Legal barriers in the EU and other countries for using black soldier fly larvae as feed for farmed animals

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  • joeturner
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Re: Legal barriers in the EU and other countries for using black soldier fly larvae as feed for farmed animals

OK, the following appears to be the definitive answer to this question:

1. Insects are considered to be farmed animals when they're produced for the purposes of use in farmed animal feed.
2. Farmed animals cannot be fed farmed animals. Specified wastes which cannot be used include catering and aboitoir waste EC Regulation 1069/2009 Article 12&13 eur-lex.europa.eu/LexUriServ/LexUriServ....300:0001:0033:EN:PDF
3. Fish can now be fed insect derived feed EC Regulation EC 56/2013 eur-lex.europa.eu/LexUriServ/LexUriServ....021:0003:0016:EN:PDF
4. Farmed animals cannot be fed prohibited materials, including animal faeces EC Regulation 767/2009 see Annex III eur-lex.europa.eu/LexUriServ/LexUriServ....229:0001:0028:EN:PDF


So all of the above legislation would have to be changed to allow insects which have fed on specified waste (including manure, aboitoir waste, and catering waste) to be used in animal feed.

It does not appear that human faeces is being considered as an acceptable substrate for the growth of insects which will be fed to animals destined for humans. Also it appears that overseas suppliers will have to follow the same regulations.
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  • joeturner
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Re: Legal situation regarding use of BSF larvae as animal feed in Europe and South Africa

I have put the question to Prof Arnold Van Huis and his answer is that human faeces is a 'dead end' for the EU.

Please take note
all those working with BSFL in sanitation and thinking that you are getting an output of larvae you can feed to animals.

I am looking to get more verification of the EU's legal position today.

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Re: Legal situation regarding use of BSF larvae as animal feed in Europe and South Africa

In a new development which I've only just noticed:

"EU approval for insect derived pig and poultry feed may be six months away" says Prof Arnold Van Huis from Wageningen University according to this article

www.feednavigator.com/Regulation/EU-appr...y-be-six-months-away

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Re: Legal situation regarding use of BSF larvae as animal feed in Europe and South Africa

Just to update this, I have heard back from the PRoteINSECT project mentioned above.

They say that the organic matter substrate that they are considering in this project do not include human faeces. So I don't think this will have any effect on the developing BSFL-in-sanitation model.

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  • BioCycle
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Re: Legal situation regarding use of BSF larvae as animal feed in Europe and South Africa

Hi All

BSF feed is registered as a feed product in South Africa without reference to what the larvae has been fed, and is permissible in the USA depending on the waste that has been used to rear it on. In the EU there is an extensive lobby team, of which we are founding partners, and we anticipate 2015 change in law by member states as the issue is more of a technicality than ban. Quite simply 'all dead animals are forbidden to be fed to other animals for agricultural purposes except fish/fishmeal' it's just because there was no insect/magmeal when they drafted it.

See attached document for more information. Its title is
Work Package 5: Pro-Insect Platform in Europe
Deliverable 5.1 - Mapping Exercise Report with regard to current Legislation & Regulation: Europe and Africa & China

(the report was also mentioned already in the posts above)

Hope this helps

Cobus

A note on the scope of this report:
This Report maps the current situation regarding legislation and regulation in Europe, Africa and China concerning the use of ‘processed animal protein’ (PAP) from insects and by implication from household flies and black soldier flies the focus of PROteINSECT research, for use in animal feed for pigs, poultry and fish. Limited information has currently been gathered from China.

A note on the methodology used to compile this report:
Searches were performed on the EUR-lex website to find out about existing European legislation relevant to the use of insects in animal feed and food. Background information and relevant scientific studies were obtained by searching for key words in an academic journal database. Information on international food standards and guidelines was obtained from the Codex Alimentarius website (www.codexalimentarius.org/). Additional useful sources were obtained from the 2013 FAO report ‘Edible insects: Future prospects for food and feed security’ and the 2012 Wageningen UR report ‘Insects as a sustainable feed ingredient in pig and poultry diets - a feasibility study’.

PROteINSECT partners were invited to contribute information and sources, together with input from identified members of the project’s Stakeholder Advisory Board. The scope and organisation of the Report was agreed with the Co-ordinator at an early stage.

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  • joeturner
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Re: Legal situation regarding use of BSF larvae as animal feed in Europe and South Africa

BioCycle wrote: Hi All

BSF feed is registered as a feed product in South Africa without reference to what the larvae has been fed, and is permissible in the USA depending on the waste that has been used to rear it on. In the EU there is an extensive lobby team, of which we are founding partners, and we anticipate 2015 change in law by member states as the issue is more of a technicality than ban. Quite simply 'all dead animals are forbidden to be fed to other animals for agricultural purposes except fish/fishmeal' it's just because there was no insect/magmeal when they drafted it.


Thanks, but the question is still unclear. Insects can be fed to fish, I can see that there is an argument to have insects fed to other farm animals like chicken. But is there not still an issue about the substrate on which the insects have been fed? As I've said above, it seems to me that the EU is currently saying that animal (and presumably human) wastes cannot be used to feed animals in the food chain.

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Re: Black soldier fly (BSF) larvae for faecal sludge reduction - research in South Africa (with the company Agriprotein)

Having read in more detail the reports from PROTEInsect, they seem to be suggesting that aboittoir and other animal wastes (and manures) are currently excluded from allowable feedstuffs to farmed animals in the EU, which at present seem to suggest that only catering waste can be fed to animals. Obviously this has little relevance to insects, but they are suggesting that to allow waste-eating insects to enter the foodchain (and/or animal feed) would require a change of EU legislation. Currently it appears that insects can be fed to fish in the EU, but not if they've been feeding on animal waste. Even that does not seem to be 100% clear.

The more I think about it, the harder time I have believing that the EU would knowingly allow human faeces to be used as a substate at any point in the human food chain.

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Re: Black soldier fly (BSF) larvae for faecal sludge reduction - research in South Africa (with the company Agriprotein)

Thanks JFK, I saw that report, but for some reason didn't actually read it!

These sections are interesting:

There are several safety risks associated with the use of insects in food and feed that must be considered. Perhaps most significantly, insects pose microbial hazards by harbouring pathogens that can cause foodborne illness. In one study, microorganisms isolated from the body surface and gut wall of the common domestic housefly (Musca domestica) included four pathogenic species of bacteria and fungus (Banjo et al, 2005). Insects may also be unsafe for consumption due to the presence of toxins.

In order to ensure that insects comply with food and feed safety requirement, it is vital that measures are taken to minimise the hazards described here. Microbial hazards can be mitigated through a combination of processing techniques, such as drying, boiling and roasting, and correct storage at refrigeration temperature. Insect toxicity can be eliminated by strictly controlling farming conditions so that sources of chemical contaminants are not present. Allergic reactions to insects are likely to be a rare event but nevertheless labelling of products containing insect protein should warn of the potential risk (Belluco et al, 2013).


The impression given by this report is that although the use of insects in feed is now not totally out of the question in the EU, significant proof would be needed of the safety of processes and, quite possibly, additional EU legislation.

I don't see that the point about the substrate on which the insects are feeding has been addressed directly in this report.

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  • JFK
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Re: write-up from webinar 6 - black soldier fly research by Ian Banks

Hi all,
Very interesting discussion.
On legal aspects, you can check on PROteINSECT pages, they made a report on legal issues : www.proteinsect.eu/index.php?id=37
JF Kleinfinger

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Re: Black soldier fly (BSF) larvae for faecal sludge reduction - research in South Africa (with the company Agriprotein)

I have quickly rescanned the discussion above and I don't think this has been mentioned:

Ian Banks has a paper in a recent edition of the academic journal Tropical Medicine & International Health called "Growth rates of black soldier fly larvae fed on fresh human faeces and their implication for improving sanitation" see here .

Apologies if this has been mentioned above, but maybe it will be of interest to others.

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Re: Black soldier fly (BSF) larvae for faecal sludge reduction - research in South Africa (with the company Agriprotein)

It is EU Regulation 56/2013 from January 2013: see here

With the exception of fishmeal and compound feed containing fishmeal, which are already permitted for feeding non-ruminant animals, PAP from non-ruminant animals and feedingstuffs containing such PAP should therefore be reauthorised for feeding aquaculture animals. Strict requirements during the collection, transport and processing of those products should apply in order to avoid any risk of cross-contamination with ruminant protein. In addition, regular sampling and analysis of the PAP and the compound feed containing this PAP should be performed in order to verify the absence of cross-contamination with ruminant proteins.

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Re: Black soldier fly (BSF) larvae for faecal sludge reduction - research in South Africa (with the company Agriprotein)

Well it was reported in this Reuters article but I am trying to track down the actual EU rule change to confirm.
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