Why the use of insects to feed other animals should be stopped: Animal Ethics feedback to the European Union

23 Apr 2021

The 20th century saw the rise of new forms of raising and killing massive numbers of vertebrates with the development of factory farms (first, for land animals such as birds and mammals — hens and chickens, pigs and cows –– and later for aquatic animals like many species of fishes). This century is now seeing the rise of new forms of  raising and killing enormous numbers of invertebrates. This is happening through the expansion of factory farming to produce insects for food products.

Many of these insects are used to produce food for humans, often disguised through their use in insect “flours” or burgers. They are also being used in an alarmingly increasing number to produce food for other animals. Because of this, and due to the small size of these animals, insect farming has a terrible potential to multiply the number of exploited animals to levels never seen before.

Because it is happening elsewhere, the European Union is currently deciding whether to authorize the use of insects to feed other animals in factory farms. If this measure is approved, it will greatly increase the number of pigs, chickens, and insects raised in factory farms. This will especially increase the number of insects used to feed other animals.

Along with other animal organizations, scholars, and people concerned with this issue, Animal Ethics provided feedback to the European Union explaining the reasons why insect farming should be stopped, not encouraged. We sent the European Commission the statement below.


Feedback for the European Commission

The use of animals to feed other animals greatly increases animal suffering. It increases it not just in absolute terms, but also in relation to the final weight of animal products obtained.

Due to this, this measure is one of the worst possible decisions that can be made from the point of view of the protection of animals. Article 13 of the Lisbon Treaty explicitly states that “the Union and the Member States shall, since animals are sentient beings, pay full regard to the welfare requirements of animals”. Accordingly, approving this measure would not honor this commitment.

The use of animals to feed other animals is harmful when those used for such purposes are vertebrates such as mammals and birds. But it is also harmful when invertebrates such as insects are used in this way. It is particularly problematic since, because of their very small size, the use of insects as food greatly increases the total number of animals that are harmed.

Despite there being a tradition of disregard for invertebrates in general, and for insects specifically, there is a growing amount of evidence indicating that they might be sentient, and thus have the capacity to suffer (Carere & Mather 2019). Due to this, considerations in their case should be similar to those for other animals when it comes to designing legislation and implementing policies protecting animals from different forms of harm.

Insects display behavioral flexibility, which has been shown to include not just decision making in contexts of changing circumstances and adaptive behavior, but also cognitive generalization and learning by integrating different types of information (EFSA 2005; Mendl et al. 2011; Adamo 2016).

Physiological evidence provides further support for this conclusion. Insects possess centralized nervous systems including distinct brains (Kaas 2016). We do not yet know exactly what complexity those structures need to have, but we do know that centralized nervous systems can process information in ways that may well give rise to consciousness. Due to this, it is highly plausible that they are sentient.

Insect brains are segmented into different regions, one of which is the protocerebrum, which includes the mushroom bodies which contain many neurons. Typically, there can be between 10^5 and 10^6 neurons, which is a remarkable figure. Local field potentials have been recorded in insects’ brains, with a 20-30 Hz response (Polilov 2012). While the insects’ nervous systems and brains are very different to those of mammals both in architecture and size, they have some elements of structure in common. The connectome of some insects is comparable to fiber tract networks among macaques. They also show what is known as a small-world organization, that is, a combination of high connectivity between neighboring regions together with “short-cut” connections to distant regions (Kaiser 2015). Insects’ mushroom bodies are higher brain centers that receive and integrate distinct multisensory information in many segregated input layers. They appear to allow insects to learn from previous experiences, to remember them and to integrate information. In this way they play a key role in the control of insects’ complex behavior (Gronenberg & López-Riquelme, 2004; Collett & Collett 2018). It has been argued the insect brain accordingly possesses a specialized center for processing spatial information as well as organizing movement (Barron & Klein 2016).

Insects’ possession of phenomenal consciousness means that they are capable of suffering, and thus can be harmed by being raised in huge numbers in contemporary insect farming (Tye 2016; Ginsburg & Jablonka 2019; Birch 2020).

We urge the European Commission to consider all this to inform decisions about measures potentially affecting nonhuman animals in very negative ways. There are strong reasons not to authorize the use of insects as food for other animals like pigs and chickens.

Even those who are not fully convinced by these arguments may accept that a precautionary approach would recommend at least studying the issue in more detail (Birch 2017). Those unconvinced may wait until more conclusive evidence on the topic is gathered to approve this measure. In the meantime, this major increase of the use of animals should be halted.

Honoring the Lisbon Treaty implies that the prevention of animal suffering is a fundamental value to protect. In addition to our general recommendation that spreading the use of animals is at odds with this treaty and should not be approved, we make the following specific suggestions:

· Concerning the Draft Regulation’s Recitals: deleting entirely Recital 16.

· Concerning the Annex to the Draft Regulation: striking all references to feeding insects to poultry and porcine animals on pages 3, 5, 6, and 20. Striking the newly added section 2 on page 1.



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Barron, A. B. & Klein, C. (2016) “What insects can tell us about the origins of consciousness”, Proceedings of the National Academy of Sciences, 113, pp. 4900-4908.

Birch, J. (2017) “Animal sentience and the precautionary principle”, Animal Sentience, 2/16, a. 017.

Birch, J. (2020) “The search for invertebrate consciousness”, Noûs, doi.org/10.1111/nous.12351.

Carere, C. & Mather, J. (eds.) (2019) The welfare of invertebrate animals, Dordrecht: Springer.

Collett, M., & Collett, T. S. (2018) “How does the insect central complex use mushroom body output for steering?”, Current Biology, 28, pp. R733-R734.

EFSA – European Food Safety Authority­ (2005) “Opinion of the Scientific Panel on Animal Health and Welfare (AHAW) on a request from the Commission related to the aspects of the biology and welfare of animals used for experimental and other scientific purposes”, EFSA Journal, 3, 292, pp-1-46.

Ginsburg, S., & Jablonka, E. (2019). The Evolution of the Sensitive Soul: Learning and the Origins of Consciousness. Cambridge, MA: MIT Press.

Gronenberg, W. & López-Riquelme, G. O. (2004) “Multisensory convergence in the mushroom bodies of ants and bees”, Acta Biologica Hungarica, 55, pp. 31-37.

Kaas, J. H. (ed.) (2016). Evolution of nervous systems, Amsterdam: Elsevier.

Kaiser, M. (2015) “Neuroanatomy: Connectome connects fly and mammalian brain networks”, Current Biology, 25, pp. R416-R418.

Klein, C. & Barron, A. B. (2016) “Insect consciousness: Commitments, conflicts and consequences”, Animal Sentience, 9/21, a. 153.

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Mendl, M.; Paul, E. S. & Chittka, L. (2011) “Animal behaviour: emotion in invertebrates?”, Current Biology, 21, pp. R463-R465.

Polilov, A. A. (2012) “The smallest insects evolve anucleate neurons”, Arthropod Structure & Development, 41, pp. 29-34.

Tye, M. (2016) Tense Bees and Shell‐Shocked Crabs: Are Animals Conscious?, New York: Oxford University Press.