Using insects in poultry feed could mean less deforestation and happier chickens. But UK law is falling short of the mark.

February 6, 2023

Rachel O’Connor, Partner in the agricultural team at UK law firm Michelmores, explains why

Why insects should be on the menu at chicken farms

Every poultry farmer wants their chickens to be happy. After all, happy hens lay more eggs. But for hens to be happy, they need to be able to do what comes naturally to them, which includes pecking around on the ground for insects.

Insects are a natural and nutritious part of a chicken’s diets. However, their typical natural diet has been replaced with grain and soy-

based pellets, which while more cost- effective, carry a number of hidden disadvantages.

At the Insects as Feed and Food conference in April 2022, we discussed the role insects play in sustainable farming. More specifically, the reasons insects should start to replace soy as poultry feed as part of the solution to achieve a more sustainable future for farming. I gave a talk on the UK’s current legislative position, which is key to unlocking the potential of this industry.

Why we need an alternative to soy

360 million tonnes of soy were produced globally in 2020 but questions have long been raised about the sustainability of long-term use of soy in poultry rations. As well as the food miles involved in transporting soy to the UK from South America, there’s its links with the destruction of the Amazon rainforest and displacement of indigenous peoples. Not to mention the amount of water required to grow the crop (1,650-2,200 litres of water are needed to produce 1kg of soybeans). The ever-fluctuating prices of soy, and unpredictability of supply, means that the industry is desperate to find a more sustainable, commercially viable alternative.

Using insects as poultry feed is the obvious choice for a number of reasons: they’re rich in protein and micronutrients; require less land, water and energy to farm; and can be sourced locally. And they produce much happier chickens. By helping boost organ health and immunity, increasing productivity and encouraging more natural, foraging behaviour in poultry, they could be exactly what the industry needs right now. However, stagnant legislation is proving a significant challenge.

According to the 2020 report The Future of Feed: A WWF Roadmap to Accelerating Insect Protein in UK Feeds, routes to greater volumes and markets are required. As the report states: ‘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.’

How Brexit left the UK on the back foot

While the UK was part of the EU, it was subject to legislative changes made by the European Commission to help advance the insect farming industry. However, EU legislation introduced since 1 January 2021 (after the transition period ended), does not apply in the UK.

Billed as a way to reduce red tape, Brexit has actually ended up hindering UK advancement in this particular industry.

Here are three examples where UK legislation is falling behind:

1. The eighth insect

In 2017, permission was granted across the EU for seven insect species (the black soldier fly; common housefly; yellow mealworm; mealworm; house cricket; banded cricket; and field cricket) to be used in aquaculture feed.

This was a significant step forward in the role insect protein has to play in the future feed market. In November 2021, the EU added the silkworm to this list. However, the UK is now missing this ‘eighth insect’ as the new legislation does not apply in the UK. Although not a significant development, it is a clear indication that the EU is making advances in legislation in this field and the UK is not keeping pace.

2. A rethink on the PAP ban

It’s a similar story with the European Commission’s decision to ease the restrictions on using certain non-ruminant processed animal protein (PAP) in pig

and poultry feed. This recognised that chickens are naturally insectivorous and that pigs are omnivorous. The ban has been in place for decades following the BSE outbreak. The European legislation introducing this amendment highlights that the risk of BSE transmission from non-ruminants is negligible if intra-species recycling is avoided.

New legislation introduced by the EU effective from September 2021, means PAP can now be used in poultry and pig feed. The rules have also been changed to allow the use of processed insect protein of the eight named species (under the same conditions as permitted for feeding aquaculture animals) in poultry and pig food.

However, these amendments do not apply in the UK, meaning potential investment opportunities are being lost. As the WWF report points out: ‘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.’

3. Synchronised standards on insect frass

Finally, there’s the new EU law regularising the use of insect frass as fertiliser. The legislation has introduced a

definition of frass, being ‘a mixture of excrements derived from farmed insects, the feeding substrate, parts of farmed insects, dead eggs and with a content of dead farmed insects of not more than 5% in volume and not more than 3% in weight.’

In other words, the faeces, outgrown exoskeletons, and dead eggs of insects.

The legislation applies the same standards as that of processed animal manure to the use of insect frass, with rules covering a range of areas, including:

  • Source plant: It must come from a plant for derived products for uses outside of the feed chain
  • Heat treatment: Frass should be treated at 70°C for one hour
  • Standards for sampling in order to monitor the process as well and
  • Storage: in order to minimise contamination, secondary infection and dampness

There has been several fundamental legislative developments at an EU level since 1 January 2021. When there was a clear opportunity to advance the UK insect protein industry following Brexit, UK domestic legislation has remained static. British law is simply not keeping pace with that of the EU. Going forward, that puts our poultry and pig farmers at a significant disadvantage.

Frass: On course for a circular economy

In terms of volume, frass is a substantial output from insect farming. According to the International Platform of Insects for Food and Feed (IPIFF), the benefits of using frass include:

  • The addition of macro- and micro-nutrients to the soil
  • The introduction of organic matter that enhances microbiological activity in soil
  • Improvement to the soil’s water holding capacity
  • Increased plant tolerance to abiotic stresses and resistance to pathogensCrucially, frass contains polymers and nutrients that promote plant growth, making it a sustainable way to grow crops.

Rearing insects on surplus crops or in some instances, co-products from other industries (brewers’ grains being a good example) and harnessing that ability to turn otherwise disused resource into high quality protein is what makes this industry so exciting. Utilising frass as a valuable by-product is an essential part of how this industry is key to contributing to a circular food system. The use of insects in this way connects two crucial points in food chain transforming a linear system to a circular one.

A sustainable future

There is a clear case for up-scaling the UK’s insect production. According to the WWF report:

  • Demand for insect protein from the UK’s pig, poultry and salmon sectors could reach around 540,000 tons a year by 2050
  • 240,000 tonnes of insect meal a year could potentially be sourced from UK insect farms
  • The use of insect protein could reduce the UK’s future soy imports by one fifth
  • Finding a viable alternative to soy could help protect vital ecosystems around the world, including the Brazilian Cerrado (where more than 100,000 hectares of habitat is lost each year to make way for soy production)

But if change is going to happen, UK policymakers urgently need to take action. By devising the appropriate policy, legislating for legal changes, removing barriers and introducing more financial initiatives to support innovative farmers, the UK sector can be successfully scaled up to meet demand. If this can be achieved, the UK’s fowl (and farmers) will be happier and healthier for it.

Agricultural Team Partner, Michelmores