Insects as food and feed – the legal perspective

Insect protein could offer poultry producers a viable alternative protein, if regulatory and perception problems can be overcome, as delegates of the Insects as Feed and Food conference discovered in early April.

Changes to European Union legislation are paving the way for insects to be used for food and feed in various agricultural sectors.

Before the beginning of the year there was no insect-specific regulation and insects were not specifically mentioned as a “novel food”, with people having to fall back on general requirements of food safety and hygiene.

As a result, according to Freya Lemon, associate at law firm Michelmore’s, there was a degree of inconsistency across EU member states with products banned in some countries but largely approved in the UK.

Ms Lemon said there was no central authorisation of novel foods, which meant there was less transparency.

However, the introduction of the EU Novel Foods Regulation on 1 January 2018, means there is now regulation across all novel foods, including insects.

Under the regulation, insects must not pose a risk to human health, there must be no misleading of consumers and there should be no nutritional disadvantages compared to conventional foods from the product.

Assessment

Various products, she said, were currently undergoing assessment, including dried crickets and dried mealworms.

Ms Lemon said legislation around using insects as feed was progressing slowly, despite it being an opportunity to promote sustainable protein in agriculture.

“We are well behind in terms of legislation… and that is a huge source of frustration.”

She added that using insects as food and feed was recognised globally, given the challenge around the availability of quality protein that was safe and environmentally responsible. Current industry practices rely heavily on grain, in particular on imported soya from South America as a source of protein – something not considered to be either sustainable or environmentally responsible in the long term.

Future for insect products in poultry feed
Considerable opportunities exist for using insects in feed as seen by the 10% rise in global sales in the past year, according to Nuffield scholar Aidan Leek. Dr Leek said the insect sector was currently the fastest growing animal feed sector and was helping meet huge protein demand. He cited the launch of the first insect-fed salmon, branded as Friendly Salmon, by Protix earlier this year as an example of the growing market, which may be niche but has potential. Dr Leek said it was likely that insects would be allowed to be fed to poultry in 2019/2020 and the challenge would be whether this would replace soymeal. Most likely products for the UK market would be the lesser or greater mealworm as dry material or the black soldier fly, house fly or blow fly. Insects can be fed on organic waste, improving food supply efficiencies and improving sustainable food supply chains. They also provided a number of opportunities in poultry feed, he said, including:

Being high in protein – suitable insects are around 40-60% crude protein
Having a high quality amino acid profile – better than vegetable protein sources
Being high in micro-nutrients

One issue however, was that they were quite a high source of calcium (2.5%-8%) which might represent a challenge to broiler growers. Dr Leek added that insect oil, as a by-product of insect processing for pet or aqua feed, might actually feature in poultry diets before insect protein. But the prevalence of soya in the supply chain, the slow progress of legislation in this area and consumer and retailer acceptance could all prove barriers. Volumes of insects needed to be commercially viable was also an issue, which might mean insect feeding to poultry remains a niche rather than a commodity.

Precautionary

The current EU legislative framework is still governed by the BSE crisis and TSE regulations but the move to allow the exception of non-ruminant processed animal protein in aquaculture feed has opened the door.

Rachel O’Connor, agriculture associate with Michelmore’s said the changes on 1 July 2017 permitted insect protein from 7 species to go into aquaculture feed (black soldier fly, house fly, yellow mealworm, lesser mealworm, house cricket, banded cricket and field cricket). This regulation (EU 2019/893) also covered a range of conditions, including record keeping, labelling, storage, methodology and contamination.

It also took away the provision, which required animal by-products, used for the production of processed animal protein, to be derived from a registered slaughterhouse – an issue that was clearly not feasible for insects.

Ms O’Connor highlighted that the EU Commissioner for Health and Food Safety, Vytenis Andriukaitis, had recently said the Commission was looking to authorise the use of insect proteins in feed for poultry in 2019, and potentially also pigs.

The popularity of insect meal as a new protein has taken off – find out about new developments, regulations and innovations.

Pest risk analysis for Black Soldier Fly
Risks posed by the introduction of the black soldier fly (Hermetia illucens) for protein production and waste management are minimal, according to leading entomologist Archie Murchie. Dr Murchie, senior scientific officer at the Agrifood and Biosciences Institute, Northern Ireland, told the conference that the fly was unlikely to persist in the wild in Ireland. Dr Murchie said the insect – originally from South America, native to south east US states and now established in southern and central Europe – had been found as far north as the Czech Republic but would not survive the cool, temperate climate of Ireland and the UK. “Larvae can survive down to 0°C for up to 4 hours but generally for mating is dependent on temperatures of 24°C and they need strong sunlight,” he said. There are, however, believed to be 47 varieties of native soldier fly in Great Britain and 32 in Ireland. These feed on dung heaps but they don’t pose any known disease transmission risk and have been found to reduce levels of E.coli and Salmonella. As a result, they are not considered a pest species or a particular threat to biodiversity.