Summary of responses and government response
Updated 14 January 2026
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Foreword
Between 4 February and 1 April 2025, Defra and the Welsh government conducted a joint public consultation on whether England and Wales should change their livestock feed controls to allow certain processed animal proteins in feed. These proposals aim to update livestock feed controls to:
- reflect current scientific knowledge of transmissible spongiform encephalopathies (TSEs)
- open new markets for industry
- level the playing field with the EU
The proposals, if introduced, would maintain the UK’s high level of biosecurity, animal and public health protection.
This publication provides a summary of responses and sets out the government response. The analysis is based on responses provided online via Citizen Space, by email and in views expressed in meetings with stakeholders during the consultation period. A total of 736 responses to the consultation were received (732 responses through the online Citizen Space platform, and 4 email responses).
When considering this summary analysis of responses, it is important to keep in mind that public consultations are not necessarily representative of the wider population. This is because anyone can submit their views - individuals, organisations and businesses. Therefore, the approach of this analysis has not only been to count how many respondents held a certain view but also to include qualitative analysis of the additional comments provided to consider the range of issues raised by respondents.
Overview
TSEs are a group of fatal neurological diseases. TSEs notably include scrapie in sheep and goats, bovine spongiform encephalopathy (BSE) – also known as ‘Mad Cow disease’ – in cattle, chronic wasting disease (CWD) in deer, and variant Creutzfeldt-Jakob disease (vCJD) in humans.
The first case of BSE in the United Kingdom (UK) occurred in 1986 and since then there have been over 180,000 confirmed cases of BSE in cattle in the UK. At the height of the epidemic in 1992, 37,056 cases were confirmed. Classical BSE occurs through the consumption of feed contaminated with the BSE agent and is considered zoonotic (transmissible to humans) due to its assumed link with vCJD through the consumption of contaminated meat.
The strict BSE control measures introduced in the UK in 1988 (The Feeding Stuffs Regulations 1988), 1996 (The Bovine Spongiform Encephalopathy (Amendment) Order 1996, and in 2001 (Regulation (EC) No 999/2001) prohibit animal protein from being fed to farmed animals, with very limited exceptions. This prevents BSE agents being recycled back into the ruminant (including cattle, sheep, goats and deer) population. Compliance with these feed controls is also monitored by the Animal and Plant Health Agency (APHA) through the National Feed Audit (NFA). These livestock feed controls, amongst other BSE control measures, have greatly reduced the incidence of BSE in the UK. The UK has had just 5 cases of classical BSE since 2014.
Our understanding of BSE and how it is transmitted has also increased greatly in this time, and the livestock feed regulations no longer reflect current scientific knowledge or the level of BSE risk.
Although these controls are effective, they were made in a precautionary manner, when knowledge of BSE was limited. Since then, research has demonstrated that pigs and poultry are not naturally susceptible to TSEs and improvements in feed testing methods allow the differentiation between ruminant and non-ruminant proteins and are able to detect the presence of porcine or poultry protein.
In 2021 the European Union (EU) amended its TSE legislation to allow the use of a wider range of animal proteins in non-ruminant animal feed. The EU has allowed:
- poultry processed animal protein (PAP) in porcine feed
- porcine PAP in poultry feed
- insect PAP in porcine and poultry feed
- ruminant collagen and gelatine in non-ruminant feed
These amendments are part of the EU TSE roadmap to review BSE controls, in the light of the reduced incidence of BSE and increased knowledge of the disease. The UK supported the roadmap when it was an EU member.
A risk assessment of the proposed changes concluded that these maintain the same level of protection of human and animal health as afforded by current controls. The consultation sought views on amending domestic legislation to implement the proposed changes.
If introduced, key protections would remain in place, including the banning of PAP of ruminant origin being fed to ruminants, a requirement by the World Organisation for Animal Health (WOAH). Animal by-product (ABP) regulations would still prohibit intra-species recycling.
Summary of respondents
A total of 736 responses to the consultation were received (732 responses on the online Citizen Space platform, and 4 email responses). Any email responses which directly responded to individual questions were entered into Citizen Space manually and treated in the same way as other responses on that platform. The 4 email responses which did not directly respond to individual questions are not included in the analytical data but taken into account in the government response.
All respondents were asked which option best describes them or their organisation. 84 percent of responses received (616) were from members of the public. We also received responses from:
- insect protein producers
- compound feed mills
- feed ingredient manufacturers
- farmers
- trade associations
- abattoirs
- rendering plants
- retailers
- enforcement officers
Respondents who selected the ‘other’ category included animal welfare organisations, charities, and a halal certification organisation.
Some responses represented the views of a whole organisation or business, whereas some responses represented the views of individuals in an organisation or business. This has been taken into account in the government response.
A full breakdown of respondents is in Annex 1 (analytical data).
Consultation response summary by policy proposal
This summary of responses is not an exhaustive list of all ideas provided by respondents but summarises the most common concerns and opinions. Therefore, a range of qualitative terms are used, such as ‘many’, ‘some’, ‘most’ and ‘a few’. Please note, any percentages have been rounded to whole numbers.
Proposal to allow poultry processed animal protein (PAP) in porcine feed
Analysis
In response to the proposal to allow poultry PAP in porcine feed:
- 71 respondents agreed
- 610 respondents disagreed
- 51 respondents didn’t know
Of the respondents who supported the proposal, many noted the scientific evidence behind the safety. Many respondents mentioned the potential environmental benefits of using PAP that is currently exported to reduce the reliance on imported soybean-based feed and to support a circular economy. Following the EU implementing these changes to feed controls in 2021, industry want to level the playing field with the European market.
Currently, pigs imported from the EU can be fed on poultry PAP and imported as product into the UK. A few responses also mentioned the nutritional value of poultry PAP and the economic opportunity. ABP processing plants manufacturing poultry or porcine PAP would be able to sell to a Great Britain (GB) market for use in the production of porcine and poultry feed.
Most respondents who disagreed with the proposal were members of the public. Many raised concerns about potential risk to biosecurity and public health. Many respondents were concerned about TSE risk, and some mentioned the risk from other pathogens. Many respondents opposed the changes due to ethical reasons and concerns that poultry PAP is not part of a pig’s natural diet. Some of these respondents favoured moving towards more plant-based options and reducing reliance on animal products. We also received a number of responses from farmers concerned about consumer perception should this proposal be introduced.
Government view
Regarding the safety of the proposed changes, Defra and the Welsh Government are assured that the changes would maintain the current levels of biosecurity and public health in England and Wales. APHA conducted risk assessments on the potential impact on animal health of adopting these same changes in GB. These risk assessments indicated that the overall risk of an animal in the UK being infected with a TSE due to these legislative relaxations is very low and is not estimated to increase the level of TSE infection and spread.
The Advisory Committee of the Microbiological Safety of Food (ACMSF), a committee of independent experts that provides advice to the government on questions relating to microbiological issues and food, concluded that the risk assessments provide public health assurance for this policy change if other key BSE controls remain in place.
The Food Standards Agency (FSA) is an independent, non-ministerial government department and is the Competent Authority for feed, food safety and hygiene policy in the UK. Based on this advice from ACMSF, the FSA determined that no public health risk assessment is required in relation to adopting these changes. The current controls were made in a precautionary manner, when knowledge of BSE was limited. Since then, research has demonstrated that pigs and poultry are not naturally susceptible to TSEs.
Regarding risk from other pathogens, PAP is derived entirely from category 3 material. Animals that show any signs of disease communicable to humans or animals are excluded from use as a category 3 ABP. Category 3 material must be treated with processing methods listed in ABPs Commission Regulation (EU) No 142/2011. These methods are designed to eradicate virus and bacteria within the product.
Defra and the Welsh Government acknowledge respondents that disagree with this proposal for ethical reasons and concerns that poultry PAP would not form a natural part of a pig’s diet. However, pigs are omnivores and inclusion rates of poultry PAP in feed in the EU are typically in the range of 5 to 10 percent. These changes are an opportunity for industry to utilise category 3 material for PAP – which is currently mainly exported for the pet food market – and sell it to a domestic GB market for livestock feed. This could increase the sustainability of the industry.
Defra and the Welsh Government acknowledge concerns around consumer perceptions of allowing certain PAP to be fed to livestock. We will work with industry to ensure effective communications on the safety of the changes.
Proposal to allow porcine PAP in poultry feed
Analysis
In response to the proposal to allow porcine PAP in poultry feed:
- 72 respondents agreed
- 614 respondents disagreed
- 46 respondents didn’t know
The main reasons respondents supported the proposal were largely the same as those for supporting poultry PAP in porcine feed. Of the respondents who supported the proposal, many noted the scientific evidence behind the safety. Many respondents mentioned the potential environmental benefits of using PAP that is currently exported to reduce the reliance on imported soybean-based feed and to support a circular economy. Following the EU implementing these changes to feed controls in 2021, industry want to level the playing field with the European market.
Currently, poultry imported from the EU can be fed on porcine PAP and imported as product into the UK. A few responses also mentioned the nutritional value of porcine PAP and the economic opportunity. ABP processing plants manufacturing porcine or poultry PAP would be able to sell to a GB market for use in the production of poultry and porcine feed.
Similarly to the last proposal, most respondents who disagreed with the proposals were members of the public. Many raised concerns about potential risk to biosecurity and public health. Many respondents were concerned about TSE risk, and some mentioned the risk from other pathogens. Many respondents opposed the changes due to ethical reasons and concerns that porcine PAP is not part of a chicken’s natural diet. Some of these respondents favoured moving towards more plant-based options and reducing reliance on animal products.
We received a few responses from farmers concerned about consumer perception should this proposal be introduced. We also received a few responses indicating that this proposal would affect religious dietary requirements.
Government view
Defra and the Welsh Government are assured that the changes would maintain the current levels of biosecurity and public health in England and Wales. APHA conducted a risk assessment on the potential impact on animal health of adopting these same changes in GB. This risk assessment indicated that the overall risk of an animal in the UK being infected with a TSE due to these legislative relaxations is very low and is not estimated to increase the level of TSE infection and spread.
PAP is derived entirely from category 3 material, which has been treated in accordance with ABPs Commission Regulation (EU) No 142/2011. These methods are designed to eradicate virus and bacteria within the product. The current controls were made in a precautionary manner, when knowledge of BSE was limited. Since then, research has demonstrated that pigs and poultry are not naturally susceptible to TSEs.
Defra and the Welsh Government acknowledge respondents that disagree with this proposal for ethical reasons and concerns that porcine PAP would not form a natural part of a chicken’s diet. However, chickens are omnivores and inclusion rates of porcine PAP in feed in the EU are typically in the range of 5 to 10 percent.
These changes are an opportunity for industry to utilise category 3 material for PAP – which is currently mainly exported for the pet food market – and sell it to a GB market for livestock feed. This could increase the sustainability of the industry.
Defra and the Welsh Government acknowledge concerns around consumer perceptions of allowing porcine PAP in poultry feed and will work with industry to ensure effective communications on the safety of the proposals.
Regarding religious dietary requirements, animals reared on a partially carnivorous diet may not be considered halal or kosher. Defra has considered how religious dietary requirements may be affected by these proposals and has reached out to halal and kosher certification authorities, who are experts in Sharia and Kashrut law.
Defra met with one of the main halal certification schemes in the UK during the consultation period. They assured us that they are able to trace products back to the feed mill to assure consumers that animal feed complies with Sharia law. We also reached out to kosher certification authorities, but we did not receive a response to the consultation. Current legislation allows porcine, poultry, and insect PAP to be used in aquaculture feed and animals reared on these diets in the EU can already be imported into the UK.
Proposal to allow insect PAP in porcine and poultry feed
Analysis
In response to the proposal to allow insect PAP in porcine and poultry feed:
- 119 respondents agreed
- 599 respondents disagreed
- 14 respondents didn’t know
Of the respondents who supported the proposal, many noted the scientific evidence behind the safety and the fact that insects form a natural part of the diets of pigs and poultry. Most of these respondents highlighted insect PAP as a potential solution to reducing reliance on imports of soybean-based protein, which has a negative environmental impact, and a move to a more circular economy.
Some respondents mentioned the opportunities for growth and innovation in the insect protein industry. Many respondents also favoured levelling the playing field with the EU market. Currently, EU pigs and poultry can be fed on insect PAP and imported as product into the UK.
Most respondents who disagreed with the proposals were members of the public. Some were concerned about potential disease and pathogen transmission risks. Some disagreed for ethical reasons.
Some respondents raised concerns over the environmental impact of feeding insect PAP to pigs and poultry, particularly the amount of electricity required to farm insects. Some respondents highlighted the limitations to the sustainability of insect farming due to current ABP regulations which restrict the feeding of certain substrates to insects.
191 respondents who disagreed with the proposal raised concerns about insect welfare. Of these, 71 also disagreed with the other proposals in this consultation, but only raised insect welfare as a concern. They raised the possibility of insect sentience and the lack of welfare standards for farmed insects.
Government response
Regarding the potential for disease and pathogen transmission, the APHA risk assessment concluded that this proposal would not increase TSE risk. Insects are not considered to be susceptible to TSE infection. Again, PAP must be derived entirely from category 3 material which has been treated in accordance with ABPs Commission Regulation (EU) No 142/2011. These methods are designed to eradicate virus and bacteria within the product.
In terms of the environmental impact of allowing insect PAP in pig and poultry feed, Defra has conducted a Life Cycle Assessment on UK Insect Protein Production Processes for Pig and Poultry Feed which was published in April 2025.
The results suggest that ‘insect protein may not currently be the solution to decarbonising the animal feed industry. However, under the right production conditions and with an increased demand for the co-products of the insect meal system, it may have a place in the decarbonisation of animal feed, particularly when considered alongside other factors beyond the LCA such as overfishing or deforestation and indirect land use change for soybeans.’
We are aware of innovation in the insect protein sector identifying novel insect substrates. According to ABP regulations, as farmed animals, insects are prohibited from being fed manure, catering waste, and feed material containing or derived from catering waste.
Regarding insect welfare, insects are not in scope of the Animal Welfare Act 2006 and are not legally recognised as sentient under the Animal Welfare (Sentience) Act 2022. We are aware of academic and wider interest in these aspects of insect protein production. However, this consultation focused on the TSE risk relating to feeding proteins to animals.
Proposal to allow ruminant collagen and gelatine in non-ruminant feed
Analysis
In response to the proposal to allow ruminant collagen and gelatine in non-ruminant feed:
- 57 respondents agreed
- 579 respondents disagreed
- 96 respondents didn’t know
Of those who agreed with the proposal, many noted the scientific evidence behind the safety of the proposals. Industry favoured levelling the playing field with the EU. Some mentioned that ruminant collagen and gelatine are already used in food consumed by humans and in pharmaceuticals.
Most respondents who disagreed with the proposals were members of the public. The main concerns raised were TSE risk and ethical concerns. Some respondents raised concerns about consumer perceptions of this proposal.
Government response
Defra and the Welsh Government are assured that the changes would maintain the current levels of biosecurity and public health in England and Wales. APHA risks assessments concluded that the TSE risk should these proposals be introduced would not increase. Defra and the Welsh government will work with industry to communicate the safety of these proposals to consumers.
Proposed measures to prevent cross contamination in the feed chain
Analysis
In response to the proposed measures to prevent cross contamination in the feed chain:
- 151 respondents agreed
- 343 respondents disagreed
- 238 respondents didn’t know
Some respondents felt that the proposed measures were not robust enough, noting the complexities of the feed chain. Some were concerned about non-compliance and the potential economic and reputational impacts of this on industry.
Some trade associations explained that the measures may be difficult and costly to implement, noting that ‘most monogastric mills produce a range of feeds for different species along the same production lines with shared storage and delivery vehicles, making complete physical separation costly and impractical’. They also highlighted the need for clear guidance on the measures.
Some respondents, mostly insect protein producers, highlighted that insects are not naturally susceptible to TSEs and ‘unlike mammalian and avian proteins, insects are natural decomposers, possessing inherent antimicrobial properties that mitigate pathogen risks.’ They questioned the necessity of complete separation which may slow down industry adoption.
Government response
Defra has worked with industry, the Welsh and Scottish Governments, the FSA, Food Standards Scotland (FSS), and APHA to develop proposed cross contamination requirements that will monitor and prevent cross contamination across the feed chain. If the changes are implemented, APHA would issue updated guidance on the changes, explaining the legislative requirements to prevent cross contamination in the feed and food chain.
This would build upon the current guidance note on feed controls in the TSEs Regulations published in 2018. Existing enforcement routes would apply to the new controls.
In GB, compliance with the feed controls is monitored through the NFA, a compliance monitoring programme conducted by APHA, an executive agency of Defra that is responsible for TSE surveillance in GB. This inspection and sampling programme, carried out at various stages of the animal feed chain, monitors for the presence of prohibited ingredients of animal origin in feed. Before implementing any proposed changes, APHA would review the NFA to ensure that testing reflects the changes.
Defra and the Welsh Government recognise that the cross-contamination requirements may be costly and difficult to implement however, these are designed not to be detrimental to current practices. These proposals are deregulatory, and it would be a commercial decision for individual business whether to implement the changes. Complete separation is necessary to ensure no cross contamination which could lead to intra-species recycling. This is prohibited in ABP regulations.
Next steps
Having considered all consultation responses, Defra and the Welsh Government intended to proceed with all the proposals. However, the government recently announced its intention to reset the UK’s relationship with the EU and pursue an SPS agreement to dynamically align with EU rules.
Therefore, we will now not be making these changes independently and will do so instead in a future process where the UK implements an SPS agreement with the EU.
Ahead of implementing the changes, APHA will conduct a review of the NFA to ensure the compliance monitoring programme reflects the changes. This will include an updated guidance note on feed controls for industry explaining the legislative requirements to prevent cross contamination in the feed chain.
Defra and the Welsh Government will continue to work with industry to ensure effective communications to the public and across the feed chain when the changes are implemented.
Annex 1: analytical data
Question 1: Which of the following best describes you, your holding, or organisation?
| Response | Number of respondents |
|---|---|
| Member of the public | 616 |
| Other | 30 |
| Insect protein producer | 20 |
| Poultry farmer | 14 |
| Trade association | 12 |
| Bovine farmer | 9 |
| Other farmer | 9 |
| Compound feed mill | 5 |
| Feed ingredient manufacturer | 4 |
| Retailer | 4 |
| Ovine farmer | 3 |
| Abattoir | 2 |
| Pig farmer | 2 |
| Enforcement officer | 1 |
| Rendering plant | 1 |
| Cutting plants | 0 |
| Haulier | 0 |
| Total | 732 |
Question 2: Do you agree with allowing poultry processed animal protein in porcine feed?
| Response | Number of respondents |
|---|---|
| Yes | 71 |
| No | 610 |
| Don’t know | 51 |
Question 3: Do you agree with allowing porcine processed animal protein in poultry feed?
| Response | Number of respondents |
|---|---|
| Yes | 72 |
| No | 614 |
| Don’t know | 46 |
Question 4: Do you agree with allowing insect processed animal protein in porcine and poultry feed?
| Response | Number of respondents |
|---|---|
| Yes | 119 |
| No | 599 |
| Don’t know | 14 |
Question 5: Do you agree with allowing ruminant collagen and gelatine in non-ruminant feed?
| Response | Number of respondents |
|---|---|
| Yes | 57 |
| No | 579 |
| Don’t know | 96 |
Question 6: Do you agree with the proposed measures to prevent cross contamination in the feed chain?
| Response | Number of respondents |
|---|---|
| Yes | 151 |
| No | 343 |
| Don’t know | 238 |