On 8 September 2026 the European Commission adopted a research and innovation strategy for agriculture and food, COM(2026) 453. Buried in section 2.3 is a sentence that an operator in this sector will have wanted written down by a public authority for years. Financial support, it says, “notably implies addressing the continent-wide shortage of industrial-scale contract manufacturing capacity at TRL 8-9 for fermentation-based technologies for food and feed ingredients”.
The action the document then commits to is a different thing. Annex 1, action 14, is to “encourage private investment to support the building and upgrading of open-access pilot and demo-scale bioprocessing infrastructure”, starting in Q1 2028. That is pilot scale, not TRL 8-9; private money, not public; and it begins roughly sixteen months or more after adoption. No amount appears against it in the passages we could read.
This piece sets the diagnosis beside the remedy, and beside what the Commission said about fermentation two months earlier. It is a reading of the text, not a forecast of what will be funded.
What the strategy says, in order
Section 2.3, “Boosting food technology for food-chain resilience and food security”, makes the argument in four steps.
First, “the EU is strong in financing early-stage innovation”, but “upscaling new, sustainable food ingredients requires more financial support to help innovative startups and other SMEs overcome the second valley of death”. Footnote 30 defines the term: “The second valley of death occurs from pilot/demo to market scale.”
Second, the food industry “has significant capital expenditure requirements and… private investors are often hesitant to support infrastructure financing”.
Third, financial support “notably implies addressing the continent-wide shortage of industrial-scale contract manufacturing capacity at TRL 8-9 for fermentation-based technologies for food and feed ingredients while fully respecting the EU risk assessment and authorisation framework”.
Fourth, the commitments. The Commission “will explore how to increase investment including through the ECF InvestEU Instrument, to accelerate commercialisation and strengthen food innovation in the EU”, and, on advanced fermentation specifically, “will explore how to encourage private investment in the building and upgrading of open-access pilot and demo-scale bioprocessing infrastructure for advanced fermentation to support the food industry”. Annex 1 turns the second into action 14, adding that the purpose is for SMEs “to test and de-risk their processes without the need for prohibitive up-front capital expenditure”.
| Element | What the text says | Stage or type |
|---|---|---|
| Gap named | Continent-wide shortage of industrial-scale contract manufacturing at TRL 8-9 | Commercial scale |
| Gap defined in footnote 30 | Second valley of death: pilot/demo to market scale | Commercial scale |
| Commitment on investment | “Explore how to increase investment”, including the ECF InvestEU Instrument | Unspecified |
| Commitment on fermentation (Action 14) | “Encourage private investment” in open-access pilot and demo-scale infrastructure | Pilot and demo scale |
| Timing of Action 14 | Q1 2028 (“Actions Starting from”) | Start date |
| Funding vehicle for the strategy | Horizon Europe 2028-2034 and relevant parts of the European Competitiveness Fund (Commission news release) | Programme period |
| Amount for fermentation capacity | None found in the passages we retrieved | n/a |
Practical consequence: an operator or investor planning EU capacity should read this as recognition of the problem, not as a financing route. Nothing in the text we read commits public money to TRL 8-9 fermentation capacity, and the nearest action is pitched a stage earlier and dated 2028.
Diagnosis at one stage, remedy at another
The mismatch is the point. The Commission’s own footnote places the second valley of death between pilot/demo and market scale. The shortage it names is at industrial scale. The action it schedules supports pilot and demo-scale infrastructure that SMEs can use “to test and de-risk their processes”. Open-access pilot capacity helps a company get from bench to a validated process. It does not add the tonnes a company needs once the process is validated, which is what a contract manufacturer at TRL 8-9 provides.
For the commercial-scale side of that gap, see our map of who has fermentation tanks. In the MAASH case, a new financing funds a 12 m³ demonstration unit on a site that once carried a far larger plant. Pilot capacity is being built. The layer above it is the one the strategy calls short.
It is fair to say the two are linked: better pilot access de-risks the processes that later need commercial capacity. But the strategy does not make that argument, and the sentence that names the shortage does not say which instrument will address it.
Two months earlier: fermentation as a “complementary pathway”
The Commission’s Protein Action Plan, COM(2026) 355 of 7 July 2026, uses “ferment” four times in the passages we retrieved. It says “Fermentation-based technologies are a complementary pathway within the broader protein landscape, with potential implications across agricultural value chains” and that “Innovative fermentation processes are developing and scaling in other jurisdictions, creating economic benefits and new income streams for farmers outside the EU”. It also says “The upcoming Biotech Act II will aim to strengthen the EU’s industrial competitiveness in industrial biotechnology and biomanufacturing, including based on advanced fermentation.”
The one funding figure we found in the plan is retrospective and concerns crops: “The Union Research Framework Programmes for R&I, Horizon 2020 and Horizon Europe have invested over EUR 190 million to support R&I in protein crops.” We found no equivalent figure for fermentation or biomanufacturing capacity in either document.
So in two months the Commission has moved from describing fermentation as one pathway among several, developing largely elsewhere, to naming a continent-wide shortage of the capacity to make it. The commitments have not moved as far. ProVeg’s reaction to the July plan described the same asymmetry from the other side: “The ambition on feed is concrete and measurable; the same firmness does not yet match the ambition on food.”
Practical consequence: the July plan points at Biotech Act II for industrial biomanufacturing. That is where any capacity instrument would have to appear, and it has not been published. For our earlier view of how the first Biotech Act treated food, see our analysis of its novel food exclusion.
What the strategy does not change
The Commission qualifies the capacity point with “while fully respecting the EU risk assessment and authorisation framework”. Novel food authorisation is untouched. The strategy’s sandbox language is general: it refers to “regulatory sandboxes and closer collaboration with EU risk assessment bodies” to support risk assessment methods, and does not say whether novel foods are in scope. Green Queen reports GFI Europe calling on the Commission to reverse its exclusion of novel foods from regulatory sandboxes, and quotes Alessandro Gardino of GFI Europe: “While it’s great to see a renewed focus on scaling up Europe’s fermentation manufacturing capacity, the lack of dedicated research to improve the taste and price of alternative proteins is a missed opportunity, particularly as the Commission has acknowledged their benefits in its own evidence review.”
For a company waiting on an EU approval, the strategy therefore adds no route to a faster one. Our reading of how long approvals take is in EFSA’s opinion is not the approval.
The counter-argument
The generous reading is that a research and innovation communication is not a budget. Its job is to set priorities that later programmes fund, and it already says the strategy will be deployed under Horizon Europe 2028-2034 and relevant parts of the European Competitiveness Fund. Committing to “explore” an ECF InvestEU route is how the Commission signals it will bring a financing proposal, not a statement that it will not. A framework document that names a capacity shortage at TRL 8-9 in an official text creates a citation that industry and Member States can use in the budget negotiations that follow.
The strategy itself says private investors are “often hesitant to support infrastructure financing”, which may explain why its chosen lever is to encourage them. We found no statement of why the Commission chose pilot and demo scale for the action.
That reading is plausible. It still leaves the sequence as it is: the diagnosis is 2026, the earliest dated action is Q1 2028, and the money is not quantified.
What we could not establish
- Any amount. We found no euro figure against action 14, the ECF InvestEU commitment, or fermentation capacity in the passages of COM(2026) 453 we retrieved. We read the document through an extraction of the published PDF, not a full page-by-page reading, so an amount elsewhere in the text is possible.
- What “TRL 8-9” is taken to mean. The communication uses the term without, in the passages we saw, defining it.
- Whether Action 14 could reach commercial scale. The text says pilot and demo scale. We have not seen any statement extending it.
- The scope of the sandbox language. We have not confirmed whether novel food is inside or outside the strategy’s sandbox references. Green Queen reports GFI’s call to reverse an exclusion, which points to the Biotech Act, not this document.
- The content of Biotech Act II. It is described as upcoming and we found no text.
- The evidence behind the shortage. The communication asserts a continent-wide shortage. The passages we read cite no capacity figure for it.
What to watch
- Publication of Biotech Act II, and whether it contains a capacity or financing instrument for industrial fermentation.
- Any Commission proposal or Member State statement that puts a figure on the ECF InvestEU route mentioned in section 2.3.
- The scope of Action 14 when it starts in Q1 2028: pilot only, or extended to industrial-scale contract manufacturing.
- Whether the Horizon Europe 2028-2034 work programmes carry a named fermentation call.
- Whether a Member State or regional programme fills the TRL 8-9 gap first.