultured cells of mammalian origin”, which is registered in the Feed Materials Register, is safe. The product manufacturing process has been subject to assessment by the relevant national authority, and as such has met all of the requirements. The fact that the actual act of registration in the Feed Materials Register is not carried out by the authority itself, but by the manufacturer, certainly doesn’t mean that the conditions of production and the nature of the product are not under the control of the relevant authorities. It’s the same as when you ceremoniously hang the name of your new restaurant above the entrance, it doesn’t mean that you don’t have the proper permits to operate.

In this context, it’s necessary to remind people that the safety of products placed on the market is the primary interest of BMT as a manufacturer and is one of the key principles of the BMT code of ethics. BMT doesn’t perceive the authorities and institutions overseeing safety (whether at the level of a member state or the EU) as rivals that need to be conquered, but as partners with whom it has a common interest – to eliminate all of the real existing risks for consumers, or in this case, for their pets. The fact that a number of the team members tested it on their pets, who liked it, and didn’t suffer any problems at all, could perhaps testify to the fact that the product is safe. And, of course, it works on long-term studies and tests that go beyond the mandatory ones, so that they have even more confidence that the raw materials are harmless.

Cultured cells are registered as a “product of fermentation”, not as an “animal by-product” that one might normally associate with meat.
It’s important to note that there is a significant difference between animal by-products (ABPs) and cultured cells when assessing safety. When assessing the safety of ABPs, three aspects are of primary interest:

1. How the animal was fed and how it lived before its slaughter,
2. Whether the animal was healthy when slaughtered,
3. How the parts of its body were treated in terms of maintaining hygiene standards after slaughter.

Obviously, these aspects are not applicable to cell cultivation. Cultured cells have a significantly different position, in terms of safety assessment. What is essential for them is primarily compliance (and control) with the risk-free standard of cultivation in bioreactors, and the composition of the cultivation medium from which they draw nutrients. In this, the cultured cells are much closer to the microorganisms in which these aspects are observed, and logically their safety for consumption is assessed as if they were microorganisms. This aspect was also consulted on with the European Commission, which on 27.1.2023 confirmed the correctness of our thinking and procedure.

It’s great that even the European Union has a world-leading position on the journey to greater sustainability.

Each approval of a cultured product is seen as a major event. One cannot help but notice a certain rivalry between manufacturers who are competing to have their product approved first. BMT is apparently the third company in the world that can produce and sell a cultured product, and the first ever company in the world that can produce and sell a cultured product for pet food. Was it the intention – to be first?
Being first in the world at almost anything is nice, of course, but it wasn’t the primary goal. We aren’t looking for investors, we’re starting a normal business. Our research and development has progressed to the manufacturing and upscaling stage, where we bring the product to market. There are no final products in stores yet, but we have started palatability testing, and are sending out samples to partners so that we can fine-tune the recipes. And we can’t do that without meeting the legislative requirements. From a commercial point of view, on the other hand, publicity is more of a drawback. Thanks to the publicity, pet food manufacturers have a chance to learn about the new available raw materials, but at the same time, we’re being watched more closely by the competition, who will certainly react very quickly, and we therefore have to try harder.

However, this is certainly great news for consumers. If all goes well, next year, the first cultured products for cats and dogs will be available for normal purchase. Everyone who wants their pet to be fed without another animal having to die, to be environmentally friendly, and with controlled health, will finally have the option.

You consistently use the term “cultured cells” and not “cultivated meat” or “cultured meat”, as is commonly used, why?
In professional discussions, we always and systematically use the term “cultured cells”, which correctly describes our product. At the same time, we understand that the lay public gravitates towards the term “meat”, because it’s a familiar and imaginable term associated with proteins of animal origin. The reason is our effort to use the most accurate terminology.

“Meat” as such is a widely used term, but there is no statutory definition of meat in either the EU or the US. It’s therefore not clear when it can be used. This is perhaps why some manufacturers use the term.

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