Regulatory work on insect feed substrates
The regulations governing insect production aim to support the circular economy while being firmly grounded in science. Below is an overview of the current framework and the work the Norwegian Food Safety Authority is undertaking in this area.
Insects are a natural food source for many animal species and can transform organic material into high-quality protein and fat. Their production has relatively low greenhouse gas emissions, water consumption, and land use, while also promoting circularity by making use of by-products and waste streams. For these reasons, there is growing interest in using insects as feed for food-producing animals.
Substrate – insect feed
The potential of insect production, as well as its environmental footprint, largely depends on the availability of safe and sustainable growth substrates. The material used to raise insects is legally defined as feed and is therefore subject to the same regulations as feed for other farmed animals. At present, only plant-based materials – with some exceptions for animal-derived products – are permitted as substrates for farmed insects.
Potential substrate sources
Scaling up insect production requires a clear understanding of the regulatory restrictions on the use of different types of organic waste as feed. The three main categories of potential substrates are:
- catering waste
- former foodstuffs
- faeces, urine, and separated digestive tract content, including fish sludge
Current regulations based on EFSA’s 2015 risk assessment
The regulatory framework for insect farming, introduced in 2017, is based on the European Food Safety Authority’s (EFSA) 2015 risk assessment of insects as food and feed.
EFSA concluded that there was insufficient scientific data to fully assess the biological risks of using catering waste or livestock manure as feed substrates. In line with the precautionary principle, these materials are currently prohibited for insect production.
The need for more knowledge before approving new substrates
As new scientific evidence emerges, EFSA may reassess additional feed substrates. If the results are positive, new substrates could be approved.
To enable this, sufficient data must be available to allow EFSA to reach clear conclusions. Research is therefore essential. It may also be worth considering whether the Norwegian Scientific Committee for Food and Environment (VKM) should assess current knowledge gaps, in order to strengthen the evidence base for determining whether currently prohibited feed materials – such as fish sludge, livestock manure, and catering waste – can be used safely.
The circular use of fish sludge as an insect feed substrate has attracted particular interest, as it offers potential environmental benefits while competing minimally with other applications. Although collection systems for fish sludge from production at sea are not yet well established, the debate is especially relevant in Norway, given the country’s large-scale salmon production and abundant access to this resource.
Digestive tract content, including fish sludge, in feed
Under current feed regulations, urine, faeces, and separated digestive tract content are prohibited as feed materials.
For aquaculture sludge or livestock manure to be used as insect feed substrates, this regulation would need to be amended to exempt insect substrates from this prohibition, provided they are shown to be safe.
Another approach could be to regulate substrates differently depending on the intended use of the insects – whether for feed or food. Since insects destined for feed are processed before use, this processing step may provide an additional safety barrier that could justify more flexible rules.
Fish sludge as a substrate – challenges and considerations
Findings from the SecureFeed project (2024/2025) show that using fish sludge as a substrate can lead to the accumulation of heavy metals, making it difficult to comply with maximum levels of undesirable substances in animal feed. One potential solution is to treat the sludge to remove these substances before use. Another approach is to improve the digestibility of certain nutrients in fish feed, such as zinc, thereby reducing their excretion and limiting accumulation in the sludge.
It is also important to note that fish sludge is not a uniform material. Its composition depends on factors such as feed content, digestibility, and the level of feed wastage.
In addition, fish sludge from hatcheries and grow-out farms has limited relevance in a broader European context, where aquaculture is far less extensive than in Norway. As a result, the International Platform of Insects for Food and Feed (IPIFF), representing the EU insect sector, has mainly focused on securing approval for catering waste as a feed substrate.
The Norwegian Food Safety Authority’s contribution to the development of insect feed substrates
Our objectives are to
- actively contribute to ongoing and future research projects on the safety of different insect feed substrates
- maintain dialogue with industry and relevant organisations, including IPIFF and the European Sludge Network via NCE Aquaculture
- advocate for a new EFSA assessment of insect feed substrates once sufficient data is available on currently prohibited materials
- work towards relaxations in the TSE regulation to permit the use of processed animal proteins (PAP) from pigs and poultry as insect feed substrates: Easing restrictions on the use of animal proteins in feed for food-producing animals ("feed ban")