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Insects and frass, circular economy in agri-food systems

Insect breeding - in addition to providing raw materials for feed and food - allows for the production of frass, an organic fertilizer or soil conditioner that expresses an excellent example of circular economy in agri-food systems.

This material also lends itself to other valuable uses, in agriculture as in animal husbandry and aquaculture, but European legislation still needs to be completed and updated to allow operators to access these opportunities.

1) Frass, definition

The phrase is 'a mixture of excreta derived from farmed insects, food substrate, parts of farmed insects and dead eggs, with a content of dead farmed insects not exceeding 5% by volume and not exceeding 3% by weight'. (1)

Regulation (EU) 2021/1925 – in addition to defining frass, in the aforementioned terms – it reformed the discipline of organic fertilizers and soil conditioners, already established in the implementing measures for animal by-products (SOA, or animal by products, ABPs). (2)

IPIFFInternational Platform of Insects for Food and Feed, has had a central role in promoting the adoption of a European regulation aimed at guaranteeing high safety and quality standards for the protection of public health, animal health and welfare, and environmental protection. (3)

2) Animal by-products and frass, the EU rules

The European discipline of by-products of animal origin (SOA, ABPs), among which frass also appears, is independent of that of waste. (4) The frass, in particular, falls into Category 2 - medium risk (5) - of the animal by products. In fact, like processed manure, it is subject to similar requirements for placing on the market: (6)

– the materials come from a manufacturing plant for derivative products for uses outside the supply chain feed, or from a biogas or composting plant, or from a plant for the production of organic fertilizers or soil improvers,

– the ABPs are subjected to a heat treatment (at least 70 °C for 60 minutes) and to a treatment to reduce spore-forming bacteria and toxinogenesis, if they are recognized as a relevant risk,

– representative samples of the frass, taken for process control purposes during or after processing in the plant, meet specific microbiological requirements
(Escherichia coli: n = 5, c = 5, m = 0, M = 1 000 in 1 g; or Enterococcus: n = 5, c = 5, m = 0, M = 1 000 in 1 g), (7)

– ABPs are stored in such a way as to minimize contamination or secondary infection and humidification after processing. In this regard, they must be stored in well-closed and isolated silos and constructed in an appropriate manner; or in tightly closed packaging (plastic bags orbig bags').

2.1) Obligations of the operators

The operators dealing with ABPs (SOA) - in addition to fulfilling the specific obligations for the production and marketing of organic fertilizers and soil conditioners - must implement the following general obligations at the supply chain level: (8)

– collection and transport accompanied by commercial documents bearing information on the origin, destination, quantity and description of the ABPs (SOA), including the category,

– traceability, by recording both commercial consignments and documents, as well as suppliers and customers,

– registration or approval (required for the treatment or production of frass as an organic fertilizer or soil improver) of establishments,

– general hygiene requirements, measures to avoid cross-contamination with food products (in the case of establishments or plants that also produce food), adoption of a HACCP plan and internal controls.

2.2) Official controls

animal by products (ABPs, SOA) are subject to the official controls envisaged by the Official Controls Regulation (EU) No 2017/625, with the aim of preventing and minimizing the health risks deriving from them, or from the derived products. Official controls must be performed at all stages of production, processing and distribution. (9)

In Italy, the official controls are entrusted to the Veterinary Services of the ASL, USL or ATS, on the basis of the regional provisions adopted in compliance with State-Region agreements and understandings, referring both to these by-products and to the official controls on the agri-food chain (still awaiting update with respect to EC regulation 882/2004. See notes 10,11,12).

The 2020 annual report on the Multi-year National Control Plan 2020/2022, refers to numerous non-conformities, especially in terms of incorrect fulfillment of the general requirements (e.g. HACCP plan, personnel training, commercial documents). With attention to the registration and/or recognition of operators, essential for organizing controls and knowing the quantities and flows of ABPs (SOA) produced and handled at a national level (13,14).

3) Regulation on Fertilizing Products

Almost all by-products of animal origin is excluded from the scope of the Fertilizers Regulation (EU) No 2019/1009, (15) without prejudice to two of the thirteen categories of constituent materials (CMC), instead permitted in the production of fertilizers in the EU:

– CMC 3 – Compost. Obtained from aerobic composting of category 2 or 3 materials (medium-low risk) and/or products derived from them, alone or mixed with other materials allowed in the compost,

– CMC 10 – Derivative products pursuant to Regulation (EC) 1069/2009. However, the list of these derivative products is not available, to date, pending a specific delegated act by the European Commission.

In both cases it is necessary that the materials have reached the final stage of production, so as to lose the qualification of ABPs, or SOA. However, these conditions must be defined by the European Commission with another delegated act still awaiting adoption. (16)

4) Frass, uses in agriculture

Il mix of nutrients contained in the frass is rapidly assimilated by the root systems of many plants, edible and not. And it is able to contribute to the need for macronutrients (e.g. nitrogen) to a significant extent, more functional than other fertilizers, with a sensitive allocation on the leaves. The insects' diet, as well as their species, affects both the mineral composition of the frass and its microbiota, which is also influential when used as an organic fertilizer. (17)

Another feature of note is the ability of frass to increase the resistance of plants to abiotic stresses (ie high salinity, drought or water stagnation). This ability is attributed precisely to the microbiota of the frass, formed by microorganisms and nitrogen-fixing fungi, capable of:

– make phosphates and potassium soluble,

– synthesize certain phytohormones (e.g. auxins) or enzymes to reduce excess ethylene in plants (ie ACC deaminase),

– activate the native defenses of the plants and contain attacks from pathogens or parasites.

5) Frass, uses in zootechnics and aquaculture

In animal feed, as we have seen, frass has been shown to be able to improve the nutritional status of animals and the quality of fish. (18) An opportunity for the development of the circular economy in agri-food systems.

European legislation however, it needs to be updated in order to take advantage of these opportunities, since Regulation (EU) No. 142/2011 only contemplates the use of processed animal proteins (Processed Animal Proteins, PAPs).

6) Provisional conclusions

Beyond the qualification of 'by-product' (of animal origin), frass is a product with numerous functions. Of particular interest among other things in a historical phase in which the costs of nitrogen fertilizers have skyrocketed. (19)

Note well however that the use of frass is currently permitted in the EU only as an organic fertilizer or soil improver. Its uses as a fertilizer and feed material still need to await implementation legislation and reforms.

Dario Dongo and Andrea Adelmo Della Penna


(1) Commission Regulation (EU) 2021/1925 amending certain Annexes to Regulation (EU) No 142/2011 as regards the requirements for placing on the market of certain insect products and the adaptation of a containment method https://tinyurl.com/ycycbepf

(2) Commission Regulation (EU) No 142/2011 implementing Regulation (EC) No 1069/2009 of the European Parliament and of the Council laying down health rules as regards animal by-products and derived products not intended for human consumption. Consolidated text 17.4.22 https://tinyurl.com/28km3skm Annex XI

(3) IPIFF Contribution Paper on the application of insect frass as fertilizing product in agriculture. https://tinyurl.com/me5237hp 19.9.19

(4) Waste and by-products are regulated by Directive 2008/98/EC (Waste Frameword Directive). The EUCJ ruling on cases C-21/19 to C-23/19 confirmed this approach in paragraph 35

(5) Animal by-products are divided into 3 risk categories:
a) category 1 materials (high risk),
b) category 2 materials (medium risk),
c) category 3 materials (low risk).

(6) See regulation (EU) no. 142/2011, Annex XI, Chapter I, Section 2, letters 'a', 'b', 'd', 'e'
(7) n = number of samples to be examined, m = threshold value for the number of bacteria (the result is considered satisfactory if all samples have a number of bacteria less than or equal to m). M = maximum value of the number of bacteria (the result is considered unsatisfactory if one or more samples have a number of bacteria equal to or greater than M). c = number of samples whose bacterial load can be between m and M (the sample is still considered acceptable if the bacterial load of the other samples is equal to or lower than m)

(8) Regulation (EC) no. 1069/2009, articles 21-26, 28, 29

(9) Regulation (EU) 2017/625, art. 20, par. 1

(10) Agreement between the Government, the Regions and the Autonomous Provinces of Trento and Bolzano and the local Autonomies on the document containing «Guidelines for the application of Regulation (EC) no. 1069/2009 of the European Parliament and of the Council of 21 October 2009 laying down health rules relating to by-products of animal origin and derived products not intended for human consumption and which repeals Regulation (EC) n. 1774/2002». (HEALTH) Site code: 4.10/2012/70 (Service III) Agreement pursuant to article 9, paragraph 2, letter c), of the legislative decree 28 August 1997, n. 281. (Rep. Acts n. 20/CU of 7.2.2013) http://archivio.statoregioni.it/Documenti/DOC_039696_20%20CU%20P.%2011.pdf

(11) Agreement, pursuant to article 4 of the legislative decree 28 August 1997, n. 281, between the Government, the Regions and the autonomous Provinces of Trento and Bolzano on the document containing «Guidelines for the operation and improvement of the official control activity by the Ministry of Health, the Regions and Autonomous Provinces and the AASSLL on food safety and veterinary public health» (Rep. deeds 46/CSR of 7.2.13) https://www.gazzettaufficiale.it/eli/id/2013/03/27/13A02503/sg

(12) Agreement, pursuant to article 8, paragraph 6, of the law of 5 June 2003, n. 131, between the Government, the Regions and the autonomous Provinces of Trento and Bolzano on the document concerning «Guidelines for official control pursuant to Regulations (EC) n. 882/2004 and 854/2004» (Rep. Acts n. 212/CSR of 10.11.16) http://archivio.statoregioni.it/Documenti/DOC_055632_Rep.%20212%20%20CSR%20Punto%20%205%20odg.pdf

(13) Ministry of Health. Multiannual National Control Plan 2020/2022. Annual Report 2020 https://www.salute.gov.it/imgs/C_17_pubblicazioni_3263_allegato.pdf

(14) In Italy, the administrative sanctions for violations of the rules contained in reg. (EC) no. 1069/2009 and reg. (EU) no. 142/2011 are established in Legislative Decree 186/2012
(15) Reg. (EU) 2019/1009, which establishes rules relating to the making available on the market of EU fertilising products http://data.europa.eu/eli/reg/2019/1009/oj

(16) Reg. (EC) n. 1069/2009, art. 5, paragraph 2

(17) Poveda J. (2021) Insect frass in the development of sustainable agriculture. A review. Agronomy for Sustainable Development 41: 5, https://doi.org/10.1007/s13593-020-00656-x

(18) Andrea Adelmo Della Penna, Dario Dongo. Black soldier fly larvae, proteins and oils from organic waste. GIFT (Great Italian Food Trade).

(19) Dario Dongo. Nitrogen fertilizers and urea, black crisis in Europe. GIFT (Great Italian Food Trade).

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Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.

Andrea Adelmo Della Penna
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Graduated in Food Technologies and Biotechnologies, qualified food technologist, he follows the research and development area. With particular regard to European research projects (in Horizon 2020, PRIMA) where the FARE division of WIISE Srl, a benefit company, participates.

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