Novel and non-novel status

Product and Regulatory Positioning: For generations, parents have quietly “food-smuggled” vegetables such as broccoli into meals to deliver nutrition in a form that is easier to consume. Our ambition is to support this same principle at industrial scale: enabling the incorporation of nutritionally valuable vegetable components into everyday foods in a simple, practical, and familiar way.

Our initial product portfolio has been deliberately designed with the intention of aligning with established non-novel food criteria under UK law, based on ingredient history, processing methods, and comparable conventional food processes. Unlike some biotechnology-driven approaches, such as precision fermentation, which may involve genetically modified microorganisms and therefore require novel food authorisation, our first products do not use genetic modification or engineered organisms. We do not use GMO-derived side streams.

Minimal Processing Philosophy: Our philosophy is one of minimal processing, with production processes specifically optimised to preserve the intrinsic complexity of whole vegetables rather than to refine them into purified single components. For our first products (Fiba, Prota, Ola), we fractionalise vegetables that have been cultivated and consumed for centuries, with a long history of use in the UK and EU. The processing steps are intentionally limited, designed to concentrate naturally occurring fractions while retaining their native molecular diversity.

Concentrates, Not Isolates: Our Prota, Fiba, and Ola ingredients are best described as vegetable-derived concentrates, not isolates:

• We focus on fractionalisation rather than synthesis, and concentration rather than isolation; accordingly, pur processing steps are comparable to established conventional food processing techniques and are not intended to alter the essential nature of the source vegetable.

• Our products contain multiple naturally co-occurring components present in the source vegetable.

• No single protein, fibre, or compound is intentionally purified to isolation.

• The ingredients retain structural and compositional characteristics consistent with established conventional food processing practices

Specifically, we avoid purified proteins, refined fibres, and chemically or enzymatically reconstructed ingredients. We do not position or claim our products as functional actives.

Based on current guidance, ingredient history, and processing methodology, we consider Prota, Fiba, and Ola unlikely to fall within the scope of novel food regulation under UK legislation. This position is subject to confirmation where required. Our approach to giving assurance to our customers and investors is to have independent lab testing (we use Intertek) and obtain independent third-party opinions (we use RSSL) to challenge, assess and substantiate our position. Where appropriate, we will seek confirmation from the UK Food Standards Agency via an Article 4 consultation.

Other Products in Development: Necta is intended to be used or sold as a feedstock for downstream processing rather than as a food ingredient in its own right, and is therefore not currently positioned as a food under UK novel food legislation.

The novel food status of Ova will be assessed once its final production process has been defined.

We are also at an early stage of development with a partner on a mycelium-based product that will use Necta as a feedstock. While mycelium has historically been consumed (for example, in products such as those produced by Quorn), the specific strain intended for this application was not widely consumed prior to May 1997 and is therefore likely to be considered novel under UK law. We will follow the appropriate regulatory pathway and work closely with national food safety authorities, initially the UK Food Standards Agency, to ensure full compliance.

United States Regulatory Pathway: For the United States, we intend to pursue a GRAS (Generally Recognized As Safe) pathway that is appropriate to the intended use levels and dietary exposure of our ingredients. We will support customers with the documentation required for compliance with the Food and Drug Administration and for importer verification purposes.