The production and distribution of BSF products used for food production through feed (e.g. fish, eggs, meat) are regulated in order to protect human and animal health.
Other, currently more niche markets, such as BSF-based products for applications in the cosmetics, biofuel and biobased industries (e.g. chitin, bioplastics) have no or fewer restrictions and are therefore not discussed further here.
The aim of regulation is to prevent contaminants from entering the food system and to produce nutritious and safe food (Lähteenmäki-Uutela et al., 2021).
Parallel to the development of the BSF sector, the last decade has seen the implementation or drafting of regulations worldwide. In many regions, this has been initiated or supported by academia, BSF companies and regional insect associations, including the following:
Asian Food and Feed Insect Association (AFFIA)
Insect Protein Association of Australia (IPAA)
North American Coalition for Insect Agriculture (NACIA)
International Platform of Insects for Food and Feed (IPIFF)
Feed production organisations.
Depending on the country, these regulations may be defined and enforced by various regulatory bodies, including those dealing with food safety, veterinary, environment and agriculture. They may include the following:
Hygiene standards for insect breeding and the production of insect products
The type of insect allowed for breeding as feed
The raw material allowed for rearing BSF larvae as feed
Processing methods for BSF products (e.g. determined heat, time and pressure) and/or quality standards (e.g. concentration of heavy metals, mycotoxins and indicator microbial organisms)
The form of BSF products that can be used for pets and livestock
The type of livestock that can be fed BFSL-based feeds
In general, the BSF sector has welcomed the establishment of regulations because they can give clear direction on how to operate, even though they may be limiting (e.g., for raw materials, restriction on feeding BSF products to certain animals, heat treatment of ash in Europe). This is particularly important for capital-intensive and industrial-scale projects. Obtaining all permits can take from several weeks to 9-18 months or more. In addition to these BSF-specific regulations, other licences may be required, including the general business licence, feed production licence, environmental impact assessment, HACCP, emissions licence (e.g. water, wastewater, CO2, NH4, particulate matter) and waste transport and treatment licence.
European Union - Regulatory framework:
Food safety and thus most regulations concerning the rearing of BSF larvae and their use as feed are harmonised in all 27 member states (IPIFF 2022). The EU has some of the most comprehensive but also most stringent regulations.
Information on the 26 relevant EU regulations is available in the IPIFF Guide on Good Hygiene Practices (IPIFF 2022). With regard to raw materials, BSF larvae are considered farm animals. Consequently, they may only be reared with certified raw materials for livestock feed and with traceable food and pre-consumer by-products (including eggs and milk, but strictly no fish or meat). Food waste (e.g. from households, restaurants, canteens), fertilisers, sewage sludge and slaughterhouses are not permitted. With regard to animals for which BSF products may be used, oils from BSF larvae may be used to feed all animals, including ruminants. The feeding of live larvae to non-ruminants is not harmonised throughout the EU and it is up to local authorities who may allow it (e.g. the Netherlands) or prevent it. Protein meal falls under processed animal protein (PAP) legislation. TSE (transmissible spongiform encephalopathies) legislation (Regulation (EC) No 999/2001) prohibits the use of any PAP if it is intended for the feeding of ruminants and non-ruminant farmed animals (excluding fur animals). However, particular legislation has permitted the use of insect protein meal (insect PAPs) in aquaculture (from 2017, Regulation (EU) 2017/893 amending Annex IV, Section F of Regulation (EC) No 999/2001) and for pigs and poultry (from 2021, Regulation 2021/1372 amending Annex IV of Regulation (EC) No 999/2001). Consequently, at the time of writing, protein meal is permitted as feed for domestic animals, pigs and poultry. The EU also has a specific regulation regarding ash. It may only be placed on the EU market after heat treatment at 70°C for one hour.
Us and Canada - Regulatory Framework:
The Food and Drug Administration (FDA) and the Association of American Feed Control Officials (AAFCO) are the most important bodies regarding BSF larvae as feed. In the United States, feed regulations are enforced by state and federal officials who provide expertise in animal science, animal nutrition, feed label compliance, field operations for inspection personnel and programme administration. AAFCO membership includes not only state and federal officials from the United States, but has grown to include international members such as Canada and Costa Rica. The AAFCO has authorised the use of whole dried BSF larvae and protein meal in aquaculture for salmonids such as salmon, trout and char (Lähteenmäki-Uutela et al., 2021). BSF larvae can only be reared on materials approved for feed production (i.e. approved as generally recognised as safe (GRAS)), including pre-consumer food waste and other by-products of food production, such as brewers' spent grain. Several states also authorise insect-based pet foods, while other states await AAFCO and FDA decisions. Pet food does not have to comply with all AAFCO regulations, as it is not a complete source of nutrition (Lähteenmäki-Uutela et al., 2021). The interests of the insect industry in North America are represented by the North American Coalition for Insect Agriculture (NACIA).
Australia - Regulatory framework:
Australia and New Zealand do not have autonomous legislation or specific government regulations on insect farming, but the Insect Protein Association of Australia (IPAA) has developed guidelines for its members (Lähteenmäki-Uutela et al., 2021). Non-members of the IPAA are not bound by the rules, which have not yet been made publicly available. BSF larvae can be used as aquaculture feed in all states and as poultry feed in NSW, ACT, Tasmania, Victoria and Western Australia. Insects used as feed must not be fed meat, manure or kitchen waste. Live, untreated (heat-treated) BSF larvae are not allowed in Australia. In Australia, however, pet food is self-regulated with voluntary industry standards from the Pet Food Industry Association of Australia (PFIAA). In Australia, the Insect Protein Association of Australia (IPAA) campaigns for the Australian insect industry to become a world leader in food and feed.