Whole and sliced fruiting bodies of species with a documented history of significant consumption in the Union before 15 May 1997 are not novel foods. Mycelium produced by fermentation, extracts and concentrated fractions can be, depending on how they are produced and what they contain.
Why it works this way
Regulation (EU) 2015/2283 defines a novel food by reference to that cut-off date. If a food was consumed to a significant degree in the Union before it, the food is outside the regime and can be placed on the market without authorisation. Species such as Boletus edulis and Cantharellus cibarius have been eaten in Europe for centuries, so the traditional fruiting body is not in scope.
The analysis changes when the material changes. A concentrated beta-glucan fraction, a solvent extract or biomass grown in a fermenter is not the food that was consumed historically, even though it derives from the same organism. Production method and composition both feed into the assessment.
The EU Novel Food Catalogue is a useful starting point and is explicitly non-binding. It records the view of Member States on particular products, not a legal determination. The burden of demonstrating that a product falls outside the regime sits with the operator placing it on the market.
What follows in practice
For dried or frozen fruiting bodies, the question does not arise. For anything processed beyond that – an extract, a concentrate, a fermentation-derived ingredient – take the assessment before commissioning production, not after a customer’s regulatory team asks.
Note that the same rule applies to cultivated species. Cultivated against wild mushrooms sets out where the two branches genuinely differ, which is documentation rather than novel food status.