Insect breeding – aside from providing raw materials for feed and food – enables the production of frass, an organic fertilizer or soil conditioner that expresses an excellent example of circular economy in agribusiness systems.
This material also lends itself to other valuable uses, in agriculture as well 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
Frass is ‘a mixture of excrement derived from farmed insects, food substrate, farmed insect parts and dead eggs, with a content of dead farmed insects not exceeding 5 percent by volume and not exceeding 3 percent by weight.’ (1)
Regulation (EU) 2021/1925 – in addition to defining frass, in the terms mentioned above – reformed the regulation of organic fertilizers and soil improvers, which was already established in the implementing measures for animal by-products (animal by-products, ABPs). (2)
IPIFF, International Platform of Insects for Food and Feed, has played a central role in promoting the adoption of a European regulation to ensure 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 regulation of animal by-products (ABPs), which include frass, is autonomous from that of waste. (4) Frass, in particular, falls under Category 2 – medium risk (5) – of animal by-products. Like processed stallactic, in fact, it is subject to similar marketing requirements: (6)
– materials come from a derivative manufacturing plant for uses outside the feed supply-chain, or from a biogas or composting plant, or from an organic fertilizer or soil conditioner production plant,
– ABPs are subjected to heat treatment (at least 70 °C for 60 minutes) and sporigenic bacteria and toxinogenesis reduction treatment if they are recognized as a relevant risk,
– representative frass samples, taken for process control purposes during or at the end of processing in the plant, meet specific microbiological requirements (Escherichia coli: n = 5, c = 5, m = 0, M = 1 000 in 1 g; or Enterococcaceae: 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 should be stored in tightly closed and insulated and properly constructed silos; or in tightly closed packaging (plastic bags or ‘big bags‘).
2.1) Obligations of operators
Operators handling ABPs – in addition to fulfilling specific obligations for the production and marketing of organic fertilizers and soil improvers – must implement at the supply chain level the following general obligations: (8)
– collection and transportation accompanied by commercial documents bearing information on origin, destination, quantity and description of ABPs, including category,
– traceability, by recording both batches and commercial documents, as well as suppliers and customers,
– registration or approval (required for treatment or production of frass as organic fertilizer or soil conditioner) 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 an HACCP plan and internal controls.
2.2) Official checks
The animal by-products (ABPs) are subject to official controls under the Official Controls Regulation (EU) No 2017/625, with the aim of preventing and minimizing health risks from them, or from by-products. Official controls must be carried out at all stages of production, processing and distribution. (9)
In Italy, official controls are entrusted to the Veterinary Services of ASL, USL or ATS, on the basis of regional provisions adopted in accordance with State-Regions agreements and understandings, referring both to these by-products and to official controls on the agri-food chain (still awaiting update with respect to EC Reg. 882/2004. See notes 10,11,12).
The 2020 Annual Report on the 2020/2022 Multi-Year National Control Plan, reports on numerous nonconformities, mainly in terms of not properly complying with general requirements (e.g., HACCP plan, staff training, business documents). With attention to registration and/or recognition of operators, which are essential to organize controls and to know the quantities and flows of ABPs produced and handled nationwide (13,14).
3) Fertilizer products regulation
Almost all animal by-products are excluded from the scope of Fertilizers Regulation (EU) No 2019/1009, (15) except for two of the thirteen categories of constituent materials (CMCs), which are instead allowed in fertilizer production in the EU:
– CMC 3 – Compost. Obtained by aerobic composting of category 2 or 3 (medium-low risk) materials and/or products derived from them, alone or mixed with other materials allowed in compost,
– CMC 10 – Derived products in accordance with Regulation (EC) 1069/2009. However, the list of such derivative products is not available to date, pending an appropriate delegated act by the European Commission.
In both cases, it is necessary for the materials to have reached the final stage of production, so that they lose their qualification as ABPs. However, these conditions are to be defined by the European Commission in another delegated act yet to be adopted. (16)
4) Frass, uses in agriculture
The nutrient mix in frass is rapidly assimilated by the root systems of numerous plants, edible and otherwise. And it is able to contribute to macronutrient (e.g., nitrogen) requirements to a significant extent, more functionally than other fertilizers, with sensitive allocation on leaves. The feeding of insects, as well as their species, affects both the mineral composition of frass and its microbiota, which is also influential when used as an organic fertilizer. (17)
Another prominent feature is the ability of frass to increase plant resistance to abiotic stresses (i.e., high salinity, drought or waterlogging). This ability is attributed precisely to the frass microbiota, which consists of nitrogen-fixing microorganisms and fungi capable of:
– make phosphates and potassium soluble,
– synthesize certain phytohormones (e.g., auxins) or enzymes to reduce excess ethylene in plants (i.e., ACC deaminase),
– activate the plant’s native defenses and contain attacks by pathogens or pests.
5) Frass, uses in animal husbandry and aquaculture
In animal nutrition, as seen, frass has been shown to be able to improve the nutritional status of animals and the quality of fish. (18) An opportunity for circular economy development in agribusiness systems.
However, European legislation must come up to date in order to take advantage of these opportunities, as Regulation (EU) No. 142/2011 only contemplates the use of Processed Animal Proteins (PAPs).
6) Interim conclusions
Beyond its qualification as a ‘by-product’ (of animal origin), frass is a product with many functionalities. Of particular interest among other things at a time in history when nitrogen fertilizer costs have skyrocketed. (19)
It should be noted, however, that the use of frass is currently permitted in the EU only as an organic fertilizer or soil conditioner. Its uses as fertilizer and feedstock still have to await implementing regulations and reforms.
Dario Dongo and Andrea Adelmo Della Penna
Notes
(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 fertilising product in agriculture. https://tinyurl.com/me5237hp 19.9.19
(4) Waste and by-products are regulated by theWaste Frameword Directive 2008/98/EC. 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 (high risk) materials,
(b) Category 2 (medium risk) materials,
(c) Category 3 (low risk) materials.
(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 of 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 other samples is m or less)
(8) Regulation (EC) No. 1069/2009, Articles 21-26, 28, 29
(9) Regulation (EU) 2017/625, Art. 20(1).
(10) Agreement between the Government, the Regions and the Autonomous Provinces of Trento and Bolzano and the Local Authorities on the document on “Guidelines for the implementation of Regulation (EC) No. 1069/2009 of the European Parliament and of the Council of October 21, 2009 laying down health rules concerning animal by-products and derived products not intended for human consumption and repealing Regulation (EC) No. 1774/2002“. (HEALTH) Site Code: 4.10/2012/70 (Service III) Agreement pursuant to Article 9(2)(c) of Legislative Decree August 28, 1997, no. 281. (Acts Rep. No. 20/CU, 7.2.2013) http://archivio.statoregioni.it/Documenti/DOC_039696_20%20CU%20P.%2011.pdf
(11) Agreement, pursuant to Article 4 of Legislative Decree Aug. 28, 1997, no. 281, between the Government, the Regions and the Autonomous Provinces of Trento and Bolzano on the document on “Guidelines for the Operation and Improvement of Official Control Activities by the Ministry of Health, Autonomous Regions and Provinces and AASSLLs on Food Safety and Veterinary Public Health” (Acts Rep. 46/CSR, 7.2.13) https://www.gazzettaufficiale.it/eli/id/2013/03/27/13A02503/sg
(12) Understanding, pursuant to Article 8, Paragraph 6, of Law No. 5 June 2003. 131, between the Government, the Regions and the Autonomous Provinces of Trento and Bolzano on the document concerning “Guidelines for official control under Regulations (EC) No. 882/2004 e 854/2004” (Acts Rep. No. 212/CSR dated 10.11.16) http://archivio.statoregioni.it/Documenti/DOC_055632_Rep.%20212%20%20CSR%20Punto%20%205%20odg.pdf
(13) Ministry of Health. 2020/2022 Multi-Year National Control Plan. 2020 Annual Report https://www.salute.gov.it/imgs/C_17_pubblicazioni_3263_allegato.pdf
(14) In Italy, administrative penalties for violations of the rules contained in Reg. 1069/2009 and reg. (EU) no. 142/2011 are set out in Leg. 186/2012
(15) Reg (EU) 2019/1009, laying down rules concerning the making available on the market of EU fertilizer products http://data.europa.eu/eli/reg/2019/1009/oj
(16) Reg. (EC) no. 1069/2009, Art. 5(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 wastes. GIFT (Great Italian Food Trade). 11.4.22
(19) Dario Dongo. Nitrogen fertilizers and urea, black crisis in Europe. GIFT (Great Italian Food Trade). 29.8.22
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
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.
