The European Food Safety Authority (EFSA) has been involved in the risk assessment of novel foods since 2003. The implementation of the current novel food regulation in 2018 rendered EFSA the sole entity of the European Union responsible for such safety evaluations. The risk assessment is based on the data submitted by applicants in line with the scientific requirements described in the respective EFSA guidance document. The present work aims to elaborate on the rationale behind the scientific questions raised during the risk assessment of novel foods, with a focus on complex mixtures and whole foods. Novel foods received by EFSA in 2003-2019 were screened and clustered by nature and complexity. The requests for additional or supplementary information raised by EFSA during all risk assessments were analyzed for identifying reoccurring issues. In brief, it is shown that applications concern mainly novel foods derived from plants, microorganisms, fungi, algae, and animals. A plethora of requests relates to the production process, the compositional characterization of the novel food, and the evaluation of the product's toxicological profile. Recurring issues related to specific novel food categories were noted. The heterogeneous nature and the variable complexity of novel foods emphasize the challenge to tailor aspects of the evaluation approach to the characteristics of each individual product. Importantly, the scientific requirements for novel food applications set by EFSA are interrelated, and only a rigorous and cross-cutting approach adopted by the applicants when preparing the respective application dossiers can lead to scientifically sound dossiers. This is the first time that an in-depth analysis of the experience gained by EFSA in the risk assessment of novel foods and of the reasoning behind the most frequent scientific requests by EFSA to applicants is made.

Department of Microbiology Nutrition and Dietetics Czech University of Life Sciences Prague Kamýcká 129 165 00 Praha 6 Czechia

European Food Safety Authority Via Carlo Magno 1A 43126 Parma Italy

Faculty of Food Science and Technology Institute of Life Sciences University of Agricultural Sciences and Veterinary Medicine Cluj Napoca 400372 Calea Mănăștur 3 5 CJ Romania

Faculty of Food Technology Osijek J J Strossmayer University of Osijek Franje Kuhača 20 31 000 Osijek Croatia

School of Medicine National and Kapodistrian University of Athens Ch Lada 6 10561 Athens Greece

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