Will you be able to feed waste to your insects, with the new EU regulations?
Food safety, Novel Foods and insect farming: the European Union is asking more from insect companies in 2019, with the new food laws and regulations.
You have already read on this blog how to start cricket farming on a small scale. Perhaps you have managed to earn some money following the advice of our DIY guide. And you could now be thinking about the next step.
If you are considering hopping onto the insect food production bandwagon, then this article is for you.
Here’s what you’ll discover:
- The edible insect market is very likely to triple its size by 2023
- What's the stand of the EU when it comes to edible insects
- Rules, Risks and Policies
- What are the goals of the new EU insect regulations
- 10 feeds of animal origin that you can serve to your insects
- Bugs, food waste and food waste regulation
- How does all of this mean for the small entrepreneur?
Is the edible insect market any good?
Yummy bugs are a fast growing new business sector with considerable potential in Europe: after Asia, this will be the second largest market for bug delicacies in the next few years, according to business analysts.
By 2023 it will have more than tripled its volume.
More and more innovative young companies are making the headlines, many of them after having started small.
If you see yourself as a future entopreneur, you should at this point invest some time in becoming familiar with the rules of the game to get legally into business.
Giving this option some serious thought?
Then you have to do a lot of homework.
Edible insects and the EU Legislation
The legal background for edible insects in the European Union is undergoing a series of changes.
We will help you with that: food laws and regulations are a complicated matter, but unavoidable for anyone planning to be in any type of food business in Europe today.
Let's start with the latest update from January 2019, that could have important consequences: the European Commission has published a proposal to introduce some specific new rules concerning food hygiene standards for edible insect products.
More specifically, what materials will be allowed as feed destined to insects for human consumption.
Fasten your seat-belts:
we are now going to try to make a complicated story simple.
What gets into your food gets into you
Insects are tiny.... so tiny that for some years they had half escaped the vigilant eye of the EU regulators.
Apart from jokes, one of the consequences of insects being so unusual as a food in Europe was that in the beginning there were no specific laws to regulate their farming, processing and placement on the market.
EU Novel food regulation
A Regulation on Novel Foods had been approved already in 1997 but its applicability to insects was not clear, so individual European countries took very different positions on what was allowed.
As for what happens to humans who eat insects, well, not such a common thing in Europe, so... there were not many scientific studies available on the consequences of entomophagy on the human organism.
Not enough for mama EU to feel completely at ease with her citizens starting to gobble up big quantities of bugs.
Food safety is the pillar of the modern food industry and the concern number one of EU food legislation
Risk Analysis from 2015
This is why in October 2015 the European Food Safety Agency (EFSA) published a first risk assessment on the use of insects as a source of protein for human consumption and animal feed.
It was necessary because the General Food Law of the EU requires all food laws and regulations to be based on a risk assessment.
The conclusion was as follows:
"the specific production methods, the substrate used, the stage of harvest, the insect species, as well as the methods used for further processing will all have an impact on the possible presence of biological and chemical contaminants in insect food and feed products."
In practice this meant:
"if you want us to allow you to sell your insects on the EU market, you will have to be VERY convincing in explaining to us in detail what measures you will take to ensure that they are safe to eat".
This information must be provided when applying to be authorized by the European Commission to place a new insect product on the market: since Jan 1st 2018, food products based on insects are considered Novel Foods (according to the new Regulation (EU) 2015/2283) and they need this specific authorization.
The dossier containing all relevant information on the production process undergoes a very detailed scrutiny before the Novel Food can be approved and added to the official list.
In January 2019 the Commission decided that something was still missing, and put forward a proposal to introduce a new section, addressing specifically insects for human consumption, to Regulation 853/2004 which establishes food hygiene standards.
What do the new EU regulations on insect food products want to achieve?
There are basically two main categories of issues that the Commission wants to regulate:
- the harmonization of the legal background across all the countries of the European Union (* a seamless common market is the goal, which means you will be able to sell your products in all the 28 EU countries with a single authorization)
- the health safety of citizens consuming edible insect products.
Foods of animal origin require special attention
Food of animal origin is an issue commanding special attention: after important shocks like the "mad cow disease" a few years ago, there is a strong awareness that you cannot feed just about anything to animals that you are going to eat.
This is why meat-and-bone meal from ruminants, for example, is not allowed as a source of protein in animal feed.
Some bugs will be fine with a vegetable-only diet, but crickets, for example, might need something more not to turn to cannibalism.
The more protein you feed to your critters, the more protein they will contain when you harvest them.
Continue reading and find out what you can and cannot do.
Feed them well and they will feed you well.
10 feeds of animal origin that you can serve to your insects
What can your bugs legally eat then?
If the Commission proposal is approved as it is now, some protein products of animal origin will be allowed as feed for farmed insects, specifically:
- blood products from non-ruminants;
- di-and tricalcium phosphate of animal origin;
- hydrolysed proteins from non-ruminants;
- hydrolysed proteins from hides and skins of ruminants;
- gelatine and collagen from non-ruminants;
- eggs and egg products;
- milk, milk based-products, milk-derived products and colostrum;
- honey; or
- rendered fats.
The above list is the exception to the general rule:
"The substrate for the feeding of the insects must only contain products of non-animal origin" (* point 3 of the Annex).
But what if I want to feed my home colony of crickets (who are well known omnivores, scavengers, and even... cannibals when they do not get enough proteins) also some chicken scraps from my kitchen or from the restaurant around the corner that I was making a deal with?
Sorry... looks like this will be confined to the field of home experiments.
Are at least vegetables scraps ok?
Well.... it is actually more tricky than that. Keep reading.
What about the circular economy? 3 re-cycle types of feed that could soon be banned for insects.
The news are not so good for all who were looking forward to the benefits of insect farming in a circular economy model: in other words, for the possibility to achieve two goals at once, help reduce the enormous quantities of food waste in Europe (20% of the total) and feed edible insects with them.
The proposal of the European Commission, namely, lists three types of feed that are not allowed in insect farming:
- catering waste;
- other waste.
The definitions of these "substrates" (as feeds for critters are referred to in the text) are contained in three more specific Regulations. According to them:
1.‘Manure’ means any excrement and/or urine of farmed animals other than farmed fish, with or without litter (as defined in point 20 of Article 3 of Regulation (EC), or Animal by-products Regulation 1069/2009);
2. ‘Catering waste’ means all waste food, including used cooking oil originating in restaurants, catering facilities and kitchens, including central kitchens and household kitchens (as defined in point 22 of Annex I to Regulation (EU) No 142/2011, containing health rules as regards animal by-products and derived products not intended for human consumption );
3. ‘Other waste’ means any substance or object which the holder discards or intends or is required to discard (as defined in point 1 of Article 3 of Directive 2008/98/EC, on waste).
Quite a lot of regulations to keep in mind!
Let's try to cut through the red tape and focus on the practical consequences that are of interest to us.
Manure is self-intuitive enough: it carries too high a risk of spreading pathogenes.
A good option for compost-producing red worms but not acceptable as feed destined to insects for human consumption.
So we will leave it aside.
"Catering waste" and "waste" as a broader category are another story.
What happened to the idea to recycle kitchen waste to feed bugs? It’s complicated
Formulated like this, the new rules would apparently exclude from the game all the enormous quantities of vegetable leftovers in agricultural farms, but also in supermarkets (AND restaurants and households).
There are actually several startup businesses around which have already got organized to use vegetable farm waste as a feed input for insect farms: will they be allowed to continue?
Someone HAS expressed concern for this possible exclusion of useful waste from the list of acceptable feeds for insects.
The objection has appeared on the page published by the European Commission under the title: "Specific hygiene rules for insects intended for human consumption".
In the feedback section dr. Gonçalo Costa, an entomology and taxonomy researcher at the University of Lisbon, states that:
"the insects’ true potential lies in their ability to consume organic side-streams and turn a often discarded product i.e freely defined as “waste” into a cog for a circular economy, reducing waste and producing a local valuable product".
His suggestion is to redefine the list by including the category of "bio-waste".
Here is where things become interesting, because the same Directive on waste has a separate definition for "bio-waste" and it reads:
“biodegradable garden and park waste, food and kitchen waste from households, restaurants, caterers and retail premises and comparable waste from food processing plants”.
Is there a contradiction with the "catering waste" definition in the other Directive? These Regulations seem to need a bit of streamlining.
In fact, the European Union is in the process of redefining its legislation on waste in general. In April 2018 the Commission published a notice by the title: "Guidelines for the feed use of food no longer intended for human consumption".
In simpler words:
The road from "food" to "waste" OR, in alternative, "feed" has more than one stop
As visualized it in the following flow chart:
What does all of that mean for the small insect enthusiasts?
Obviously, all these complications are a little above your head if you were just planning to do a little insect farming for fun at home, or to experiment with bugs' cuisine And to get rid of your kitchen scraps in the process.
As long as you are not trying to sell your products on the market, the only thing you have to worry about as a consequence of what you feed your insects is your own safety.
And that of your friends if you invite them over for an ento-dinner...
A nice hobby can sometimes grow into a small business, and a small business can be scaled up to a large business: some leading companies producing insects and insect feed and food products started really small and grew really fast!
Edible insect foods are in high demand and equally high are their prices, owing to the relatively small quantities that are available on the market at the moment.
All this means that in years to come the number of players on the market is likely to grow.
So don't be shy, go for it! Learning hands-on is usually extremely useful also for the success of later stages.
But keep in mind that once you decide to move on and get your products on the EU market, you will have to comply with its complicated legal system and highly set food hygiene and food safety standards.
Better then to get it right from the start.
Doing the maths
What our critters will in the end be allowed to eat will have one more vital set of consequences: on our wallet!
In terms of production costs for the future entrepreneur and retail price for the final consumer.
More in general, feed choices will have consequences on the sustainability issue that has brought edible insects under the limelight in the first place in recent years: their environmental footprint, so much lower than cattle.
The higher, more efficient, feed conversion ratio of insects as compared to beef, pork and poultry is only part of the story.
High hopes have been placed also on their potential as "recyclers". Bugs eat much less cereal feed, for example, that cows or chicken to produce the same quantity of food consumable by humans.
The real breakthrough though, will not be simply going on growing cereals to feed them to insects instead of cattle, but to use the bugs' full potential.
This implies that part of their diet should include vegetable scraps that farms, supermarkets, restaurants and households discard although they are still perfectly edible.
And what about WATER?
As all insect farmers know, their critters can get all their water needs satisfied by the moisture contained in their vegetable food. This in turn makes the ecological footprint for bugs even lower.
Let's have a look at what the companies members of the International Platform of Insects for Food and feed (IPIFF), the EU non-profit organization gathering major stakeholders of the sector, have been using as insect food so far and we will notice that some "recycling" is already part of the "farm to fork" chain:
"Former foodstuff": does this mean... waste? Or more elegantly put (as in the Commission's Guidelines from April 2018 we quoted above), "food no longer intended for human consumption"?
Yes. But not any kind of waste.
Do not be discouraged by this maze of definitions and rules: it is actually a good sign!
A sign that the European Union is taking the food waste problem seriously and would like to see it re-used as much as possible – including as feed for the rapidly growing edible insect industry - but without causing health hazards for its citizens.
More research is being carried out and the rules will surely be adapted or changed many more times in years to come.
A few more seasons will probably be necessary for the EU to eliminate contradictions and fill in loopholes in its legislative system, but clearly a big effort is under way to transform entomophagy from a somewhat adventurous and visionary niche into mature mainstream business, capable of offering EU citizens safe and reliable products.
There is much more to learn about all the rules that you will have to comply with if you want to go into business with your insect foodstuffs. Stay tuned – we will soon be back with more useful articles!
Crickster and food security standards
We at Crickster take your health very seriously! This is why the insects for our products are raised taking care that food laws and regulations are utterly complied with.
Our bugs have been kept on a healthy diet to make sure that they get to your table loaded with proteins and beneficial vitamins and minerals.
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