Under European law, animal by-products (ABPs) are materials derived from animals that are not intended for human consumption and are regulated under Regulation (EC) No 1069/2009 (the Animal By-Products Regulation—ABPR). By-products such as hydrolysed proteins, chitosan (from crustacean shells), and insect frass are often used in plant biostimulants.
ABPs are integrated into biostimulants for their ability to enhance plant growth, nutrient use efficiency, and resistance to abiotic stress. These biobased substances have naturally variable content, which influences the exact effects of a specific containing any of them. Hydrolysed proteins are obtained by breaking source proteins into their component amino acids and peptides, and each manufacturer has a unique combination of raw materials and treatment process that will deliver a specific mix of peptides, polypeptides, and amino acids, and thus a specific functional profile. Chitosan, which is usually derived from crustacean shells, can also provide biostimulant functions, depending on its characterisation (degree of polymerisation (DP), fraction (or degree) of acetylation (FA/DA), and pattern of acetylation (PA)). Insect frass also contains substances, including enzymes, amino acids, and possibly some chitosan from the insect carapaces, with documented biostimulant properties.
One of the main challenges for using ABPs in biostimulants is the lack of clearly defined “end-point” status under the Animal By-Products Regulation for most of these substances to be component materials of EU Fertilising Products even though six years have passed since the Fertilising Products Regulation (FPR) was adopted. The lack of such endpoints, makes it impossible to scale up the valorisation of ABPs under the FPR, restricting farmers’ access to these valuable tools and undermining the FPR’s contribution to the Circular Economy.
EBIC believes that hydrolysed proteins and frass should be granted end-point status based on the risk-profile of substances obtained through the processes specified in the ABPR. End-point status means that these materials, once processed, would be considered safe and no longer subject to the stricter requirements governing raw animal by-products. This is crucial for ensuring the use of these key materials in biostimulant products that can circulate on the Single Market.
Chitosan is a different case because shellfish shells are outside the scope of the ABPR, and the deacetylation process transforms it into a chemical. Because the substance is no longer recognisable as animal-derived, chitosan can therefore be classified under the FPR as a REACH-compliant, chemically defined, naturally occurring polymer (under Component Material Category 1 of the FPR), with safety being assured by the applicable REACH requirements.
EBIC emphasises that the ABPs used in biostimulants have a proven safety record and contribute directly to the functional performance of biostimulants, particularly in enhancing nutrient use efficiency and supporting plant resilience in the face of abiotic stress.
Learn more about animal by-products in plant biostimulants