The 2021 WWF Report, ‘The Future of Feed: A WWF Roadmap to Accelerating Insect Protein in UK Feeds’ projected that “…the total demand for insect meal from the UK’s pig, poultry and salmon sectors could reach the region of 540,000 tonnes a year by 2050. Of this, around 240,000 tonnes of insect meal per year could be sourced from UK insect farms.”
The use of insects in our feed chains has huge potential in helping the transition to a circular economy. In particular, there ability to convert surplus food (which would otherwise be waste) into high quality protein to replace soymeal and fishmeal in animal feed. There is a role that insects perform so effectively that there is simply, no such thing as a waste in nature.
In the UK, we are et to see the industry operating at a scale that reflects the value of the sector and the role it has to play in making the feed sector more sustainable and addressing food security issues. Navigating the legislation which governs the sector has long been identified as one of the biggest challenges to scaling up. The 2021 WWF Report concluded: “Existing legislation is placing a stranglehold on insect farming, restricting what materials insects can be reared from and preventing insect meal from being used in pig and poultry feed.”
The UK’s feed and food laws remain comprised of EU legislation which continues to apply in the UK as part of the body of “Retained EU Law”. The UK adopted EU food and feed legislation into UK domestic law as it was in force on 31 December 2020.
Fundamentally, the legislation:
Recent legislative developments at an EU level are intended to pave the way for the development of the industry by lifting certain unnecessary regulatory restrictions. Crucially, these developments create an unlevel playing field between the EU and GB markets as far as regulation is concerned. So where does the UK stand?
In 2017 the European Commission passed legislation authorising the use of processed animal protein from seven species of insects as feed in aquaculture, these were:
This authorisation marked a significant acknowledgment of the future role insect protein has to play in the feed market. The legislation was adopted as part of GB domestic legislation.
With effect from November 2021, the European Commission expanded this list, adding Silkworm (Bombyx mori). As the expansion of the list was post 31 December 2020, it does not apply in GB.
By far the most significant change is that from September 2021, the European Commission amended the Feed Ban Rules to permit certain non-ruminant processed animal protein for use in pig and poultry feed.
Crucially, the legislation highlights that the risk of BSE transmission from non-ruminants to non-ruminants is negligible if intra-species recycling is avoided. The decision to amend the Feed Ban Rules is supported by scientific developments in sampling and analysis in order to reduce the risk of cross-contamination and intra-species recycling.
On that basis, the legislation permits the feeding of processed animal protein derived from porcine animals to poultry and vice versa. In addition, the Feed Ban Rules have been amended to permit the use of processed insect protein in poultry and pig feed under the same conditions as permitted for feeding aquaculture animals and limited to the (now eight) species of insects mentioned above. The legislation acknowledges that poultry are insectivorous animals and porcine animals are omnivorous and as such there are no concerns with insect protein as a feed material.
This significant amendment to the Feed Ban Rules does not, however, take effect in GB as it was introduced after 31 December 2020. It is expected, however, that GB legislation will be amended in the future to permit the use of processed insect protein in poultry and pig feed. The 2021 WWF Report acknowledged that: “…if legislation were to be amended to permit the use of processed insect protein in pig and poultry diets, a far larger market could be accessed and insect farming could become an attractive investment, generating returns for UK industry.” The question is – when will this happen?
Frass, which is the mix of excreta, feeding substrate and other matter left once farmed insects are ‘harvested’, is a valuable co-product. In November 2021, the European Commission introduced legislation regularising the use of insect frass as fertiliser. At an EU level, the standards for placing frass on the market are now the same as those which apply to processed animal manure (including a requirement for frass so be treated at 70 degrees Celsius for one hour).
This is an important step in recognising frass as a valuable co-product, particularly at a time when the cost of inputs like synthetic fertiliser are so high. It also demonstrates that there is an anticipation that as the industry develops, the volume of frass will increase considerably.
The 2021 WWF Report recorded that: “…Evidence from other countries shows that a strong domestic market for frass in agriculture and horticulture provides an important secondary revenue stream within the overall insect farming business model.”
The processing and sale of frass for fertiliser or soil conditioner in GB does not sit uncomfortably within the existing regulations for dealing with manure, despite its unconventional composition. At some point, however, it will be necessary to consider how the legislation should be framed to recognise the special nature of frass, particularly if current prescribed processes (such as heat treatment) inhibit its beneficial properties.
According to the International Platform for Insects as Food and Feed the benefits of using frass include:
“…provides macro- and micro-nutrients in soil…”
“…supplies organic matter that enhances mircobiological activity in soil…”
“…improves the [soil’s] water holding capacity…”
“…increases plant tolerance to abiotic stresses and resistance to pathogens…”
The value of frass as a fertiliser further demonstrates the circular properties of this industry. The value of frass is now considered to be on-par with insect protein itself.
Ensuring that the industry is able to operate within an effective regulatory regime that recognises the role insects play as part of the circular economy AND protects and reassures consumers, is key to supporting the growth of the industry. One area that the EU is yet to address through regulatory change, is the range of substrates that insects may be reared on in order maximise the impact of the industry. The WWF Report set out that: “Research is required to identify the feedstock substrates with the greatest potential for use, which meet product safety and quality needs while also minimising environmental impact.”
Whilst the UK may have fallen behind in relation to some aspects of legislation in this area, reviewing policies related to frass and permitted substrates remain areas of opportunity for the UK protein industry to advance in.
This article is for general information only and does not, and is not intended to, amount to legal advice and should not be relied upon as such. If you have any questions relating to your particular circumstances, you should seek independent legal advice.
Michelmores are looking forward to putting on another Agriculture Roadshow, between 3-7 February 2025. Following the success of our tour last year, we are going...
