From aquaculture to kibble: the insect-protein authorisation timeline
Insect protein — chiefly black soldier fly (Hermetia illucens) — moved from a regulatory curiosity to an authorised pet-food ingredient in less than a decade. The path ran through two separate systems with opposite instincts: the European Union, which opened the door for farm animals first under its transmissible-spongiform-encephalopathy (TSE) feed-ban framework, and AAFCO in the United States, which built its path species-by-species and life-stage-by-life-stage, landing on cats last. This article lays the timeline end to end and contrasts the two rhythms.
The backbone is the EU "feed ban" under Regulation (EC) No 999/2001, which prohibited feeding farmed animals protein derived from animals. Insect processed animal proteins (PAPs) carved out exceptions to that ban, one animal class at a time.
2017 — the first crack: aquaculture (EU)
The first insect-specific EU authorisation was Commission Regulation (EU) 2017/893, which "amended Annex IV of Regulation (EC) No 999/2001" and "permitted the use of processed animal proteins (PAPs) derived from insects in aquaculture feed" for the first time in EU history. It covered seven insect species — black soldier fly, common housefly, yellow mealworm, lesser mealworm, house cricket, banded cricket and Jamaican field cricket. Aquaculture was the natural first opener: it is the largest animal-feed sector by volume of insect-derived protein, and the risk profile was judged acceptable on the EFSA pathogen opinion. Pet food, already the most permissive category, was not the focus of this text — but the 2017 aquafeed step was the precondition for everything after.
2021 — poultry, pigs, and a silkworm (EU)
Two 2021 steps widened the EU door. Commission Regulation (EU) 2021/1372 was "published in the Official Journal of the European Union on 17 August 2021 and entered into force on 7 September 2021," amending Annex IV to authorise insect PAPs in poultry and pig feed. The political path was explicit: EU member states voted 25 of 27 in favour on 13 April 2021. Per IPIFF, this opened "two of the most relevant EU animal-feed markets, which represent circa 65% of the EU's compound feed production." The same seven species carried over.
Then Regulation (EU) 2021/1925, "adopted November 2021," added silkworm (Bombyx mori), taking the authorised list from seven to eight species, usable in aquaculture, poultry and pig feed. The silkworm addition is telling: it validated the EU's "incremental authorisation" pattern — add species one by one as EFSA opinions accumulate, rather than waiting for a single comprehensive review.
A note buried in the 2021/1925 topic is the twist of the whole story: "the pre-existing pet food market for insect PAPs in Europe was the first commercial scale use of insect protein in animal feed even before the 2017 aquaculture authorisation." So in the EU, pets ate insect protein first, even though the regulation named livestock first.
2021 — AAFCO's tentative entry: adult dog
Across the Atlantic, AAFCO moved on a different clock. At the Ingredient Definitions Committee (IDC) Midyear Meeting, January 2021, the Pet Food Committee discussed a new tentative definition, and "T60.117(C) Dried Black Soldier Fly Larvae" was "tentatively approved in August 2021" at the AAFCO Annual Meeting. The definitive text authorises the ingredient "for use in salmonid, poultry, and swine feed and in adult dog food." This was "the first time AAFCO explicitly added 'adult dog food' to the BSFL use list" — the formal entry of insect protein into the US pet-food regulatory framework. Notably, AAFCO's first pet-food step was dogs, not cats, and the definition was tentative, not official.
2024 — official for finfish, and cat oil (AAFCO)
At the Hyatt Regency San Antonio Riverwalk on August 7, 2024, the IDC annual meeting carried several BSFL motions. T60.117(A) Dried Black Soldier Fly Larvae moved to OFFICIAL for finfish (joining the earlier tentative uses for poultry, swine and adult dog). More relevant to pets, T33.29(B) Black Soldier Fly Larvae Oil moved to OFFICIAL, extending use to adult cat food for the first time. A new tentative, T33.29(C) BSFL Oil (Poultry), completed the cross-species matrix. So by late 2024, AAFCO had an official insect ingredient for cats — but only the oil, not the dried larvae.
2025 — the loop closes: official for dog and cat (AAFCO)
The consolidation came at the IDC Midyear Meeting in Little Rock, Arkansas, January 21, 2025. The motion: "Move to Official and replace current Official: T60.117 Dried Black Soldier Fly Larvae" — now "for use in finfish, poultry, and swine feed, and in adult dog food, and adult cat food." This "closes the regulatory loop" for BSFL Dried Larvae as a federally-official pet-food ingredient in the US. The new element versus 2021 is adult cat food: until 2025, dried BSFL larvae for cats had no US feed-law authorisation, because AAFCO's expert-panel review is per species and life stage and "the cat food approval had to wait for completion of the cat-specific safety/efficacy dossier."
EU vs AAFCO — two rhythms, same insect
Read side by side, the timelines reveal a structural asymmetry:
- EU authorised species broadly, animals narrowly. Eight insect species (seven from 2017, silkworm from 2021) are legal in aquaculture, poultry and pig feed. Pet food was always the permissive outlier.
- AAFCO authorised one insect, broadly across animals. So far the official definitions cover only black soldier fly — dried larvae (T60.117) and oil (T33.29). The other six EU species (housefly, mealworm, the three crickets, lesser mealworm) have no AAFCO definitions in this dataset. US pet food can use BSFL; it cannot yet point to an AAFCO-defined housefly or mealworm ingredient.
- The cat lag is real in both systems, but for opposite reasons. The EU never needed to "add" cats (pet food was pre-permitted); AAFCO explicitly held cats until the 2024 oil and 2025 larvae decisions.
| Year | EU | AAFCO |
|---|---|---|
| 2017 | 2017/893 — insect PAPs in aquafeed (7 species) | — |
| 2021 | 2021/1372 — poultry + pig (Aug/Sep); 2021/1925 — silkworm (Nov, 8 species) | T60.117(C) BSFL tentative — adult dog (Aug) |
| 2024 | — | T60.117(A) BSFL official — finfish; T33.29(B) BSFL Oil official — adult cat |
| 2025 | — | T60.117 BSFL official — dog + cat (Jan) |
What this means for the label
For a formulator in 2026, the practical picture is: in the EU, insect PAPs from up to eight species are legal in livestock feed and available in pet food under the permissive pet category; in the US, black soldier fly (larvae and oil) is now an official AAFCO-defined ingredient for adult dogs and cats, with state feed laws adopting it by reference. The next likely US step — absent from this dataset — would be official definitions for the other EU-authorised species. Until then, "insect protein" on a US bag means, in regulatory terms, almost always black soldier fly.
Sources
All dates, regulation numbers and definition texts are verbatim substrings of the source topics (EU primary regulation via IPIFF guide; AAFCO IDC minutes). Quoted definition texts are reproduced from the cited AAFCO minutes.
eu_2017_893_aquaculture_first_authorization_insect_pap— Reg (EU) 2017/893 amended Annex IV of 999/2001; insect PAPs in aquaculture feed; 7 species.eu_2021_1372_poultry_pig_insect_pap— published 17 Aug 2021, in force 7 Sep 2021; poultry + pig; 25/27 vote 13 Apr 2021; ~65% of EU compound feed.eu_2021_1925_silkworm_added_to_authorised_species— adopted Nov 2021; silkworm (Bombyx mori); 7→8 species; pet food pre-existing market noted.aafco_2021_t60_117_bsfl_adult_dog_tentative— IDC Midyear Jan 2021; T60.117(C) tentative Aug 2021; adult dog food; first AAFCO BSFL pet-food use.aafco_2024_t60_117a_bsfl_official_finfish— Hyatt Regency San Antonio, 7 Aug 2024; T60.117(A) official finfish; T33.29(B) BSFL Oil official adult cat; T33.29(C) tentative poultry.aafco_2025_t60_117_bsfl_official_adult_dog_cat— Little Rock, AR, 21 Jan 2025; T60.117 official finfish + poultry + swine + adult dog + adult cat; loop closed.