In the EU there are different alternative/non-traditional sources of proteins allowed for use in animal nutrition that companies and consumers are not necessarily familiar with. In this short article, we will cover some of them, including the characteristics the ingredients must have to comply with European regulations.
By Argenta
Alternative sources of protein for use in animal nutrition are classified in the EU as feed materials. As per Regulation (EC) No 767/2009, ‘feed materials’ are products of vegetable or animal origin, whose principal purpose is to meet animals’ nutritional needs, in their natural state, fresh or preserved, and products derived from the industrial processing thereof, and organic or inorganic substances, whether or not containing feed additives, which are intended for use in oral animal-feeding either directly as such, or after processing, or in the preparation of compound feed, or as carrier of premixtures. In Commission Regulation (EU) 2022/1104 of 1 July 2022 amending Regulation (EU) No 68/2013 on the Catalogue of feed materials both, industry and consumers, can find the list of these proteins that can legally enter the market for use in feeding stuffs. On Table 1, you will find some of the most interesting examples authorised to date.
The first two entries of the table cover insects already authorised for use in the EU, which is a source that can be tricky to understand from the farming/manufacturing point of view since the diet of these animals is also subject to regulatory requirements, further details are provided.
FEED FOR INSECTS
Companies interested in harvesting insects for use in animal feeds should notice that their feed is also subject to legal requirements that guarantee the safety of the entire food chain. In particular, farmers must pay attention to the following (as per Commission Regulation (EU) 2017/893):
– Feed for insects cannot contain ruminant proteins, catering waste, meat-and-bone meal, manure, or faeces.
– The substrate used for feeding insects may only contain products of non-animal origin or the following products of animal origin of Category 3 material: fishmeal, blood products from non-ruminants, di- and tricalcium phosphate of animal origin, hydrolysed proteins from non-ruminants, hydrolysed proteins from hides and skins of ruminants, gelatine and collagen from non-ruminants, eggs and egg products, milk, milk based-products, milk-derived products and colostrum, honey, and rendered fats.
How about the potential for new ingredients to be authorised for use in insect feeds, such as feed additives? To date, there is no feed additive authorised specifically for use in insects in the EU. However, European authorities are already contemplating the possibility of receiving a request for authorising such products since, as it can be seen in the recently updated Guidance on the assessment of the efficacy of feed additives published by the European Food Safety Authority (EFSA), there are now requirements for experimental design when the target species are insects. For example, a) an application dossier aimed at authorising a feed additive for all insects must contain a total of 4 efficacy studies: 2 in honeybees + 2 in other insect species (1 in each), b) applications for all terrestrial species must now include studies with insects or they will be excluded from the authorisation, c) the duration of the efficacy studies must cover the whole production cycle.
NEW ALTERNATIVE PROTEINS ON THE HORIZON?
From the regulatory point of view, companies interested in placing a new feed material on the market must first make a registration in the Online Feed Material Registers. The register is periodically reviewed and updated by the EU Feed Chain Task Force composed of representatives of the EU feed business sectors. As part of this process, the Task Force could authorize the incorporation of new protein sources into the Catalogue of feed materials in the next update of this regulation. To date, there are some interesting ingredients in the Online Register that could make it into the Catalogue in the future, such as onion protein, pineapple concentrate (protein-rich), lemna protein, and guar protein concentrate.*
PARTNER FOR SUCCESS: NAVIGATING REGULATORY CHALLENGES TOGETHER
Securing market authorisation for your product requires navigating a complex regulatory landscape. This can be challenging, but the rewards—healthier, happier, and safer animals—are significant.
Taking a proactive and strategic approach is key to overcoming these regulatory hurdles. At Argenta, we understand the importance of tailored support for your unique needs. Our collaborative and knowledgeable team is dedicated to providing the regulatory expertise needed to guide your product to approval.
Whether you’re developing feed materials or other animal health/nutritional products, our experienced teams in Germany, Spain, and the USA are here to support you. We have a proven track record with the European Food Safety Authority (EFSA), the EMA, and national competent authorities in the EU, as well as with the FDA Center for Veterinary Medicine (CVM), the Environmental Protection Agency (EPA), and the USDA in the USA. Let’s work together to ensure your product reaches the market successfully.
References
1. Commission Regulation (EU) 2022/1104 of 1 July 2022 amending Regulation (EU) No 68/2013 on the Catalogue of feed materials: https://eur-lex.europa.eu/eli/reg/2022/1104/oj
2. Commission Regulation (EU) 2017/893 of 24 May 2017 amending Annexes I and IV to Regulation (EC) No 999/2001 of the European Parliament and of the Council and Annexes X, XIV and XV to Commission Regulation (EU) No 142/2011 as regards the provisions on processed animal protein: https://eur-lex.europa.eu/eli/reg/2017/893/oj
3. Feed materials register: https://feedmaterialsregister.eu/
4. Guidance on the assessment of the efficacy of feed additives: https://www.efsa.europa.eu/en/efsajournal/pub/8856
5. Regulation (EC) No 767/2009 of the European Parliament and of the Council of 13 July 2009 on the placing on the market and use of feed, amending European Parliament and Council Regulation (EC) No 1831/2003 and repealing Council Directive 79/373/EEC, Commission Directive 80/511/EEC, Council Directives 82/471/EEC, 83/228/EEC, 93/74/EEC, 93/113/EC and 96/25/EC and Commission Decision 2004/217/EC: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02009R0767-20181226
*As per Regulation (EC) No 767/2009, ingredients in the online register can be placed on the market but its regulatory status can be revoked at any given time and the consequences will be immediate.