1. Purpose
This policy sets out Murzo Group’s approach to the selection, sourcing, handling, and control of substrates and feedstock used in insect-related activities.
The objectives of this policy are to:
- Reduce biological, chemical, and regulatory risk associated with insect feed inputs
- Support compliance with applicable UK and EU food, feed, and animal by-product frameworks
- Promote responsible sourcing and traceability of substrates
- Provide a defensible governance framework for inspection, audit, and design purposes
This policy forms part of Murzo Group’s wider insect operations, biosecurity, and food safety governance framework.
2. Scope
This policy applies to:
- Insect farming and rearing systems
- Facilities designed, operated, or advised on by Murzo Group
- Substrates, feedstocks, and growth media used for insects
- Procurement, storage, and handling of feed inputs
- Employees, contractors, suppliers, and authorised third parties
It applies globally, irrespective of jurisdiction.
3. Regulatory Context & Position
Murzo Group recognises that insects intended for food or feed are subject to regulatory controls, substrate legality varies by jurisdiction and intended end-use, and insects are treated as farmed animals for feed safety purposes in UK and EU contexts.
Murzo Group’s approach is to align with applicable regulatory principles without asserting certification or authorisation status unless expressly confirmed.
4. Core Compliance Principles
Murzo Group’s substrate governance is guided by the following principles:
- Legality: Substrates must be lawful for the intended insect species and end-use
- Suitability: Substrates must be appropriate to insect health and safety
- Traceability: Origin and composition should be identifiable
- Risk Minimisation: High-risk materials are excluded
- Segregation: Substrate streams should be separated where required
Murzo Group does not guarantee regulatory acceptance of any specific substrate.
5. Prohibited Substrates
Unless explicitly authorised by applicable law and competent authority guidance, the following are not permitted for insects intended for food or feed:
- Catering waste or kitchen waste
- Manure or slurry
- Mixed municipal waste
- Materials containing animal by-products not authorised for insect feed
- Contaminated, spoiled, or unknown-origin materials
Use of prohibited substrates may expose operators to regulatory enforcement.
6. Permitted & Lower-Risk Substrate Categories
Subject to jurisdiction and end-use, lower-risk substrates may include:
- Plant-based by-products from food or agricultural processing
- Cereal-based materials
- Fruit or vegetable processing residues
- Approved feed-grade materials
Final responsibility for confirming legality rests with the operator placing insects or derived products on the market.
7. Supplier Due Diligence
Where Murzo Group sources or recommends substrates, reasonable steps may include:
- Supplier identity verification
- Documentation of origin and composition
- Assessment of contamination risk
- Review of transport and storage practices
Murzo Group does not assume responsibility for upstream supplier compliance beyond contractual scope.
8. Receiving, Storage & Handling
Substrates should be inspected upon receipt where practicable, stored in clean, secure, and segregated conditions, protected from contamination, moisture, and pests, and labelled or identifiable by batch or source.
Poor handling increases biosecurity and regulatory risk.
9. Traceability & Record-Keeping
Where appropriate, records may include:
- Supplier details
- Delivery dates
- Batch identifiers
- Intended use and insect species
Murzo Group does not mandate record formats unless contractually required.
10. Segregation & Cross-Contamination Prevention
Facilities should prevent cross-contamination between substrate types, separate food-grade and non-food-grade materials, and maintain clear physical or procedural separation.
Segregation supports both biosecurity and regulatory compliance.
11. Waste & Rejected Substrates
Rejected or expired substrates should be clearly identified, isolated from usable materials, and disposed of through authorised routes.
Improper disposal may create biosecurity and compliance risks.
12. Third-Party & Client Responsibilities
Clients, partners, and operators remain responsible for confirming regulatory compliance of substrates, ensuring legality of feed inputs for their specific jurisdiction, and meeting inspection and approval requirements.
Murzo Group does not act as a regulatory authority or compliance certifier.
13. Monitoring & Review
Substrate controls may be reviewed following regulatory changes, after incidents or non-conformities, and when insect species or end-use changes.
Murzo Group retains discretion over review frequency.
14. Legal Position & Limitations
This policy does not guarantee regulatory approval or market acceptance, does not replace statutory obligations of operators, does not constitute legal or regulatory advice, and does not create contractual obligations unless expressly incorporated.
Nothing in this policy excludes liability that cannot be lawfully excluded.
15. Review & Updates
This policy is reviewed periodically and may be updated to reflect regulatory developments, industry guidance, and operational experience.
