Novel food vs traditional food notification: which pathway is right for your product?

Two pathways to the EU market under Regulation (EU) 2015/2283. How they differ, which one applies to your product, and what each requires.

Regulation (EU) 2015/2283 provides two distinct pathways for placing a new food on the EU market: the standard novel food application and the traditional food notification. Understanding which pathway applies — and the practical differences between them — is one of the first decisions an applicant must make.

The standard novel food application

This is the main pathway. It applies to any food that was not consumed to a significant degree in the EU before 15 May 1997. The applicant submits a full dossier through the E-Submission Food Chain platform, covering ten mandatory assessment sections. EFSA's NDA Panel conducts a risk assessment and issues a scientific opinion. The European Commission and Member States then decide on authorisation.

The statutory timeline is nine months for EFSA's opinion, followed by seven months for the authorisation decision. In practice, the median time from application to published opinion is around 16 months (Neytinck et al., 2025), driven largely by clock stops for additional data requests.

If authorised, the novel food is added to the Union List (Regulation (EU) 2017/2470) with specified conditions of use. Data protection applies for five years.

The traditional food notification

Articles 14–20 of the regulation provide a lighter procedure for traditional foods from third countries. A traditional food is one with a history of safe food use in a third country — specifically, at least 25 years of continuous use in the customary diet of a significant number of people in at least one third country.

The procedure is simpler: the applicant submits a notification (not a full application) to the European Commission, which forwards it to EFSA and Member States. If no reasoned safety objections are raised within four months, the traditional food can be placed on the EU market.

If objections are raised, the applicant must either withdraw or submit a full novel food application through the standard pathway.

Key differences

Evidence of history. The traditional food pathway requires documented evidence of 25 years of continuous, safe consumption in a third country. This means records, publications, or other documentation — not simply the assertion that "people have been eating this for centuries." The documentation must be specific to the food form and preparation method proposed for the EU market.

Assessment depth. A traditional food notification still requires the same ten assessment sections as a standard application, plus a mandatory history of use section. The difference is procedural, not in the depth of scientific evidence required.

Timeline. The notification pathway is faster — four months versus a median of around 16 months for the standard route. But this advantage disappears entirely if an objection is raised, because the applicant must then start the standard application process from the beginning.

Scope. The traditional food pathway is limited to foods with a documented consumption history. Novel foods produced using new technologies — precision fermentation, cell culture, engineered nanomaterials, new extraction processes — do not qualify, regardless of whether the source material has a long history of use.

Which pathway applies?

The decision tree is straightforward:

Does the food have documented evidence of at least 25 years of continuous, safe use as food in a third country, in the same form proposed for the EU market? If yes, the traditional food notification is an option. If no, the standard novel food application is required.

In practice, the traditional food pathway is most commonly used for plant-based ingredients and preparations with well-documented use in Asian, African, or South American food traditions. It is rarely applicable to technology-derived novel foods.

An important nuance: even if a plant or organism has a long history of use, a novel preparation method (such as a new extraction technique or concentration process) may mean the resulting product qualifies as a novel food rather than a traditional food, because it is the production process — not just the source — that determines novel food status.

Sources

- Regulation (EU) 2015/2283 on novel foods, Articles 3, 10–13 (standard application), 14–20 (traditional food notification). - Regulation (EU) 2017/2469 laying down administrative and scientific requirements.