How We Changed the Legal Environment of Our Startups

The 20th of September 2017 big news came out: Evira, the Finnish FDA, changed its interpretation of certain EU-level regulations to allow the sale of insect products for human food and for animal feed in Finland. Before the change, all insect products sold for human consumption were banned and there were serious restrictions on insect feed for farmed animals. This change means the end of the years-long waiting period and the Finnish Insect for Food and Feed (IFF) companies have been able to start selling full speed.

The legal environment is one the risks that every company must consider carefully in their business plan regardless the industry they are operating in. In general, a hostile legal environment is seen as a big minus and something that is difficult to change, especially in short term.

No matter how unlikely and how difficult it was considered to be, the Finnish IFF- startups were able to lobby the authorities to change their viewpoint and open the markets. Similar changes are expected all over the Western world, but Finland changed it’s interpretation now sooner than others.

How exactly the Finnish startups spurred the change and how can you do the same in your home country and your industry?

Positive Relationship with Media

The hype around rearing insects for food and feed started around 2011 when FAO started to promote insects as a sustainable choice over conventional animal protein sources. The media attention reached Finland as well and since has been featured multiple times on all major media platforms. Finnish start-ups started to emerge some years after 2011 and since they have featured the articles and news regularly as well.

The IFF- industry is quite unique in many ways and this is one of the major reasons why media has covered so much of it nationally, but all the startups have been not only accepting invites for public speaking and giving interviews, but also reaching out for reporters. What has been great to notice on many occasions I have been asked to cover for other players in the industry to cover for them for e.g public speaking if there has been a double booking. This tells of shared understanding that raising public’s understanding and awareness is very important, even if the publicity points goes to the neighbor company.  For emerging industries many times the competition is not the companies doing similar things than you, but the companies you coming to steal the market from. This essential idea is widely spread in the small Finnish industry and now we all share the fruits of co-operation.

Make Regulators Work for You

Some years ago I had a discussion with Entocube, one of the Finnish startups. I criticized their approach to bring to market end-user products, even though their main business the insect farming technology had at that point many open questions. Now looking back Entocube’s vision to raise awareness about their company and industry by their clever “kitchen decoration products” (insect food was banned) was very unselfish and brave, but also the right thing to do. By pushing the limits of the regulating bodies and sparking even more discussion with their products in media gave the initiative for Evira to start looking seriously on their approach to the topic.

sirkkapurkki

Above is a picture of the “Cricket Jar”- kitchen decoration jar. Not for consumption! A great way to raise awareness and push the limits. This product forced the regulatory body to react. 

We did not have common plan or organization

What was not done is equally important with what was done. Finnish companies have not formed a registered association, but what we have shared so far is a common goal and modern perception of markets. Also, it is worth noticing that there are no Finnish members in the global association of IFF-companies IPIFF.

To me, this tells that organic communication from different entities was at least in this case the key to build up political pressure that leads to this change. Could it be that when the communication is natural and organic instead of designed and always politically correct it is something that interest media and the big audience more?

Three learning points

Every country is their own case, but I see that there are three points to learn from this case.

  • Raise public’s awareness. This is the first step for people to start accepting the idea of something new and to introduce more wide pressure for the public sector to start thinking of the current policies.
  • Force the regulating bodies to react. Especially in a field that was never been though of carefully by the lawmakers by pushing the boundaries, you force them to draw the lines for the first time. What is most important here is that the decisions must be justified. If there is clear lack of regulation, the wheels will start to move within the public sector.
  • Co-operation of the industry. It is essential that the companies operating in the field do not fall into the trap of thinking that they are each other’s enemies. Even though they are working in the same field, the growth in nascent markets is gained from the growing market, not by winning market share from the competition. When the common goals are understood by the industry players they can work together and achieve bigger targets that they could ever be done alone.

Finnish IFF-industry in 2017:

Insect Farming Is Best Suited for the Production of Animal Feed

The companies of the growing industry of high-scale insect farming are approaching their businesses from many different angles, but where the use of insects can be justified the best is when the insects are used to create animal based feed for other animals. The “animal based feed” means feed that include proteins and other nutrients that are coming from an animal instead of plants. Certain farmed animals like salmon and pets like some reptiles require animal based feeds for their health and efficient farming.

When evaluating where the insect based products should be used, the animal based feed is the only group of products where the insects stand out in a positive way against the substitute products. Other products that can be made out of insect are human food, chitin and fertilizer. Chitin and fertilizer are side products of the main purpose of the insect farming that is aiming to produce food either for human or animal consumption.

Let’s go through some of the approaches the insect farming industry has made so far, and how they match up with the substitute products.

Human food

When talking about human food, insects are associated to it as a protein source and replacement for other animal products and beans like soy. There is no doubt that insect farming have significant benefits over these two product groups, but when looking at other new protein products, insects are not anymore the number one choice. Single-cell proteins (Algae, fungus and bacteria), cultured meat and bio engineering (e.g plant based products mimicking animal based products) can all offer the same value proposition as insects, but they do not carry similar risk exposure for the producers making them. For this reason the substitute products are more likely to be produced with more efficiency.

The main difference and in the same time the source of higher risks compared to these other modern food sources is that the insects are the only animal based, or putting it more precisely, the only one coming from live animals.  When farming animals in high-scale the pathogens are a risk for the health of the animals themselves. This risk is underlined in the coming years as the pathogens’ are building bit by bit more resistance against antibiotics. Secondly, when dealing with live animals the end products are also exposed to pathogens like salmonella more than plant based products.

The factor that insect industry has over the substitutes is the possibility of nutrient recycling. Nutrient recycling in this case means that nutrients can be saved from bio waste or even manure by feeding them to insects. Using bio waste brings multiple benefits for an insect farm, but it also highlights the risks. When the raw material of the production is bio waste the cost is very low. This lower cost can make up some of costs of higher risks when comparing the substitutes and underline positive environmental impact of the insect farming.

There are a few negative sides of using bio waste. Depending on the source of the waste the quality and quantity of it changes and this makes the forecasting of the production more difficult also in both quality and quantity. Additionally, when the waste is so unstable it bring additional pathogen risks. There are ways to mitigate these issues: If using waste from bio waste created by facilities such as breweries the quality and quantity are consistent, but the price is not as good as the same waste can be used for example in bio gas production. Other way to make the raw material consistent is for example fermentation and mixing of different high standard deviation batches to make them consistent by quality, but these solutions increase the production and inventory carrying costs. Lastly, the issue of regulations might be a problem from companies using bio waste. At the moment it is unknown how for example heavy metals and medication residues build-up in the food chain of insects. This is one of the main reasons why EU has not yet opened the markets for insect based food and feed. It has been speculated that the first steps of the opening of the markets will include only certain insect species fed only with certain feeds, and those fees would not include bio waste.

All these downsides may compromise one of the main arguments of insect farming, the possibility of nutrient recycling. If you are interested to read more about this aspect, see my blog post “Using bio waste as feed” here: https://ilkkataponen.com/2015/08/20/using-bio-waste-as-feed-for-farmed-insects/

Animal feed

When looking at the substitutes in the animal feed sector “insect feed” is competing with wild fish, side streams of traditional farming and plant based proteins like soy. The prices of these products are low and the quantity demand is extremely high. It will be difficult from the insect businesses to answer these numbers especially when the industry is still building up, but insect feed have other significant benefits over the competition.  Both wild fish and insects are part of the natural diet of predatory fishes like salmon, but unlike the wild fish, insects can be produced locally and insect products are a lot more sustainable. Soy is one of the key elements in the modern fish farming even though it is not a part of for example salmon’s diet. This area is not my expertise, but it is my understanding that soy is being used as fish feed only because it is the cheapest possible protein source, and if the price of an animal based protein source would be close soy, soy would be ditched right away. Additionally, the rise of the wild fish based fish feed prices is expected to continue. This will be closing the price cap year after year in benefit of the insect feed.

Conclusion

Keeping in mind the explained issues and when thinking about the industrial scale food production it can be concluded that insect are most suitable for animal feed for situations when the animal based nutrients are a must. When thinking of human food the new and modern substitute products offer more efficient and, depending on the type of the feed used for insects, more environmentally friendly solutions. When looking at the topic from non-industrial point of view insects are a great solution for human food. For developing countries and areas where arable land is scarce insects can offer great benefits over mammal farming that need huge areas of land and water. Topic that was not discussed in the blog was taste; will it work in benefit of insect or other protein sources? This question I leave for other bloggers and experts.