Regulations on insects as food and feed: a global comparison
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Wageningen Academic
Journal of Insects as Food and Feed, 2021; 7(5): 849-856 P u b l i s h e r s
SPECIAL ISSUE:Advancement of insects as food and feed in a circular economy
https://www.wageningenacademic.com/doi/pdf/10.3920/JIFF2020.0066 - Monday, September 20, 2021 2:08:03 AM - Wageningen University and Research Library IP Address:137.224.11.139
Regulations on insects as food and feed: a global comparison
A. Lähteenmäki-Uutela1*, S.B Marimuthu2 and N. Meijer3
1Finnish Environment Institute, Latokartanonkaari 11, 00790 Helsinki, Finland; 2School of Law, University of New England,
Armidale, NSW, Australia; 3Wageningen Food Safety Research, Akkermaalsbos 2, 6708 WB, Wageningen, the Netherlands;
anu.lahteenmaki-uutela@syke.fi
Received: 7 July 2020 / Accepted: 18 December 2020
© 2021 Wageningen Academic Publishers
OPEN ACCESS REVIEW ARTICLE
Abstract
Insects, as a food and or feed source, represent an emerging protein source relevant to farmers, feed companies,
food companies and food marketers globally. The growth of this industry is somewhat restricted due to outdated
food and feed regulations covering insect use. The regulations also do not allow the use of all potential insects as
food and feed. Governments aim to ensure food and feed safety, and each country has its own substantive and
procedural rules for this purpose. However, the regulatory demands and differences between countries complicate
the international marketing strategies for insect products. Food and feed regulation are separate; feed regulation
may allow insect usage even when they are not allowed as food. Some countries have specific rules for novel foods,
while others do not. This paper compares insect food and feed regulation of the primary production and marketing
areas: the European Union, the United States, Canada, and Australia. In addition, the situation in selected countries
in Central and South America, Asia and Africa is also discussed.
Keywords: food law, feed law, regulations
1. Introduction familiar ones. The main legal question with insects is about
how the risks involved may be mitigated through product
This is a comparative review on the global regulations safety rules. If specific government standards are lacking,
on insects as food and feed. Earlier reviews on legislation companies may decide to rely on the existing industry
specific to the production and marketing of insects for practices or the private standards as guidance or they
food and feed have been published by Lähteenmäki- may decide to postpone further business investment until
Uutela et al. (2017) and Lähteenmäki-Uutela et al. (2018). transparent rules appear.
These publications are used as a starting point for this
publication. The review aims to cover all main markets This review limits itself to general food and feed safety law,
interesting for the global insect business. In comparison because it is the most central issue for the insect business.
to the above-mentioned legal reviews, this paper focuses Producers and marketers need to know which insects and
on legal developments between 2018 and 2020 as well as insect-based ingredients are allowed for which end use.
adds some new countries where interest in insect food and This paper does not discuss production animal welfare,
feed is on the rise and where regulations therefore need genetic modification or gene editing of insects, food and
to be considered. feed product labelling (although allergen labelling is an
important part of food safety legislation), or nutrition and
Legal issues can arise at various stages of the production, health claims on insect products. Materials and methods
processing, and marketing cycle. Insects can grow on are briefly discussed in Section 2. Sections 3 to 8 discuss
various substrates including manure and bio-waste, but regulations in the European Union, North America, Central
there are risks in bringing such insects into the food chain. and South America, Australia, Asia, and Africa. Section 9
Insects that are novel as food and feed may be riskier than presents the conclusions.
ISSN 2352-4588 online, DOI 10.3920/JIFF2020.0066849A. Lähteenmäki-Uutela et al.
2. Materials and methods a new Section in Annex III of Regulation No 853/2004.
At its core, the draft Regulation does not introduce any
Comparative reviews on legislation specific to the new provisions precisely for insects, but rather reiterates
https://www.wageningenacademic.com/doi/pdf/10.3920/JIFF2020.0066 - Monday, September 20, 2021 2:08:03 AM - Wageningen University and Research Library IP Address:137.224.11.139
production and marketing of insects for food and feed have rules from various other legislation that already applied
already been published by Lähteenmäki-Uutela et al. (2017) previously. Specifically, insects must be approved as a
and Lähteenmäki-Uutela et al. (2018). These publications novel food under Regulation (EU) No 2015/2283 (Article
were used as a starting point for this publication, which is 3 of the draft Regulation). In addition, insects may only
focused on legal developments between 2018 and 2020. be reared on substrates of vegetable origin or specifically
The recent legal developments were tracked through allowed materials of animal origin such as fishmeal and
government web pages, publications of insect industry hydrolysed proteins from non-ruminants (Article 4 of
associations, and food and feed industry news. the draft Regulation), but this was already the case under
Regulation (EC) No 1069/2009 and No 142/2011. Finally,
3. European Union according to the draft Regulation (Article 5), the ‘substrate
for the feeding of insects must not contain manure, catering
In terms of insects as food for human consumption, waste or other waste’ – but this was already the case under
provisions placing insects within the scope of Regulation Regulation (EC) No 1069/2009. As of October 2020, this
(EU) 2015/2283 on novel foods have been applicable since draft Regulation has yet to be implemented.
2018. Under this new Regulation, insect food products
may only be marketed when authorised after a safety On the executive front, the European Commission’s (EC)
assessment by the European Food Safety Authority (EFSA). Directorate-General Health and Food Safety (DG SANTE)
At this time (October 2020), applications for food products audited the French (DG SANTE, 2019) and Netherlands
from the following insect species have been submitted: (DG SANTE, 2018) official control systems for reared
house cricket (Acheta domesticus), banded/tropical house insects. Although these audit reports are not legislative
cricket (Gryllodes sigillatus), lesser mealworm (Alphitobius in nature and recommendations are primarily intended
diaperinus), black soldier fly (Hermetia illucens), honey bee for the authorities, they do provide an insight into the
(Apis mellifera), migratory locust/grasshopper (Locusta legal requirements for insect rearing companies. Areas
migratoria), and yellow mealworm (Tenebrio molitor) covered by the audit reports included the approval process
(EC, n.d.). The first of EFSA’s safety assessments are of new establishments, microbiological testing, and required
expected to be published soon. documentation. A report aimed explicit for the insect
rearing industry is a ‘Guide on Good Hygiene Practices’,
While waiting for the EFSA assessments and thereafter published by the International Platform of Insects for Food
Commission decisions on novel food applications, a and Feed (IPIFF). Formal endorsement of this guidance
transitional period applies for whole insects and their document by the EC and Member States is pending.
preparation. This means that insect foods which had
been lawfully marketed on 1 January 2018, and for which In the context of insects for animal feed, one of the most
an application or notification was submitted by January critical changes in 2017 was introduced by Regulation
2019, may continue to be marketed until the Commission (EU) No 2017/893. This act amended Regulations (EC) No
hands down its decision on the respective application or 999/2001 and (EU) No 142/2011, allowing the feeding of
notification. This means that several insect species may seven insect species to aquaculture animals (black soldier fly
continue to be sold as food in Europe without novel food (H. illucens), common housefly (Musca domestica), yellow
authorisation. On 1st October 2020, the European Court mealworm (T. molitor), lesser mealworm (A. diaperinus),
of Justice gave its ruling in the case C-526/19 stating that house cricket (A. domesticus), banded cricket (G. sigillatus)
whole insects were outside the old Novel Food Regulation. and field cricket (Gryllus assimilis)). Regulation (EU) No
This means the transitional measures for whole insects 2017/893 removed the requirement for reared insects
had to be expanded to all EU countries. The case was that ‘products of animal origin must be sourced from a
initially brought against two French ministries by company registered slaughterhouse’, because insect rearing facilities
Entoma SAS, and the Supreme Administrative Court of (where the insects are generally also ‘slaughtered’), could not
France requested a preliminary ruling from the European comply with the requirements specific to slaughterhouses.
Court of Justice. Finally, Regulation (EU) No 2019/1981 introduced a list
of third countries that were authorised to export insect
Specific hygiene rules for insects intended for human products complying with the mentioned Regulation (EU)
consumption are currently being considered: a draft No 2017/893.
Regulation, amending Regulation (EC) No 853/2004, was
published for public comment in 2018 (Ares(2019)382900). Significant legislative changes regarding insects are
The feedback period ended in February 2019 with adoption required to be implemented in the future to overcome
scheduled for Q1 2019. The draft Regulation would add current barriers to the growth of the insect industry. In DG
850 Journal of Insects as Food and Feed 7(5) Regulations on insects as food and feed
SANTE’s ‘strategic safety concept for insects as feed’ (DG in robotics, automation, sensor technology and data
SANTE, 2017), two primary legal barriers for the insect aggregation from the start. (Shockley et al., 2018).
rearing industry were identified. Firstly, it is prohibited
https://www.wageningenacademic.com/doi/pdf/10.3920/JIFF2020.0066 - Monday, September 20, 2021 2:08:03 AM - Wageningen University and Research Library IP Address:137.224.11.139
to use former foodstuffs containing meat or fish as feed In the United States, governing insect food is under the
materials for insects, and secondly it is not allowed to feed stewardship of the US Food and Drug Administration
processed animal proteins from insects to pigs and poultry. (FDA). Already in 2013, the FDA gave its ‘response to
According to the SANTE document, before the first barrier inquiry’ that represented their thinking on insect food.
can be lifted, it is necessary that ‘operational and validated It stated that insects are considered food under the Food,
analytical techniques’ for differentiating between insect Drug, and Cosmetic Act (United States Code, Title 21), if
material and other animals are available. Work on these that is their intended use. According to the Act, food must
methods is ongoing. For the second barrier, it is indicated be clean and wholesome (i.e. free from filth, pathogens,
that allowing any additional feed materials for insects toxins), must have been produced, packaged, stored,
‘would require a robust EFSA opinion assessing the risk and transported under sanitary conditions, and must
for human and animal health and recommending measures be appropriately labelled (Sec. 403). Insect-raising for
to ensure that such risk is negligible’ (DG SANTE, 2017). In human food must follow good manufacturing practices
February 2020, the Netherlands Food and Product Safety (cGMP, 21CFR110). Insects raised for animal feed cannot
Authority’s Bureau for Risk Assessment (NVWA-BuRo) be diverted to human food. Insects collected from the
advised the Dutch Ministry of Agriculture to propose wild cannot be sold as food. If insects are not sold as such,
an EU amendment to remove these two barriers. The but altered or used as a food ingredient, they may require
change would allow the use of insects as feed to an animal food additive authorisation. An insect protein is a food
providing that the insects have not being reared on former additive, unless it has GRAS status (generally recognised
foodstuffs containing meat of the same species (e.g. insects as safe). (Lähteenmäki-Uutela et al., 2018). GRAS and
reared on pig sourced meal are not subsequently fed to food additive petition (FAP) are two equally legitimate
those same species again) (NVWA-BuRo, 2020). In a note and parallel processes of compliance to the US law on food
accompanying the report, the agency’s Inspector General ingredients. GRAS is basically a self-approval system, and
reiterated that the prerequisites for lifting these barriers, FAP is government managed. A company may itself make
as mentioned in the 2017 DG SANTE Safety Concept a GRAS determination. A GRAS notice can be submitted
document, should be met first (IG-NVWA, 2020). to FDA for review, but there is no legal obligation to do
so. According to Burdock Group, GRAS can offer a lower
Summarising the European legal situation, the substrate cost and a faster route to market. The burden of proof
options on which insects may be reared are still restricted for safety is the same regardless of the process (FAP or
to those materials that are also permitted for other livestock GRAS). In both processes, the approval is for the specific
species. Developments to ease some of these restrictions use of the ingredient, not for the ingredient per se (https://
are ongoing, but legislative changes are not expected to be burdockgroup.com/).
implemented in the short-term. Since 2017, aquaculture
animals have been allowed to be fed with insect meal, the According to the Food, Drug and Cosmetic Act, animal
feeding insects to pets was already permitted. Legislative foods must be safe, produced under sanitary conditions,
changes are anticipated to allow the feeding of insects to and contain no harmful or deleterious substances. Many
more animals such as poultry and pigs, but the timeline for states base their feed regulations on recommendations
these changes is unclear. Novel food applications have been on the Association of American Feed Control Officials
submitted, but at the time of writing, no safety assessment (AAFCO). The AAFCO has established an ingredients
reports have been published by the EFSA. The European definition for only one insect species as an animal
Court of Justice ruling on the non-applicability of the old food ingredient for livestock feed. The black soldier fly
novel food regulation to whole insects somewhat changes (H. illucens) larvae, including dried whole larvae (since
the regulatory landscape as it extends the transitional period 2016) and black soldier fly meal (since 2018) is permitted
for whole insects to all EU member states. for use in feed for aquaculture for salmonids such as salmon,
trout and char. The FDA has reviewed and approved the
4. North America: United States and Canada AAFCO’s decision. Notably, the black soldier fly larvae can
be reared on approved feed-grade materials, including pre-
In many parts of North America, insects have traditionally consumer food waste as a substrate, as well as other food
been used as a part of food culture. The production of manufacturing by-products such as spent brewery grains
insects for the food and feed industries started to expand and other feed grade materials. (Lähteenmäki-Uutela et
after 2012. The modern insect industry had its basis in al., 2018). Several states also allow insect-based pet foods,
companies that had already grown crickets and mealworms while other states wait for AATCO and FDA decisions. Pet
for pet food. In order to avoid high labour costs, many treats do not have to comply with all AAFCO regulations,
United States and Canadian insect farms have invested as they are not a source of complete nutrition.
Journal of Insects as Food and Feed 7(5) 851A. Lähteenmäki-Uutela et al.
In Canada, the safety and nutritional adequacy of novel beetles (Cerambicidae), larvae of ‘escamoles’ (Liometopum
foods must be evaluated before they enter the market apiculatum), and ant eggs. These insects should be collected
(Canada Gazette Part II, Division 28: Novel Foods, October from areas of organic production or in ecosystems with
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27, 1999). Novel foods must be notified to Health Canada. little or no human intervention having no contact with
If there is an international history of safe consumption, a prohibited substances. The Organic Plan or an equivalent
food is not considered novel. A history of safe use means the document should demonstrate that the collection, farming,
food has been an ongoing part of the diet for a number of catching, limiting and processing of insects does not alter
generations in a large, genetically diverse human population or influence the ecosystem. A record on the history of the
where it has been used in ways and at levels, which are site or an Organic Plan must be kept proving that the areas
similar to those expected or intended in Canada (Health of collection, farming or catching have not been subject to
Canada, 2006). Crickets are not a novel food in Canada, treatment by prohibited substances.
and there are large cricket breeders in the country.
Brazilian researchers, farmers and companies are
Novel feed ingredients, i.e. feed ingredients not already increasingly interested in using insects as food and feed,
listed in Schedules IV and V of the Feeds Regulations, particularly in replacing soybean meal with black soldier
must be authorised in Canada. Each insect species, fly meal to feed the poultry. As Brazil is the leading global
rearing condition, and livestock species needs separate exporter of poultry, increasing the sustainability of the
authorisation. The Canadian Food Inspection Agency is Brazilian poultry industry would be significant (Allegretti
responsible for the pre-market assessment of new feed et al., 2018). Brazilian feed law does not yet foresee insects
ingredients and the registrations of feed products. Black as animal feed. According to Allegretti et al. (2018), Brazil
soldier fly products have been authorised to feed broiler tends to follow Codex Alimentarius standards.
chickens, salmonids, tilapia and poultry including chickens,
ducks, geese, and turkey (Lähteenmäki-Uutela et al., 2018). In Argentina, there is interest for example in adding cricket
Pet foods are another regulatory category. Black soldier fly flour to foods. The government has notified the nascent
larvae, mealworms, and silkworm pupae are sold as pet industry that insect food is currently not covered by the
food in Canada. national Food Code. An application to add insects to
the Food Code must be submitted to the National Food
5. Central and South America: Mexico, Brazil Commission. All packaged food must also have the approval
and Argentina of the National Administration of Medicines, Food and
Medical Technology (Anmat) (Crespo, 2019).
In Mexico, many different insects are used as food and
insects have also been used for medicinal purposes. Insects 6. Australia
are mainly collected from the wild. (González and Contreras,
2009). Mexico’s food safety laws are the responsibility Save for indigenous Australians, the protein consumption
of two government secretaries, SSA (Health Secretary) of the average Australian, which has been predominately
and SAGARPA (Agriculture, Cattle, Rural Development, meat, does not include insects. The indigenous Australian
Fishing and Feeding Secretary). The SSA mainly focuses diet, also termed as ‘bush tucker diet’ comprises of various
on processed food and SAGARPA on primary production. insects including witchery grubs, Bogong moths, termites,
The General Health Law, the Federal Vegetal Health and beetles, honeypot ants and native honey bees. (Yen, 2005).
Animal Law, and the Products and Services Sanitary Control
Regulation are three most important regulations. (Leon and Australia or New Zealand do not have a standalone
Paz, 2013.) All health-related products and services are legislation or specific government regulations on insect
regulated through mandatory standards called Normas farming. Insect Protein Association of Australia (IPAA)
Oficiales Mexicanas (NOMs). NOMs are revised at least has developed guidelines for its members (https://www.
every five years. At the time of writing, there are not yet insectproteinassoc.com). Non-members are not bound by
specific NOMs for insect food or insect feed in Mexico. the rules, and they are yet to be made available for public
General NOMs apply, e.g. the Norma Oficial Mexicana access. Insect food is regulated under Standard 1.5.1 of the
NOM-251-SSA1-2009 on the hygienic standards for foods, Food Standard Code as a category of novel food. These
beverages and dietary supplements. are non-traditional foods, the safety of which has not
previously been established and which therefore require
Mexico’s Organic Products Law and regulations for organic assessment. Three species of insects are categorised as
production were implemented in April 2017. There is a non-novel, namely: (1) super mealworm (Zophobas morio);
regulatory category for organic insect food in Mexico, (2) house cricket (A. domesticus); and (3) mealworm beetle
including an indicative list of the species and their life stages (T. molitor). Beetles, grasshoppers, butterflies, moths, bees,
concerned: eggs, larvae, nymphs, and adult insects of the bugs and dragonflies may also be consumed, although they
maguey worm (Aegiale hesperiaris), larvae of longhorn are not allowed to be sold.
852 Journal of Insects as Food and Feed 7(5) Regulations on insects as food and feed
Before a novel food is sold in Australia and New Zealand, These two codes and standards are applicable to feed
a thorough risk-based assessment process is carried out production in both Australia and New Zealand. Insects
that considers, amongst other things, ‘toxicological and may be used as feed for aquaculture in all states, and as feed
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nutritional issues’ of its chemistry and consumption for poultry in NSW, ACT, Tasmania, Victoria and Western
patterns. Ordinarily, a novel food will have to be listed Australia. Insects used for feed are not to be fed with meat,
in the Standard before it can be sold as food or used as a manure and catering waste, and raw insects (live and
food ingredient. Where it is not listed, an application can untreated by heat) for feed are not permitted in Australia
be forwarded to Food Standards Australia New Zealand (DiGiacomo et al., 2019). According to IPAA, the insect
(FSANZ), who will then include the novel food in the list for the feed industry in Australia comprises of five larger
after a pre-market safety assessment. There are provisions commercial fly farms and a variety of smaller operations
to allow ‘first to market advantage’: FSANZ extends, upon that are starting research and developing processes.
request being made, an exclusive permission to new owners
of novel food or novel ingredients in a specific brand or class Pet food in Australia is self-regulated with voluntary
for a period of 15 months. This does not preclude other industry standards of the Pet Food Industry Association
applicants seeking approval of their own different brand. of Australia (PFIAA) through its Australian Standard (AS
Imported novel foods are governed under the ‘Imported 5812-2017) for the Manufacturing and Marketing of Pet
Food Control Act’ 1992, ‘Biosecurity Act’ 2015 and ‘Food Food regulation for the pet food industry.
Standard Code’. The Department of Agriculture enforces
the ‘Food Standards Code’ at the border for imported food. 7. Asia: China, Japan and Thailand
In Australia, the edible food industry continues to grow The Chinese have used insects for thousands of years.
(Maxabella, 2019), despite there being only a limited choice Several Chinese medicines and health foods are based on
of insects permitted for sale. There are more than 50 insect insects. Honey bee larvae are used as a sedative and as an
farmers across Australia (Jones, 2019) as well as several anti-inflammatory medicine; male silkmoths and male
sellers specialising in edible insects (GrupsUP, 2020). The silkworms are sold for strengthening kidneys; termites are
‘Edible Bug Shop’ claims to produce and sell 200 kilograms used for anti-aging purposes; and black ants for improving
of insects a week to the domestic market (Black, 2020). immunity (Lähteenmäki-Uutela et al., 2017). China has a
Insects are sold in a variety of forms – sweet and savoury long tradition in silk production and is the world’s largest
snacks, tea leaves, candy, dukka, marshmallow, cricket silk producer. New food raw materials, including insect
powders, pasta powder, tortillas chips, white chocolates protein, require authorisation from the Ministry of Health.
and more (https://ediblebugshop.com.au). Though in Authorisations have general applicability: if a new food raw
Australia insects have been traditionally consumed by the material is added to the Food Materials Catalogue, all food
indigenous community (Yen, 2005), the culture of adapting producers can use the material (Sun, 2015: 445). According
to eating insects amongst the Australian majority is recent. to Belluco et al. (2013), silkworm pupae were authorised
Insects are increasingly consumed for their nutritional and as a new food ingredient and according to Shen (2014),
environmental benefits (Edwards and Ranasighe, 2019). earthworm protein powder has been authorised. New feed
raw materials also need to be authorised, and authorised
Animal feed materials and ingredients which are fed feed materials are added to the Feed Materials Catalogue.
as part of the normal diet of an animal do not require
registration in Australia. Australia has strict rules on According to Mitsuhashi (1997), several different insects
animal feed, however. Ruminant animals are not to be fed are traditional foods in Japan. These include Oxya yezoensis
with meat, including meat and bone meal, derived from or Oxya japonica, the larvae and pupae of a wasp, Vespula
all vertebrates, including fish and birds. Such restrictions lewisi, and the pupae and female adults after oviposition
are in place to safeguard against risk of bovine spongiform of the domestic silkmoth, Bombyx mori. These insects
encephalopathy (BSE or mad cow disease) or transmissible have been cooked with soy sauce and sugar and sold as
spongiform encephalopathies (Food Standard, 2020). This canned foods. Larvae of the dobsonfly, Protohermes grandis
ruminant feed ban is governed under the legislation in all (Neuroptera) have been used as traditional medicine
states and territories and is reinforced by industry-based (Mitsuhashi, 1997). In Japan, normal novel foods do not
quality assurance programs such as the FeedSafe Standard require pre-market authorisation, while novel additives do.
(Animal Health Australia, 2020). Feed ingredients and Food safety is under the responsibility of the Ministry of
additive suppliers in Australia are represented by the Feed Health, Safety and Welfare. Feed law is another issue. The
Ingredients and Additives Association Australia (FIAAA). Ministry of Agriculture, Forestry and Fisheries has given
This organisation regulates its industry via the Australian the Act on Safety Assurance and Quality Improvement of
New Zealand Code of Practice for Animal Feed Ingredients Feeds, which includes the maximum limits for pesticide
and Additive Suppliers (the FIAAA Code of Practice) and residues, heavy metals, mycotoxins and melamine. Feed
the FeedSafe Standard (https://fiaaa.com.au/about/#bg). manufacturers, importers and/or dealers must submit
notification prior to starting a business. (FAMIC, 2014)
Journal of Insects as Food and Feed 7(5) 853A. Lähteenmäki-Uutela et al.
Thailand is the world’s biggest cricket producer. It has a Coleoptera, Isoptera and Hymenoptera are commonly
Standard for cricket farming (Good Agricultural Practices consumed in Nigeria. In big cities, insects have started to be
for Cricket Farm, Thai Agricultural Standard 8202-2017). regarded as primitive foods. With the population projected
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The Standard includes rules on farm components, feed, to reach 400 million in 2050, Usman and Yusuf (2020) see
water, animal health, environment, and record-keeping. that Nigeria must turn back to healthy and sustainable food
The aim is to produce crickets of good quality which are alternatives such as insects. Indigenous knowledge on insect
safe for consumers. Feed shall not be deteriorated, water harvesting, preservation and use should be complemented
must not be contaminated, equipment must be clean and with university-level research and development focusing
hygienic, and all chemicals must be used according to the e.g. on nutritional content and mass rearing (Usman and
instructions. The development of the Thai cricket farming Yusuf, 2020).
standards was connected to cricket exports, particularly
to accessing the EU markets (Preteseille et al., 2018: 435). According to Usman and Yusuf, insect food regulation
Food is governed by FDA Thailand. In fish aquaculture, is currently missing in Nigeria. Protecting food safety is
Thai companies are looking to replace unsustainable under the competence of the National Agency for Food
fishmeal with insects (Dao, 2020). Thailand also has a large and Drug Administration and Control (NAFDAC). The
broiler meat and pork industry where insect-based feed Food and Drug Act (Cap F32 Laws of the Federal Republic
has potential. Thailand has product quality standards for of Nigeria, 2004) applies. The Standard Organization of
each type of animal feed, but standards for insect feed are Nigeria (SON) sets the rules for packaging materials,
still lacking. The Ministry of Agriculture and Cooperatives labelling and marketing. According to Usman and Yusuf,
regulates animal feed. what is needed in Nigeria is an amendment to the NAFDAC
Act to include rules for insect food safety and control.
8. Africa: South Africa and Nigeria
The NAFDAC Act also applies to animal food, pet food
Niassy et al. (2018) studied the regulatory environment and premixes. Both local manufacturers and importers
for insects as food and feed in South Africa. The country of feed must apply for registration for each product at the
has a high diversity of insect species and a high demand NAFDAC, more specifically the Veterinary Medicine and
for insect protein. Replacing imported food and feed Allied Products directorate (NAFDAC guidelines VMAP
ingredients with local insect production can provide 003/13 and VMAP 004/13). Registrations are valid for
jobs in South Africa. Regulation is fragmented, however. five years.
Various governmental departments and various levels
of government deal with food and feed safety, and there 9. Conclusions and discussion
is no specific legislation on insect production or insect
foods. Insects are not novel foods. The Agricultural Insects have traditionally been harvested and consumed in
Product Standards Act 1990 (Act 119 of 1990) governed many food cultures including Mexico, China and Australia,
by the Department of Agriculture, Forestry and Fishers, without a specific regulatory framework. Due to concerns
the Foodstuffs, Cosmetics and Disinfectants Act 1972 over climate change and food system sustainability, the
(Act 54 of 1972) governed by the Department of Health industrial production of insects and their use as food
and the Consumer Protection Act 2008 (Act 68 of 2008) and feed is now gaining momentum in developed and
governed by the Department of Trade and Industry apply. developing countries. Two problems emerge in parallel
For the large informal food markets, local rules are the with this growth, the first being the lack of regulation locally,
most relevant. (Niassy et al., 2018.) and the second is the lack of a stable and consistent set of
regulations across international borders. More specifically,
For being able to manufacture, import, or sell farm feed or many local companies are interested in exporting their
pet food in South Africa, the product must be registered insect products across the world, but the regulatory
according to the Fertilizers, Farm Feeds, Agricultural demands and differences between countries complicates
Remedies and Stock Remedies Act 1947 (Act 36 of 1947). the initiatives to market and sell insect products.
Before submitting the application, one must send a sample
of the farm feed or pet food to an accredited laboratory Every major stakeholder agrees that insect production
where the product is analysed. Product registrations are and the human food and stock feed uses of insects must
valid for three years, after which they must be renewed be regulated in order to guarantee safety. In that respect,
(South Africa government, n.d.). there is agreement to build regulatory systems around a
scientific risk assessment approach. Clear and unambiguous
Nigeria is another African country where interest in modern regulation will level the playing field, encourage investments,
insect production is rising. Referring for example to Kelemu add trust, and normalize the industry (Van der Spiegel,
et al. (2015), Usman and Yusuf (2020) describe how several 2016: 213). Allegretti et al. (2018) suggest that public
species of insects from the orders Lepidoptera, Orthoptera, and private actors must join forces to construct a global
854 Journal of Insects as Food and Feed 7(5) Regulations on insects as food and feed
regulatory framework for insects as a part of sustainable market after the leaders have cleared the way. If the familiar
food systems. insect species will eventually be authorized in all important
countries, and the authorisations are generic, researchers
https://www.wageningenacademic.com/doi/pdf/10.3920/JIFF2020.0066 - Monday, September 20, 2021 2:08:03 AM - Wageningen University and Research Library IP Address:137.224.11.139
For each government, the primary aim of regulating insect and companies may shift their attention to new species.
food and feed production is to guarantee product safety
and quality. The global industry may view unharmonized In essence, much work needs to be done if we are to
regulations as simply an obstacle which generates repetitive assist and promote this important fledgling industry.
science and repetitive administrative work. Research All stakeholders from government legislators through to
institutions and companies must choose where to invest industry players and the scientific community need to work
their limited resources, e.g. studying familiar insects vs together to achieve consistency and design a way forward
studying unfamiliar insects. In order to become mainstream locally and globally.
food and feed in the Western countries, insects and their
related risks need to be understood and science plays an Acknowledgements
integral part in this process. Safety concerns for insects
which have traditionally been used are less than for new For Lähteenmäki-Uutela, this research was funded by the
insects and new production technologies. Academy of Finland under the EE-TRANS project, grant
number 315898.
Today, much research effort goes into verifying and
replicating previous experiments with insects such Conflict of interest
as crickets, mealworms, and black soldier flies. In the
regulatory context in Australia, for instance, house cricket, The authors declare no conflict of interest.
super mealworm and mealworm beetle are not considered
novel foods. In Canada, the definition of novel food References
excludes traditional foods from other countries. Thorough
safety assessments for all insect foods are required for Allegretti, G., Talaminia, E., Schmidt, V., Bogorni, C. and Ortega,
the European Novel Food Regulation and the American E., 2018. Insect as feed: an emergy assessment of insect meal as a
GRAS or FAP rules. In Europe, traditional foods from third sustainable protein source for the Brazilian poultry industry. Journal
countries are regulated under the novel food regulation, of Cleaner Production 171: 403-412.
but as a specific category (Article 14 of Regulation (EU) Animal Health Australia, 2020. Australian ruminant feed ban.
No 2015/2283). A globally operating insect company Animal Health Australia, Braddon, ACT, Australia. Available at:
will need to prepare an application or notification on the https://www.animalhealthaustralia.com.au/what-we-do/disease-
same product for each national authority, and they all have surveillance/tse-freedom-assurance-program/australian-ruminant-
differing requirements. Many complications are obvious feed-ban/.
as demonstrated by these examples. Belluco, S., Losasso, C., Maggioletti, M., Alonzi, C., Paoletti, M.G.
and Riggi, A., 2013. Edible insects in food safety and nutritional
In theory, insects as food and feed could be regulated perspective. Comprehensive reviews in Food Science and Food
globally. Insects proven safe as food and feed by the scientific Safety 12: 296-313.
community could be authorized in all countries. In the Black, Z., 2020. Don’t fancy eating insects? There’s a good chance you
absence of a global food and feed administration body, the already are. The New Daily, January 9, 2020. Available at: https://
global harmonisation of both substantive and procedural thenewdaily.com.au/life/eat-drink/2020/01/09/edible-insects-
standards would be helpful for both entrepreneurs and crickets-australia/.
authorities. Codex Alimentarius Commission by the FAO/ Crespo, T., 2019. Eating insects, gourmet trend approaching Argentina.
WHO is the arena for developing global food and feed The trend comes from Europe to Argentina. Available at: https://
standards. Codex still does not have the insect standards we www.serargentino.com/en/taste/gastronomy/eating-insects-
anticipated in Lähteenmäki-Uutela et al. (2018), namely a gourmet-trend-approaching-argentina
standard for insect farming practices, a list of insect species Dao, T., 2020. Thai Union to invest in insect-based feed companies.
recognized as safe, a standard on fresh and processed insect Available at: https://www.seafoodsource.com/news/aquaculture/
product hygiene, and a standard on insect product labelling. thai-union-considers-using-fish-feed-from-insects.
DiGiacomo, K., Akit, H. and Leury, B.J., 2019. Insects: a novel animal-
Whether authorisations are generic or firm-specific is feed protein source for the Australian market. Animal Production
an essential feature of safety regulations, impacting the Science 59: 2037-2045. https://doi.org/10.1071/AN19301.
market positions of companies. Larger companies may Directorate-General for Health and Food Safety (DG SANTE), 2017.
benefit, if each company needs to prove the safety of each Strategic safety concept for insects as feed, updated. DG SANTE,
insect product separately. The dissemination of insect Brussels, Belgium. Available at: https://ec.europa.eu/food/sites/
innovations may be faster with generic authorisations that food/files/safety/docs/animal-feed_marketing_concept-paper_
apply to all similar products: the followers may enter the insects_201703.pdf.
Journal of Insects as Food and Feed 7(5) 855A. Lähteenmäki-Uutela et al.
Directorate-General for Health and Food Safety (DG SANTE), 2018. Leon, M.A. and Paz, E., 2013. A perspective of food safety laws in Mexico.
2018-6339: final report of an audit carried out in the Netherlands Journal of the Science of Food and Agriculture 94(10): 1954-1957.
from 13 to 16 November 2018 in order to evaluate the use of Maxabella, B., 2019. Are Australians ready yet to embrace ants, crickets
https://www.wageningenacademic.com/doi/pdf/10.3920/JIFF2020.0066 - Monday, September 20, 2021 2:08:03 AM - Wageningen University and Research Library IP Address:137.224.11.139
insects in animal feed. DG SANTE, Brussels, Belgium. Available and locusts for dinner? SBS, 14 February 2019. Available at: https://
at: https://ec.europa.eu/food/audits-analysis/audit_reports/details. www.sbs.com.au/food/article/2018/06/28/edible-insects-edible-
cfm?rep_id=4138. bug-shop.
Directorate-General for Health and Food Safety (DG SANTE), 2019. Mitsuhashi, J., 1997. Insects as traditional foods in Japan. Ecology of
2019 2019-6647: final report of an audit carried out in France from Food and Nutrition 36: 187-199.
17 to 21 June in order to evaluate the use of insects in animal feed. Nederlandse Voedsel- en Warenautoriteit (IG-NVWA), 2020.
DG SANTE, Brussels, Belgium. Available at: https://ec.europa. Managementreactie IG-NVWA op BuRO advies over de dier-
eu/food/audits-analysis/audit_reports/details.cfm?rep_id=4216. en volksgezondheidsrisico’s van op VVM gekweekte insecten als
Edwards, A. and Ranasinghe K., 2019. Does it taste like chicken? grondstof voor diervoeder. IG-NVWA, Utrecht, the Netherlands.
Australian insects a potential new snack. CSIROscope. Available Available at: https://www.nvwa.nl/documenten/dier/diervoeder/
at: https://blog.csiro.au/australian-insects-potential-new-snack/. diervoeder/publicaties/bijlage-managementreactie-ig-nvwa-buro-
European Commission (EC), n.d. Novel food – authorization advies-gekweekte-insecten-als-grondstof-voor-diervoeder.
procedures. Summary applications and notifications. EC, Brussels, Nederlandse Voedsel- en Warenautoriteit (NVWA-BuRo), 2020. Advies
Belgium. Available at: https://ec.europa.eu/food/safety/novel_food/ van BuRO over de risico’s van op voormalige voedingsmiddelen
authorisations/summary-applications-and-notifications_en. gekweekte insecten als grondstof voor diervoeder. NVWA-BuRo,
Food and Agricultural Materials Inspection Center (FAMIC), 2014. Utrecht, the Netherlands. Available at: https://www.nvwa.nl/
Act on safety assurance and quality improvement of feeds. Available documenten/dier/diervoeder/diervoeder/risicobeoordelingen/
at: http://www.famic.go.jp/ffis/feed/r_safety/r_feeds_safety11.html. advies-van-buro-over-gekweekte-insecten-als-grondstof-voor-
Food Standards Australia New Zealand, 2020. Bovine spongiform diervoeder.
encephalopathy (BSE). Food Standards, Majura Park, ACT, Australia. Niassy, S., Ekesi, S., Hendriks, S.L. and Haller-Barker, A., 2018.
Available at: https://www.foodstandards.gov.au/industry/bse/Pages/ Legislation for the use of insects as food and feed in the South
default.aspx. African Context. In: Halloran, A., Flore, R., Vantomme, P. and Roos,
González, F.C.V. and Contreras, A.T.R., 2009. La Entomofagia en N. (eds.) Edible insects in sustainable food systems. Springer, Berlin,
México. Algunos aspectos culturales. El Periplo Sustentable 12: 57-83. Germany, pp. 457-470.
Grups UP, 2020. Super nutrition. Grups UP, Pinjarra, WA, Australia. Preteseille, N., Deguerry, An., Reverberi, M. and Weigel, T., 2018.
Available at: https://grubsup.com.au. Insects in Thailand: national leadership and regional development,
Health Canada, 2016. Guidelines for the safety assessment of novel from standards to regulations through association. In: Halloran,
foods derived from plants and microorganisms. Health Canada, A., Flore, R., Vantomme, P. and Roos, N. (eds.) Edible insects in
Ottawa, ON, Canada. sustainable food systems. Springer, Berlin, Germany, pp. 435-441.
Insect Protein Association of Australia (IPAA) About – insects as feed. Shen, R., 2014. China regulations on new food raw materials.
https://www.insectproteinassoc.com/insects-as-feed. Accessed Chemlinked. Available at: https://food.chemlinked.com/foodpedia/
5 July 2020. china-regulations-new-food-raw-materials.
Insect Protein Association of Australia (IPAA), 2020. Our mission. Shockley, M., Lesnik, J., Nathan Allen, R. and Fonseca Munõs, A.,
IPAA, Canberra, ACT, Australia. Available at: https://www. 2018. edible insects and their uses in North America; past, present
insectproteinassoc.com/. and future. In: Halloran, A., Flore, R., Vantomme, P. and Roos, N.
Jones, K., 2019. Rise of the edible bugs. Sydney Herald, 7 October 2019. (eds.) Edible insects in sustainable food systems. Springer, Berlin,
Available at: https://www.smh.com.au/business/small-business/ Germany, pp. 55-78.
rise-of-the-edible-bugs-20190927-p52vl1.html. South Africa Government, n.d. Register farm feeds and pet food. South
Kelemu, S., Niassy, S., Torto, B., Fiaboe, K., Affognon, H., Tonnang, Africa Government, Pretoria, South Africa. Available at: https://
H., Maniania, N.K. and Ekesi, S., 2015. African edible insects for www.gov.za/node/727474.
food and feed: inventory, diversity, commonalities and contribution Sun, J., 2015. The regulation of ‘Novel Food’ in China: the tendency
to food security. Journal of Insects as Food and Feed 1: 103-119. of deregulation. European Food and Feed Law Review 10: 442-448.
https://doi.org/10.3920/JIFF2014.0016 Usman, H.S. and Yusuf, A.A., 2020. Legislation and legal frame work
Lähteenmäki-Uutela, A., Grmelová, N., Hénault-Ethier, L., Deschamps, for sustainable edible insects use in Nigeria. International Journal
M.-H., Vandenberg, G. W., Zhao, A., Zhang, Y., Yang, B. and of Tropical Insect Science. https://doi.org/10.1007/s42690-020-
Nemane, V., 2017. Insects as food and feed: laws of the European 00291-9.
Union, United States, Canada, Mexico, Australia, and China. Van der Spiegel, M., 2016. Safety of foods based on insects. In: Prakash,
European Food and Feed Law Review 12: 22-36. V., Martin-Belloso, O., Keener, L., Astley, S., Braun, S., McMahon,
Lähteenmäki-Uutela, A., Hénault-Ethier, L., Marimuthu, S.B., Talibov, H. and Lelieveld, H. (eds.) Regulating safety of traditional and ethnic
S., Allen, R.N., Nemane, V., Vandenberg, G.W. and Józefiak, D., 2018. foods. Elsevier Academic Press, New York, NY, USA, pp. 205-216.
The impact of the insect regulatory system on the insect marketing Yen, A.L., 2005. Insect and other invertebrate foods of Australian
system. Journal of Insects as Food and Feed 4: 187-198. Aborigines. In: Paoletti, M.G. (ed.) Ecological implications of
minilivestock. Science Publishers Inc., Enfield, NH, USA, pp. 367-387.
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