New proposals regulating organic labeling and insect farming are under discussion. How could they potentially affect pet food producers?
In the context of both a healthy diet and the environment, Europeans care about the food they consume themselves, and they are also increasingly conscious of the food they buy for their pets. Therefore, many pet food producers are striving to develop highly nutritious, premium products that contribute to pet health while also meeting owners’ demands for more sustainable options. Considerable strides have recently been made in pet food innovation.
A close eye on changes around insects
However, protein production is at the core of any food strategy, whether at the national or supranational level, and food safety is closely governed by policies in the European Union (EU). Producers of food for humans or pets in Europe need to keep a close eye on any legislative changes that may affect them.
Right now, this is particularly the case for pet food manufacturers who are exploring the potential benefits of organically produced insects as an alternative, more sustainable source of protein.
Known for their reduced overall footprint, insects are among the most efficient sources of protein in terms of output per area of land. Their fast rate of development and growth allows several cycles of insects to be farmed per year. In view of this, in combination with the incorporation of vertical farming principles in insect farming, insects are up to 70 times more environmentally efficient than commonly used proteins of vegetal origin.
EU Organic Regulation creates uncertainty
However, the new EU Organic Regulation that came into force on 1 January 2022 falls somewhat short in the integration of labeling rules used for pet food, resulting in a degree of legislative uncertainty surrounding organically farmed insects. While ingredients of non-organic origin are authorized for use in organic feed, manufacturers are not permitted to make any reference to organic production, or display the EU organic logo, unless 100% of the ingredients are sourced from organic production.
As a result, although feed and pet-food processing companies are informed about the organic and non-organic origin of ingredients, that information often does not subsequently appear on the retail packaging.
Legal clarification on labeling
On 28 November 2022, the European Commission adopted a legislative proposal aimed at establishing a new regulatory framework for the labeling of organic pet food products in the EU. The draft rules clarify that pet food can be labeled as organic if at least 95% (by weight) of its agricultural ingredients are organic.
This clarification is critical since – in the current absence of EU-level legislation for organically produced insects – pet food manufacturers who want to complement their mix with nutritious insect-derived protein can now make use of the 5% leeway. The draft text has now entered the final phase of discussion and it is hoped that the regulation will be adopted and will enter into force soon, possibly even before the end of 2023.
The reality of organic insect farming
In parallel, discussions are ongoing between the European Commission and the EU member states with a view to establishing organic production rules for farmed insects. The Expert Group for Technical Advice on Organic Production (EGTOP) has recently been consulted for its recommendations. These are expected to be published during the second half of this year, after which the EU discussions will be able to resume.
Current EU legislation does not take into account invertebrate animals such as insects, which may lead to unrealistic standards. Therefore, in the context of these discussions, the International Platform of Insects for Food and Feed (IPIFF) calls for tailormade organic rules that should apply to the insect-farming reality.
A compromise could be reached by mid-2024, thereby paving the way for final adoption of this new legislation before the end of next year. Then, insect ingredients complying with the future EU standards for organic insect production will be eligible for use in organic pet food, above the 5% leeway that will hopefully be authorized under the proposed EU rules for organic pet food.
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