Position papers

Position of IPIFF on the Need for a Supportive Framework for Insect Production Scale-Up

Date: July 2026

IPIFF welcomes plans to revise the framework for Joint Undertakings and the European Competitiveness Fund but argues that these mechanisms need to better support capital-intensive bio-innovation. The insect sector is presented as strategically important for European protein autonomy, circularity, decarbonisation and rural economic development, yet companies face a substantial financing gap between pilot projects and industrial-scale production.

IPIFF proposes a dedicated bio-innovation funding window, EU-backed blended finance and stronger integration with CAP and CFP funding. It also calls for regulatory simplification, including faster Novel Food authorisations, simpler feed additive renewals and authorisation of whole insects in feed, alongside greater coordination between EU programmes.

 Download our contribution paper here.

IPIFF Position Paper: Towards the European Commission Consultation on the European Ocean Act

Date: July 2026

IPIFF argues that the European insect sector should be recognised as a strategic partner in delivering the objectives of the European Ocean Act. Insect-based aquafeed can reduce pressure on wild fish stocks, lower land, water and carbon impacts, valorise organic side streams and reduce Europe’s dependence on imported fishmeal and soy, supporting a more sustainable and resilient blue economy.

IPIFF calls for progressive mandatory inclusion rates for sustainable insect protein in aquafeed, recognition of insect protein as a strategic European resource, wider authorisation of circular substrates, harmonised rules for insect frass and dedicated funding for sector scale-up. It urges the Commission to treat the insect sector as a strategic ally in implementing the Ocean Act.

 Download our contribution paper here.

IPIFF Policy Paper: EU Livestock Strategy – Insects as Strategic Enablers for Resilience, Sustainability and Protein Diversification

Date: April 2026

IPIFF argues that insect farming should be explicitly recognised as a strategic activity within the future EU Livestock Strategy. Insects provide a scalable and circular source of protein that can strengthen feed security, diversify European protein production and support more resilient regional livestock value chains.

The paper calls for clearer insect-specific regulation covering organic production, frass, feeding substrates and market authorisations, alongside targeted funding, public procurement, labelling and market-development measures. It also recommends integrating insects into a formal EU protein-diversification pathway and strengthening monitoring, R&D and regional governance.

 Download our contribution paper here.

IPIFF Position Paper: CAP Mid-Term Evaluation and CAP Post-2027 – Insects: A Strategic, Sustainable and Inclusive Path for the Common Agricultural Policy

Date: April 2026

IPIFF calls for insect farming to be formally recognised and mainstreamed as a legitimate agricultural activity within the CAP Post-2027 framework. The paper highlights its contribution to European protein resilience, circularity, rural employment, reduced resource use and diversification of farmers’ income.

Recommendations include tailored organic and fertiliser standards, improved rules for insect frass and feeding substrates, targeted CAP and public-private financing, regional implementation through CAP Strategic Plans, stronger market development and procurement measures, and dedicated sector indicators. IPIFF argues that these measures would enable insect farming to contribute more effectively to food security, rural development and the EU circular bioeconomy.

 Download our contribution paper here.

IPIFF Position Paper: European Commission Consultation on EU Funding for Competitiveness

Date: April 2026

IPIFF argues that EU funding should more effectively support innovative, sustainable and capital-intensive sectors such as insect production. The paper highlights the sector’s contribution to decarbonisation, protein security, circularity, rural development and reduced dependence on imported animal feed and fertilisers, while noting that regulatory barriers and insufficient access to finance continue to impede scale-up.

IPIFF calls for better alignment of existing EU funding mechanisms, including CAP, EMFAF, the Innovation Fund and industrial decarbonisation measures, alongside increased public-private finance. It also advocates using public procurement, the Agrifood Promotion Policy and binding sustainable protein targets to stimulate market demand and help innovative companies move from research to commercial-scale production.

 Download our contribution paper here.

IPIFF Position Paper: The Critical Role of Insect Meal for a Sustainable, Competitive and Resilient Vision for Fisheries & Aquaculture 2040

Date: March 2026

Drawing on scientific research, industry evidence and dialogue with EU institutions, IPIFF argues that insect meal is already a validated, high-performing and environmentally beneficial aquafeed ingredient. Its wider adoption could reduce reliance on imported protein and fishmeal, strengthen the resilience of EU aquaculture and help address the sector’s environmental footprint and exposure to global market volatility.

IPIFF proposes regulatory reforms to expand circular feeding substrates, stronger sustainability standards for imported ingredients, dedicated EU scale-up funding and progressive mandatory inclusion rates for sustainable aquafeed. Suggested targets include 3% by 2027, rising to 15% by 2030 and 50% by 2050.

 Download our contribution paper here.

Position Paper: The Contribution of the EU Insect Sector to Resilient, Diversified and Prosperous Coastal Communities

Date: March 2026

IPIFF argues that insect production can support the EU Strategy for Coastal Communities by creating green jobs, diversifying fishing-community incomes and strengthening the competitiveness and resilience of European aquaculture. Insect farming can also create local circular value chains by transforming regional food and fish-processing by-products into protein, oil and fertiliser.

IPIFF recommends recognising insect production as a strategic blue-economy activity, supporting coastal circular-economy hubs, improving access to finance and skills training, and introducing progressive targets for sustainable aquafeed. It also calls for wider approval of circular substrates and harmonised frass standards, arguing that these measures could create jobs, improve aquaculture competitiveness and strengthen European strategic autonomy.

 Download our contribution paper here.

IPIFF Position Paper: Organic Production – Targeted Updates and Simplification: The Urgency of Measures to Unlock the Potential of Insects

Date: March 2026

IPIFF welcomes the review of EU organic production rules but argues that regulatory uncertainty is preventing insect farming from contributing fully to the organic sector. It identifies two major barriers: the absence of EU organic certification standards for insect production and the lack of transitional rules allowing organic aquaculture and poultry producers to use insect meal while organic insect production develops.

IPIFF calls for the immediate finalisation of EU organic production rules for farmed insects and temporary derogations permitting conventional insects in organic aquaculture and poultry feed. These measures are presented as a way to address shortages of organic protein, strengthen EU farmer competitiveness and accelerate the development of a more circular and resilient organic food system.

 Download our contribution paper here.

IPIFF Position Paper: Critical Gaps in the “Study on Biomass and Precision Fermentation” – A Call for a Holistic EU Bioeconomy Strategy that Includes Insect Farming

Date: March 2026

IPIFF argues that the EU study on biomass and precision fermentation takes an overly narrow approach by overlooking established and scalable bioeconomy sectors such as insect farming. The paper stresses that insect production is already converting agricultural and food side streams into protein, lipids and fertilisers while contributing to circularity, waste valorisation and reduced import dependency.

IPIFF recommends expanding the study to compare insect farming, biomass fermentation and precision fermentation on equal terms, adopting a portfolio approach to protein innovation and establishing a biomass hierarchy that prioritises higher-value food and feed applications. It also calls for regulatory reforms that enable greater use of bio-waste and facilitate cross-border markets for insect-derived products.

 Download our contribution paper here.

IPIFF Position Paper: Food and Feed Safety – Simplification Omnibus

Date: December 2025

IPIFF welcomes the European Commission’s food and feed simplification initiative, arguing that regulatory simplification, standardisation and greater predictability are essential for scaling Europe’s insect sector while maintaining high food and feed safety standards. The paper highlights outdated and fragmented rules as an obstacle to investment, competitiveness and circularity.

IPIFF recommends simplifying feed additive renewals, authorising whole insects for animal feed, clarifying the use of former foodstuffs and agri-food by-products, introducing a six-month timeframe for Novel Food authorisations following a positive EFSA opinion, and widening the range of permitted circular substrates. These reforms would reduce administrative burdens, strengthen EU competitiveness and support a more circular, domestically produced protein supply.

 Download our contribution paper here.

InnovProtein EU Alliance Joint Position Paper: Evaluation of Public Procurement Directives

Date: December 2025

The InnovProtein EU Alliance — representing the insect, algae and yeast sectors — calls for reform of EU Public Procurement rules so that public spending more effectively supports innovative and sustainable protein production. The paper argues that these sectors can contribute to food security, reduced import dependency, environmental sustainability and greater resilience within the European food system.

The Alliance proposes directing more public procurement spending towards innovative proteins, introducing binding sustainability standards and minimum requirements for alternative protein ingredients, and using procurement to create lead markets for insects, algae and yeast. It also calls for public spending to better support EU strategic autonomy, competitiveness, the circular economy and sustainable agriculture and aquaculture.

 Download our contribution paper here.

IPIFF Position Paper: Call for Evidence for a European Innovation Act

Date: October 2025

IPIFF welcomes the European Innovation Act but argues that the existing innovation framework does not adequately support capital-intensive bio-industries such as insect production. Key barriers include fragmented regulation, limited access to scale-up finance, difficulties leveraging intellectual property, insufficient testing infrastructure and procurement rules that fail to properly value circular and sustainable products.

IPIFF proposes adapting the Innovation Fund to recognise circularity alongside carbon reduction, improving access to finance, harmonising permitting and substrate rules, introducing regulatory sandboxes and using public procurement to create markets for sustainable proteins. It also calls for stronger alignment with the EU’s Bioeconomy Strategy, Net-Zero Industry Act, Start-up and Scale-up Strategy, CAP, CFP and wider protein strategy.

 Download our contribution paper here.

IPIFF Position Paper: Towards the Recognition of Insect Bioconversion as a Strategic Net-Zero Technology in the EU’s Public Procurement Framework

Date: October 2025

IPIFF calls for the formal recognition of insect bioconversion as a strategic net-zero technology within the EU’s public procurement framework. The paper highlights how insect farming supports Europe’s climate and circular economy objectives by transforming agri-food side streams into sustainable protein, organic fertiliser and biogas opportunities, while reducing resource use and dependence on imported proteins.

IPIFF recommends that insect bioconversion be considered in future reviews of Regulation (EU) 2024/1735, supported by harmonised sustainability standards, future implementing acts and pilot Green Public Procurement projects.

 Download our contribution paper here.

IPIFF Position Paper: Unlocking Nature-Positive Investment – The Case for Including the Insect Sector in the EU Nature Credit Framework

Date: September 2025

IPIFF argues that insect farming should be recognised within the EU Nature Credit Framework because insect bioconversion inherently generates measurable nature-positive benefits. By transforming organic side streams into valuable proteins and fertilisers, the sector can contribute to circularity, biodiversity protection, reduced pressure on natural resources, food-system resilience and climate mitigation.

IPIFF recommends making sustainable insect farming explicitly eligible for nature credits, developing sector-specific methodologies to quantify its environmental benefits and supporting dedicated pilot projects through EU programmes. It also stresses that the certification system must remain accessible and affordable for the SMEs that make up much of the sector.

 Download our contribution paper here.

IPIFF Position Paper: 28th Regime – An Opportunity to Support the Scale-Up of the EU Innovative Sector of Insect Production

Date: September 2025

IPIFF supports the European Commission’s proposed optional “28th regime” as an opportunity to create a more unified EU corporate framework for innovative businesses. For insect producers, the initiative could reduce regulatory fragmentation, simplify cross-border expansion, lower administrative burdens and improve access to investment.

IPIFF recommends making the regime accessible to SMEs and scale-ups through low capital requirements, rapid digital company formation, the “once-only” principle for company information and flexible investment structures. It also calls for simplified cross-border employment and insolvency rules to create a framework capable of supporting innovative European bioeconomy businesses throughout their growth.

 Download our contribution paper here.

IPIFF Position Letter to the Danish Presidency of the Council of the European Union- Insects’ protein for food and feed – supply, production and sustainability

Date: July 2025

IPIFF welcomes the Danish Presidency’s initiative to emphasise the vital role of proteins in food and feed, particularly in addressing issues related to supply, production, and sustainability. However, we note that the preparatory note for the upcoming Agriculture and Fisheries Council meeting on the 14th of July primarily centres on plant proteins, without sufficiently considering the contribution of insects or other alternative protein sources in developing a comprehensive future protein strategy.

 Download our contribution paper here.

IPIFF Contribution Paper as regards the classification of certain killing methods in insect production as ‘primary production’ activities

Date: May 2025

The killing of farmed insects is not specifically mentioned under EU food and feed hygiene rules. E.g. Annex I to Regulation (EC) No 852/2004 includes references to the ‘hygiene slaughtering of animals,’ whereas Regulation (EC) No 853/2004 (laying down specific hygiene rules for food of animal origin) refers to ‘slaughter’ and ‘killing’ activities for the different categories of animals covered under the sections of its annex III. Farmed insects are not covered under any of the sections of the concerned annex.

 Download our contribution paper here.

IPIFF Position Paper towards the European Commission’s Consultation on EU funding for competitiveness

Date: May 2025

With this position paper, IPIFF aligns with the European Commission’s identified challenges in this consultation paper, which resonate with the EU insect-producing sector. By addressing these challenges effectively, better financial allocation under the EU budget can be achieved and thus, improve the EU’s innovative competitiveness.

 Download our position paper here.

IPIFF Position Paper: EU Start-up and Scale-up Strategy

Date: April 2025

IPIFF calls for stronger and more targeted EU support to help the European insect sector overcome the barriers facing innovative start-ups and scale-ups. The paper identifies three central priorities: improving competitiveness by removing regulatory barriers, stimulating demand for insect-derived products and catalysing investment through stronger public and private financing mechanisms.

IPIFF advocates greater recognition of insect production across EU protein, agricultural, industrial and research policies, alongside improved access to finance and measures that open new markets for sustainable proteins. The paper argues that these changes would enable insect businesses to scale while strengthening Europe’s food resilience, circular economy and sustainable protein production.

 Download our contribution paper here.

IPIFF Position Paper: Public Consultation – CFP Regulation Evaluation

Date: April 2025

IPIFF calls for greater recognition and support for sustainable aquafeed, particularly insect-based proteins, within the EU Common Fisheries Policy. The paper argues that increasing the use of insects in aquafeed could reduce reliance on fishmeal and soybean meal, protect marine biodiversity and improve the environmental, economic and social sustainability of European fisheries and aquaculture.

IPIFF recommends targeted funding for sustainable aquafeed production, alongside progressive binding targets for its inclusion in EU aquafeed — proposing 2% by 2027, 5% by 2030 and 50% by 2050. It also calls for greater regulatory alignment to support circular feed ingredients and increased use of insects within organic aquaculture.

 Download our contribution paper here.

IPIFF Position Paper towards the Common Fisheries Policy Regulation Evaluation

Date: March 2025

With this position paper, IPIFF calls for greater support of insect-based aquafeed within the Common Fisheries Policy to enhance sustainability and align with EU environmental goals.

 Download our contribution paper here.

IPIFF Position Paper towards the Net-Zero Industry Act

Date: March 2025

With this position paper, IPIFF welcomes the Net-Zero Industry Act and calls for recognition of insect sector contributions to EU biogas goals through regulatory clarification on frass use.

 Download our contribution paper here.

InnovProtein EU Alliance Joint Position Paper towards the EU Evaluation of Public Procurement Directives

Date: March 2025

With this position paper, the InnovProtein EU coalition reaffirms its joint commitment to advancing sustainable food systems by promoting insect, algae, and yeast proteins in line with the EU Farm to Fork Strategy.

 Download our position paper here.

IPIFF Position Paper towards the EU Startup and Scaleup Strategy

Date: March 2025

With this position paper, IPIFF highlights the rapid growth and job-creating potential of the European insect sector, calling for tailored EU support to help scale production and strengthen rural economies.

 Download our contribution paper here.

IPIFF Feedback to the Net-Zero Industry Act: List of Net-Zero Technology Final Products and Their Main Specific Components

Date: February 2025

IPIFF welcomes the EU Net-Zero Industry Act and its ambition to strengthen European manufacturing capacity for net-zero technologies. The paper highlights the contribution the insect sector can make, particularly through the valorisation of insect frass in sustainable biogas and biomethane production.

IPIFF calls for regulatory clarification allowing processed insect frass to be used as a starting material for composting and biogas transformation. This would provide additional outlets for increasing volumes of frass, strengthen the competitiveness of European insect producers and contribute to the EU’s transition towards a circular and decarbonised economy.

 Download our contribution paper here.

IPIFF Position Paper towards the Committee of the Regions Opinion on ‘The Future Common Agricultural Policy’

Date: March 2024

With this contribution paper, IPIFF expresses the full commitment of the European insect sector to cooperate with the Committee of the Regions in order to promote the economic, social, and territorial development of the EU regions and, rural areas.

 Download our contribution paper here.

IPIFF Pledge Letter and Commitments towards the Code of Conduct for Responsible Food and Businesses and Marketing Practices

Date: 24 May 2023

IPIFF is actively supporting the development of the European insect sector. To accomplish its mission, the association helps its members in the effective implementation of EU food and feed safety legislation, such as through the development of shared standards and good hygiene practices.

 Download our pledge letter here.

IPIFF Stakeholder Contribution Paper on the Hungarian Authorities Notification on the National Decree to provide consumers with additional information on insect novel food products- Notification Nbr 2023/0109/HU

Date: 12 June 2023

In the present document, IPIFF outlines the views of the EU insect producers, on the manifested intention on behalf of the Ministry of Agriculture of the EU Member State of Hungary.

 Download our position paper here.

IPIFF Stakeholder Contribution Paper on the Romanian Authorities Notification on the Order requiring economic operators to provide consumers with clear and complete information on foods that contain species of any insects authorised to be placed on the market as novel foods

Date: 12 June 2023

The present document outlines the views of the EU insect producers, in response to the Order on behalf of Romanian authorities requiring economic operators to provide consumers with clear and complete information on foods that contain species of any insects authorised to be placed on the market as novel foods.

 Download our position paper here.

IPIFF Contribution Paper to the European Commission Initiative on Food Waste Reduction Targets

Date: January 2023

IPIFF welcomes this initiative promoted by the European Commission in the context of the revision of the Waste Framework Directive (WFD). We strongly believe that the inclusion of EU-level targets for food waste reduction will strongly support the achievement of the objectives set out in the Farm to Fork Strategy.

 Download our position paper here.

IPIFF Contribution Paper to the European Commission Initiative on Nutrients Action Plan for Better Management

Date: January 2023

IPIFF welcomes this initiative on behalf of the European Commission. We believe that the target presented in the European Green Deal for reducing nutrient losses by 50% by 2030 is essential and that an integrated Nutrient Management Action Plan is a unique opportunity to consider the nutrient cycles globally and to provide a holistic and sustainable approach to nutrient management.

 Download our position paper here.

IPIFF Contribution Paper on the inclusion of insect frass as part of the EU fertilisers’ Regulation

Date: 2 December 2022

The International Platform of Insects for Food and Feed (IPIFF) – the Brussels-based umbrella organisation representing stakeholders active across the insect production value chains – is happy to share its contribution paper in including insect frass under CMC 10 (Annex II) of the EU Fertilisers’ Regulation

 Download our contribution paper

IPIFF position paper as regards the determination of an end point for insect frass in organic fertilisers (Reg. 1069/2009)

Date: 21 October 2022

The International Platform of Insects for Food and Feed (IPIFF) – the Brussels-based umbrella organisation representing stakeholders active across the insect production value chains – is happy to share its position paper on to the revision of the Draft Commission Delegated Regulation – Supplementing Regulation (EC) No 1069/2009 as regards the determination of end points in the manufacturing chain of certain organic fertilisers and soil improvers

 Download our position paper here.

IPIFF position paper on the use of insect larvae as feed for food-producing animals

Date: 16 September 2021

The International Platform of Insects for Food and Feed (IPIFF) – the Brussels-based umbrella organisation representing stakeholders active across the insect production value chains – is happy to share its position paper on the use of insect larvae as feed for food-producing animals.

 Download our position paper here.

Contribution Paper – EU organic certification of insect production activities

Date: 19 July 2021

The International Platform of Insects for Food and Feed (IPIFF), the focal point of the European insect production sector in Brussels, is pleased to share its updated Contribution Paper ‘The European insect sector’s response to the growing demand for EU organic products’.

 Download our contribution paper on the EU organic certification of insect production activities.

Briefing Paper – The provisions relevant to the commercialization of insect-based products intended for human consumption in the EU

Date: 23 June 2021

This updated version (June 2021) of the briefing paper published in May 2018 elaborates on the procedures related to the authorisation of a novel food (namely the transitional measure), but also on the role of the European authority in charge of risk assessment throughout the food chain – the European Food Safety Authority (EFSA). Furthermore, it also addresses potential scenarios for FBOs during the transitional period and steps following the authorisation of a novel food application (data protected/non-data protected).To this end, the Briefing paper includes up-to-date information on the EFSA Administrative Guidance, improving the overall understanding of current and prospective applicants with regards to the criteria necessary for a comprehensive application (the completeness checklist has to be fulfilled) and the factors which could influence the estimated timeframe – such as the ‘stop-the-clock’ procedure.

Please note that recently added text appears in red. 

Download the briefing paper.

IPIFF Contribution Paper – Specific labelling criteria for edible insect food products in the European Union (EU)

Date: 18 November 2020

The International Platform of Insects for Food and Feed – the European association representing European insect producers – is publishing today its ‘Contribution Paper on specific labelling criteria for edible insect food products in the European Union (EU)‘, a document which presents the position of the umbrella association on with regard to labelling specifications for edible insect products and related recommendations.

Download the Contribution Paper here.

IPIFF Contribution – Commitment of the European insect sector towards more resilient and sustainable food supply systems

Date: 09 April 2020

The well-functioning of our food supply systems is essential to ensure food security for affected populations around the globe during times of crisis. Alike for many other food sectors, the COVID-19 pandemic poses numerous challenges to insect producers in Europe and around the globe. Exclusively composed of SMEs and ‘newly established’ businesses, the insect sector is, indeed, facing important disruptions as a consequence of this unprecedented crisis.

Download the IPIFF Contribution here.

Position Paper – The contribution of the European insect sector to improving sustainability from ‘Farm to Fork’

Date: 18 February 2020

The International Platform of Insects for Food and Feed – IPIFF – the Brussels-based umbrella organisation representing stakeholders active across the insect production value chains publishes today a ‘Position Paper‘ entitled ‘The Contribution of the European Insect Sector to Improving Sustainability from Farm to Fork‘.

Download the IPIFF Position Paper on the ‘Farm to Fork’.

Contribution Paper – The application of insect frass as fertilising product in agriculture

Date: 19 September 2019

The International Platform of Insects for Food and Feed – the European association representing the stakeholders involved in the production of insects – is publishing today its ‘Contribution Paper on the application of insect frass as fertilising product in agriculture‘, a document which presents the position of the umbrella association as part of its strategy to expand the circularity potential of insect production.

Download the IPIFF contribution on insect frass application as fertilising product.

Position Paper – The revision of EU food hygiene legislation and import rules for insects as food

Date: 5 November 2018

As EU umbrella organisation for the insect production sector, IPIFF welcomes the establishment of harmonised rules to spell out hygiene requirements and EU import conditions for food insect products.

Download our position paper on the revision of the EU food hygiene rules & imports of insects.

Contribution Paper – The development of a European Protein Plan

Date: 28 September 2018

The present document explains how in her view the insect sector may contribute to respond to the challenge of the EU protein deficit (see chapter 1) and sets a series of general recommendations for the EU protein plan along that line (see chapter 2).

 Download our IPIFF contribution paper on the development of a European Protein Plan. 

Possible approaches to addressing data requirements for novel food applications for insects and insect-derived products in the EU

Date: 16 May 2018

The present document has been prepared for the International Platform of Insects for Food and Feed (IPIFF) in relation to the regulatory requirements including risk assessment of insects intended for human consumption in the European Union (EU). This document provides an overview of the main aspects that should be considered when preparing an application for the authorisation of insects for human consumption under Regulation (EU) 2015/2283 on novel foods.

 Download our IPIFF summary.

Position Paper – The use insect proteins as animal feed

Date: 26 July 2017

IPIFF believes that insects will soon constitute a reliable alternative or addition to fishmeal feed formulae for aquaculture: insect nutritional characteristics (e.g. protein content, amino acid profile and/or digestibility levels) are indeed comparable to those of fishmeal products, making them a pertinent substitute or addition in the diet of certain fish species (e.g. trout or Atlantic Salmon) or shellfish (e.g. shrimps).

Download our position paper on the use of insect proteins in animal feed.

Position Paper – Implementation of EU Regulation 2015/2283 on ‘novel foods’

Date: 29 November 2016

IPIFF considers that the establishment of harmonized rules for the marketing of insect products is a ‘step in the right direction’: while insects have the potential to become a major source of protein in Europe, insect producers primarily rely on a ‘solid’ and ‘stable’ EU regulatory framework to plan their investment marketing activities throughout the continent.

Download our position paper on the implementation of EU NF regulation.