ISSUE FOCUS 64 FEED & ADDITIVE MAGAZINE August 2025 terest in circular food systems, Europe’s regulatory landscape remains a major roadblock. Under current EU legislation (Regulation EC 1069/2009 and 142/2011), insect larvae destined for animal feed must be raised on “feed-grade” substrates. This excludes most aquaculture by-products, especially anything classified as an Animal By-Product (ABP) of Category 2 or 3. In practice, this means that nutrient-rich fish viscera, blood, and sludge are not allowed as BSF feed, even when pre-processed to eliminate pathogens. These materials are considered “too risky” due to the potential for contamination from viruses, bacteria, heavy metals, or veterinary residues. Ironically, many of these side streams are already used for other purposes, such as ensiling or energy generation, without similar levels of scrutiny. The paradox is that Europe continues to promote circularity and waste valorization as sustainability goals while keeping some of the most promising feedstocks for BSF locked behind regulatory barriers. The result is a frustrating bottleneck: The biological solution exists, but the political and legal framework has not caught up. WHAT THE REST OF THE WORLD IS DOING DIFFERENTLY Outside the EU, other countries are moving faster. In Thailand and Vietnam, BSF larvae are routinely reared on a mixed organic waste that includes catering scraps and fish byproducts.4 In Chile and Ecuador, countries with large aquaculture industries, BSF systems have been piloted using fish offal and processing waste with strong results. The USA, while still cautious, allows more flexibility for R&D projects and regional approvals, enabling innovative trials on aquaculture sludge and other feedstocks.5 The environmental and economic impacts are significant. Insects fed on aquaculture waste can reduce the organic volume by a considerable percentage, thereby cutting methane emissions and landfill use. Feed costs for aquaculture producers can drop substantially, especially when larvae are raised locally using existing waste streams. In regions where fishmeal costs are volatile or imports are expensive, this model offers supply chain resilience. CONTAMINANTS, PATHOGENS, AND REAL RISKS The key hesitation from regulators, and rightly so, revolves around food safety. Aquaculture residues can carry pathogens like salmon viruses or contain contaminants such as cadmium, arsenic, and antibiotics.6 But these risks can be addressed. Thermal preprocessing, blending of substrates, and real-time monitoring technologies are now advanced enough to keep these contaminants within legal thresholds.7 This isn’t just a theory. One of our existing partners who has tested BSF larvae growth on aquaculture sludge found that larvae performed well up to a specific percentage of sludge inclusion. Beyond that, performance declined due to elevated ash and metal accumulation, underscoring the need for careful formulation. However, within limits, it worked well, suggesting the need for consistent quality control rather than a blanket prohibition. CLOSED LOOPS AND OPEN OPPORTUNITIES The potential for integrated circular systems is enormous. Imagine a recirculating aquaculture system (RAS) where sludge is directed to an on-site insect bioconversion unit. There, larvae, such as those provided through FreezeM’s live-suspension solution, are activated and introduced into controlled rearing systems. The resulting larvae are processed into high-protein meal and reintroduced into the fish feed. The leftover frass is used to fertilize fields or aquaponic crops, closing the nutrient loop entirely. Pilot projects, such as ClimAqua and Safe Insects, are already exploring these models by combining BSF farming with aquaculture and agriculture. What’s missing is scale, and that can only be achieved with regulatory reform.
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