Waste processing companies and zoos have a lot of Category 3 material (animal by-products) and manure. Category 3 material can contain meat and fish residues, as well as small amounts of plastic. This concerns, for example, food that has passed the date. This should of course not end up in the food chain. Therefore, no category 3 material may be fed to farm animals. To protect human, animal and environmental health.

Larvae are classified under the “Farmed Animal” category. However, the natural food for larvae is manure. But they are not allowed to eat manure, because they are “farmed animals” that are used for the production of food or other animal husbandry purposes.

But if larvae of the Black Soldier Fly on Category 3 material are fattened and then used as a raw material for biobased products: do they then fall outside the definition of “farmed animals”?

This definition is namely according to EU Regulation 1069/2009, Article 3, paragraph 6 under a: “any animal that is kept, fattened or bred by humans and used for the production of food, wool, fur, feathers, hides and skins or any other product obtained from animals or for other farming purposes;”

If the larvae are fattened on category 3 material, a waste processor does so with the aim of using them as raw materials for biobased products, such as biodiesel, bioplastic, adhesives, coatings and green chemicals. These are not animal husbandry purposes. And if a zoo breaks down the manure from the zoo animals with BSF larvae to realize an educational attraction about circularity and thereby save on feeding costs (because the larvae are fed to the monkeys), these are not farming purposes either. In such cases they fall outside the definition of “farmed animal”? This has been communicated with the European Commissioner. Indeed, there seems to be room here, in view of his statements made on 9 August 2018, in response to questions from VVD MEP Jan Huitema.

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