EU policy and insect alternative protein, panacea or chimaera?

Insect farming is not necessarily compatible with a more sustainable food system. It raises new animal welfare issues and, as an industry, it is expanding rapidly despite numerous and significant unknowns. The precautionary principle needs to be applied in legislating the insect production sector. It is imperative to ensure that its development is compatible with the EU’s objectives for a sustainable food system.

Jacopo Moccia
Political Advisor
Eurogroup for Animals (EfA)

Insect farming has still to prove all its environmental credentials and, as an industry, is shrouded in overwhelming lack of knowledge, according to European Union (EU) experts. Nevertheless, ten species of insects are authorised for food or feed in the EU, and the number is likely to grow over the coming years. Authorisations are given purely on the digestibility of the insects, rather than on an overall appreciation of insect protein’s role and impact on the food system and broader environment.

The European Union is committed to developing a fair, healthy and environmentally friendly food system, and has adopted its lighthouse Farm to Fork strategy to reduce greenhouse gas emissions, soil and other environmental pollution from its agricultural sector. Indeed, according to the European executive’s figures, the farming sector is responsible for over 10% of the EU’s greenhouse gas emissions (Methane and Nitrous Oxide), excluding CO2. With animal farming by far the biggest contributor to agriculture’s GHG footprint representing, alone, 7% of total EU emissions.

Non-CO2 Greenhouse gas emissions in EU
Source: A European Green Deal – European Commission 2019

Given the disproportionate environmental impact of animal farming, the European strategy recognises, therefore, the importance for the environment and human health of reducing animal products in Europeans’ diets and moving towards more extensive – as opposed to intensive – animal farming with high animal welfare standards.

In this context, insect protein from industrial insect farming facilities is touted as an environmentally friendly way to enrich and replace traditional feed for intensively farmed animals as it could replace soy imports from Latin America and reduce the amount of arable land used to produce feed. This, in turn, could diminish the political urgency of reducing animal product consumption and, on the contrary, justify increased intensive animal farming to meet increasing demand for meat, fish and dairy.

On this basis, insect farming is taking off in Europe, with the two biggest insect production facilities in the world operating, or soon-to-operate, located in the EU. Not wishing to rain on this insect parade, Eurogroup for Animals and other animal welfare advocates in Europe are calling for the precautionary principle to be applied to the sector, with future authorisations subordinated to a broader understanding of impacts on the environment, the sustainability of the food system and the welfare of the animals reared by this new livestock industry.

EXACERBATING THE FOOD-FEED COMPETITION
One of the main arguments in favour of insect farming is that insects can feed on waste and other products not fit for human or animal consumption and upcycle them into protein. However, most of these ingredients are not authorised in feed for insects (known as substrates) due to concerns over disease and pathogen spread. Studies on the capacity of insects to carry pests and spread disease and pathogens suggest that this is a serious concern.

The slaughter process through freezing or use of heat may reduce the risk, but what is not known is how unprecedented concentrations of thousands of individuals may impact pest and disease transmission and resilience.

Moreover, not all ingredients are sufficiently nutritious to guarantee high protein conversion rates and low mortality rates in facilities. Not all insect species can thrive on waste or poor-quality substrates. Absence of adequate food can trigger competitive behaviour between individuals and cannibalism, leading to injury and death. Bottom line, this means that not all ingredients are commercially viable for insect rearing.

Ingredients used in substrates by insect producers (percentage -%- of producers using each substrate)
Source: IPIFF vision paper on the future of the insect sector – Survey of IPIFF members March 2018

In fact, according to the industry association International Platform of Insects for Feed and Food (IPIFF), producers use a number of different ingredients, including fruits, vegetables, and cereal. These are resources that could be used for direct human consumption or to feed extensively reared chickens and pigs. Around a third of insect producers use commercial feed which can include soy.

Adding an extra trophic level to the food chain, by feeding insects ingredients that could be consumed directly by animals or people, is not necessarily efficient and contradicts the need to reduce the food-feed competition and the EU’s objective of making the food system more resilient. The need for system resilience has, unfortunately, been made painfully clear by the tragic war in Ukraine that is putting pressure on the EU’s feed supply chains.

If the insect industry ramps up at rates forecasted by some observers – Industry investor Rabobank predicts up to half a million tonnes of insect protein produced by 2030 – there could be 45 trillion to 50 trillion individual insects produced per year. It is, therefore, fundamental that this does not increase pressure to produce feed for insects to feed animals rather than food for people.

MANIPULATING GENES FOR A VIABLE BUSINESS CASE
As feed goes, insects are still costly. Data by Rabobank (2020) and Indexmundi (October 2021) suggests that insect meal is 3 to 4 times more expensive than fishmeal and ten times more expensive than soy meal.

The necessary path to cost reduction requires increasing the number of individuals reared in facilities. Overcrowding of insects is generally not seen as a problem, due to a generic understanding that insects are gregarious animals and that any resulting cannibalism is normal.

This, however, is an oversimplification. Certain species thrive in isolation as well as in gregarious settings. Even with gregarious species, overcrowding not only hinders individuals’ capacity to behave normally, but can be a trigger for abnormal aggressivity and cannibalism. Density in facilities, therefore, matters.

Yet true competitiveness will only be attained if insects can grow bigger and faster, a fact that industry CEOs are candid about. The industry is, therefore, turning to genetic breeding and genetic selection. However genetic manipulation is not a risk- nor consequence-free activity, it can give rise to new welfare issues in insects as has been the case in the genetic manipulation of vertebrates before them.

BRUSHING ETHICS TO ONE SIDE
Overcrowding, behavioural needs and genetic manipulations raise ethical as well as practical and environmental questions. Insects are not protected under EU or national laws which leaves industry carte blanche to consider their welfare or not.

Scientific work on insect behaviour is raising the key question of whether farmed insects are sentient, capable of subjective experiences such as pain and fear. There are over 2,000 identified edible insect species, consequently, determining sentience for each is a considerable task. Yet, evidence on insect sentience exists, both for individual species, and across the taxa.

The subject of insect welfare may seem risible and, indeed, is brushed aside as the complete absence of insect welfare legislation or standards indicates. Although the subject has not been fully researched, the scientific community does nonetheless advocate caution.

This means that insects should be reared in ways that respect their species-specific needs and behaviours and treated humanely at the time of slaughter, despite industry productivity considerations. What is the fundamental difference between insects as livestock and the pigs, hens and fish livestock they are fed to?

IMPACTING ECOSYSTEMS
Among the various environmental impacts of the insect farming industry that EU experts readily concede they have little information on, are the consequences of release, accidental or otherwise.

The introduction of invasive alien species or, simply, the sudden introduction of high concentrations of certain endemic species in a given area may have consequences for local ecosystems, threaten food security and biodiversity.

The economic consequences could be significant, considering that invasive species are the cause of a 14% reduction in global food production. Moreover, the changing climate increases the capacity of invasive alien species to establish.

An increased risk of insect-borne pathogens would pose an additional threat to already struggling wild-living insects that are essential for the ecosystem, such as pollinators. These concerns, furthermore, are multiplied when considering the possibility of insects that have been genetically modified to grow bigger, faster, adapt more easily and be more resilient.

APPLYING THE PRECAUTIONARY PRINCIPLE
Insect farming is not necessarily compatible with a more sustainable food system. It raises new animal welfare issues and, as an industry, it is expanding rapidly despite numerous and significant unknowns.

The precautionary principle needs to be applied in legislating the insect production sector. It is imperative to ensure that its development is compatible with the EU’s objectives for a sustainable food system.

Indeed, in June of this year, the Global Partnership for Animals banned the use of insect protein as feed in its animal welfare certification scheme for Atlantic Salmon aquaculture, citing the lack of “thorough understanding” of insect feed sustainability and its animal welfare implications.

Further EU regulatory authorisations for industrial rearing of insect species should not be given until there is solid scientific evidence on their welfare needs, and a greater understanding of the practice’s environmental, ecosystem and food system impacts.

Failing this, the emerging insect protein industry, seen as a panacea for animal farming by some, may turn out to be a chimaera.

About Jacopo Moccia
Jacopo Moccia is a Political Advisor on insect farming and sustainable food system at Eurogroup for Animals (EfA), an EU-wide animal welfare organisation with over 80 members across Europe. EfA is based in Brussels, Belgium and works closely with the European institutions to promote animal welfare and a healthy and sustainable food environment policies.
Belgian of Italian origin, Jacopo has a Master’s degree from the University of Sussex and has worked for over 20 years in politics and EU-affairs.