*3.1. Food Law*

As in other regions of the world, the food law of a given African country is determined by both international and national regulations. From the international point of view, Codex Alimentarius, AU and the different African trade blocks are the most important ones. As the Codex is well-known, it will be omitted here.


the priority areas of this action plan. This would, in fact, include insects, regardless of whether they are caught from the wild or farmed.


animal health, do not respond to the consumer information requirements, do not fulfill the ethics of the international food trade as established by the Codex Alimentarius, or do not cope with the requirements for novel foodstuffs. The latter refers to foodstuffs unknown to the member states' population and consumed marginally and also includes GMOs. Furthermore, the regulation refers to the so-called Secrétariat Régional de la Normalisation, de la Certification et de la Promotion de la Qualité (NORMCERQ) that is in charge of harmonizing the corresponding regulations, but no hint of this activity regarding food could be encountered.

• UMA. The Arab Maghreb Union has a commission for food safety, which, according to its website, met 2007 in Nouakchott, Mauretania. It has ratified several conventions regarding the exchange and quarantine of agricultural products among member countries. However, these documents are not online.

As can be seen, most of these international organizations do not set a concise legal framework for the member states. This is a difference to other trade blocks, e.g., the EU. Instead, policies are proposed. Policy documents are typically placed on consulted ministries' homepages, dealing with ways to increase food security, food safety, intermember states exchange, and food and production-related research. In some cases, policy statements are presented rather than concrete legal frameworks.

Policies seldom address edible insects directly. Some exceptions will be presented on a national level.

On a this level, no data on the food law in Chad and Lesotho could be encountered. Technical and safety reasons made it impossible to access the corresponding web presences in Botswana, Cameroon, Sierra Leone, Sudan, Tanzania, and Togo. FAOLEX was used whenever possible.

No country has explicitly included edible insects in their current food legislation so far. However, direct contact to authorities and consulting the internet provided the following results:


edible insects, but they are accepted, and the Codex Alimentarius is used when determining the hygiene and edibility of insects. However, Codex specifications apply to foodstuffs in general or to specific, non-insect foodstuffs.


These results show that edible insects are tolerated in many countries, and although there is no regulation for them at the moment, some governments are interested in developing them.

When working with legal texts, it is important to check the definitions provided there. In the case of the definitions for 'foodstuff', all countries would permit considering insects as such (Table 4), at least in the case of the countries for which such a definition could be encountered. In most cases in which countries apparently lack a foodstuff definition, however, they do have food legislation, but either they work without the preliminary definition or address specific foodstuffs, e.g., meat, fishery products, or eggs. For UEMOA member states, the food definition provided there would have an official character, even in the countries apparently without their own definition, i.e., Burkina Faso and Senegal. Another probable reason for information gaps may the fact that some regulations have simply not been published on the internet. To give an example, a central regulation for food in Togo is the *Arrêté interministériel n<sup>o</sup> 06*/*08*/*MAEP*/*MEF*. It is mentioned in secondary literature (e.g., [15]) but could not be traced back in the net.

**Table 4.** Definitions of "foodstuff" in African food regulation frameworks; for Botswana, Burundi, Cameroon, Chad, Comoros, Congo-Brazzaville, Congo-Kinshasa, Djibouti, Equatorial Guinea, Eritrea, Gabon, Gambia, Guinea, Lesotho, Malawi, Mauritania, Libya, São Tomé and Príncipe, South Sudan, and Togo, no definitions could be encountered.


**Table 4.** *Cont.*





**Table 4.** *Cont.*

\* This part must have been amended since it is no longer part of this Act, \*\* definition of 'animal product'.

Although these definitions basically include edible insects, a further insertion into food law is not possible. This is due to the fact that food inspection framework usually includes a definition of the food category, e.g., 'meat', 'fishery product', etc. With insects being foodstuffs of animal origin, the term 'animal' is defined, if at all, in terms of livestock and species obtained via fishing, sometimes including game species. Interestingly, some regulations seem to make a difference between "animal", "bird", and "fish", suggesting that "animal" as a food provider is perceived as a mammal. In fact, *The Food and Drug Act* (Art. 1) from Uganda excludes birds and fish from its 'animal' definition. In any case, these definitions usually exclude invertebrates. Some, however, mention honeybees, e.g., *Lei no 30*/*VIII*/*2013* of Cape Verde. One of the relatively few countries that actually mentions insects in the animal definition is the *Food Act, 2014*, of the Seychelles (Art. 2). The *Veterinary Law Code* of Somalia (Section 1) does not contain an overall definition of foodstuff, but for 'animal product', an 'animal' being "any vertebrate or invertebrate animal other than the human being".

Some nations also have addressed the idea of novel foodstuffs. To provide an example, Niger's *Décret no 2011-616*/*PRN*/*MEL* defines them as "products or foodstuffs for which human consumption in Niger has so far been unknown or marginal, as well as foods and ingredients made from genetically modified organisms" (Art. 7/2). A definition for novel foodstuffs is also provided by *007*/*2007*/*CM*/*UEMOA*. It may be debated, however, if edible insects actually are a novel food in African countries, particularly if marginal consumption is used as a criterion. However, as can be seen in Table 3, the amount of edible insect species varies from country to country, as will the extent of traditional entomophagy. In this way, the issue of insects as novel food will have to be answered on the nation level, also for those cases in which edible insects are traded from one country to another.

#### *3.2. Wildlife Resources Management*

Africa is known worldwide for its spectacular wildlife, which has been exploited for centuries as game, providing meat and trophies. Fearing the extinction of these valuable resources, most countries have developed a comprehensive regulatory framework to manage these species. Laws pertaining wildlife were issued in order to regulate the usage of the large African animals, particularly mammals, birds, and reptiles such as crocodiles, be it as a trophy obtained via sports hunting, be it as a foodstuff during regular hunting. Hunting legislation basically refers to the species that can be hunted, the methods permitted, and the fee to be paid for the right to hunt under a combination of the aforementioned parameters. Inclusion of arthropods such as insects and arachnids must be seen as incidental and a consequence of the definition for 'animal', particularly if regulations date from the previous century.

Then, and in view of the many other natural resources, it became necessary to regulate the management of, e.g., wood or mineral resources, i.e., activities that compromise the integrity of certain areas. Finally, natural reserves attract tourism, and so, regulation of these also became necessary.

AU has issued the *African convention on the conservation of nature and natural resources*. It addresses the need of balancing environment protection with sustainable use of the natural resources. In Article V, some basic terms are defined, e.g., "natural resource", "species", "specimen" (which refers to any non-human life-form, dead or alive), "product" (any part or derivative of a specimen), and a series of conservation areas types are recognized (defined more precisely in Annex 2). Among others, Article

XIV addresses the sustainable use of these resources and Article XVII the traditional rights of local ethnics to make use of them. In Article VI on land and soil, the term "sustainable farming and forestry practices" is coined and considered a goal to follow. Managing these specimens is the basic objective in terms of species diversity (Article IX), be it inside conservation areas, be it outside of them. In the latter case, harvestable populations are allowed. Among other objectives, the introduction of non-native species is to be controlled strictly, and existing populations should be eradicated, pests controlled, and diseases eliminated. This goes along with the phyto-sanitary convention which basically seeks to minimize the impact of, among others, insect pests by restricting the importation of potential sources. Member states are encouraged to regulate the extraction of specimens, avoiding a series of extraction methods specified in Annex 3. Although it may be expected that this passage refers to vertebrates, some of these banned means are used for regular insect hunting, e.g., artificial light sources, target illumination devices, nets (with exceptions as agreed upon by the Conference of the Parties), and traps. It calls the member states to regulate the domestic trade with, transport of, and possession of specimens (Article XI), to ensure the sustainable management of natural resources within development plans (Article XIV), to respect traditional rights and knowledge (e.g., of farmers; Article XVII), enable research (Article XVIII), and promote capacity building and technology transfer (Articles XIX and XX). Still, this paper did not contain concise regulations, but should be seen as a general framework from which other (inter)national regulations may start from.

Below the AU, one of the larger organizations is the Commision des Forêtes d'Afrique Centrale (COMIFAC), which includes Burundi, Cameroun, Central African Republic, Chad, Congo-Brazzaville, Congo-Kinshasa, Gabon, Equatorial Guinea, Rwanda, and São Tomé and Príncipe. In their constituting treaty, they expressed their commitment to support and develop a sustainable use of the forest resources, creating income from these resources (Article 1).

Of all these bases, edible insects only play a minor role, being one of the many forest products that may, or may be not, harvested. The main focus is clearly the game species, either for sport hunting or for bushmeat. Besides, the permitted use of insects (trophy, foodstuff, feedstuff, medicine, etc.) is frequently not stated. In this way, the first approach of asserting the legal status of insects within this area was to determine if insects actually were (respectively could be) included in the 'animal' definitions these regulations provide (Table 5). In some cases (e.g., Burkina Faso), the regulation did contain a concise definition, suggesting that 'animal' was defined using common sense, i.e., a non-human member of the Animalia kingdom. If this is actually the case, then the *Décret no 96-061*/*PRES*/*PM*/*MEE*/ *MATS*/*MEFP*/*MCIA*/ *MTT* would in fact be applicable to insects as it refers to "animals".

In other cases, regulations exclude insects. To give an example, *Loi no 1*/*17 du Septembre 2011 portant Commerce de Faune et de Flore Sauvages* from Burundi refers, in terms of animals, to a list of mammal, bird, reptile, and plant species.

**Table 5.** Summary of the references towards edible insects within African wildlife management legislation; numbers refer to the specific article of the regulation in question; for Cape Verde, Namibia, Seychelles, Somalia, South Sudan, and Zambia, regulations' definitions were not applicable to insects; no applicable regulations were found for Libya, São Tomé and Príncipe, Senegal, Sudan, and Zimbabwe.


**Table 5.** *Cont.*


**Table 5.** *Cont.*


**Table 5.** *Cont.*


\* s = schedule.

Wildlife can be managed or protected. In most countries, wildlife protection is mainly focused on large animals, typically hunting species. Some nations, however, also include insects. The *Décret no 2004-0065*/*PR*/*MHUEAT* of Djibouti puts all national animal species under protection, i.e., also the insects. In Cape Verde, the *Decreto-Regulamentar N*◦ *7*/*2002* lists several beetle species as protected, i.e., the scarabids *Aphodius* spp., the hydrophilids *Berosus* spp., the buprestid *Chrysobothris dorsata*, the dytiscid *Eretes sticticus*, the cerambycids *Xystrocera* spp., and the tenebrionids *Alphitobius laevigatus, Tenebrio* spp., and *Zophobas* spp., which are all edible. So, local consumers have to take care not to feed on these species.

• Cape Verde. No regulation on wildlife management could be found. However, the *Decreto-Regulamentar no 7*/*2002* classifies the national fauna into several types, with different levels of protection. It contains a large list of beetles, of which according to [11] some are edible, at least at the genus level. Unless bred in captivity, these species may not be extracted from the wild or managed in any commercial way (Article 9). For the commercial use of endemic species, a permit from the

government is mandatory. Introducing exotic species (as farming insects would be) can only be done after authorization from the government (Article 13). As mentioned before, the list also includes the classical tenebrionid genera *Alphitobius*, *Tenebrio*, and *Zophobas*. Although the text refers to *Tenebrio guineensis*, all *Tenebrio* species are considered edible. The mentioned "Zophobas atratus concolor" is basically *Z. atratus*. This one and *Alphitobius laevigatus* are typically used for food. Installing tenebrionid farms on Cape Verde may therefore be a challenge because the introduction of foreign populations, certifying the captivity origin of national populations or catching the initial stock from the wild are all subject to authorization.


Finally, a modern way of handling insects is by farming them. A survey conducted via FAOLEX in search of applicable data did not yield any results.

So, edible insects can be handled in many African countries in a traditional way, but typically after an official permit was provided.

#### *3.3. Edible Insects in Pest Legislation*

Some pest insects are edible, e.g., mealworms or locusts which, when swarming, are responsible not only for marked economic losses but may also trigger famines. Thus, there are other joint ventures in which several African nations cooperate. Two of them are CLCPRO ( j ϲϓϱϭήΤμϟΩήΠϟΔΤϓΎϜϣΔΌϴϫ ΔϴΑήϐϟ ΔϘτϨϤϟ—Commission de Lutte contre le Criquet Pèlerin dans la Région Occidentale, Commission for Fighting the Desert Locust in the Western Region) and CRC (ΩήΠϟ ΔΤϓΎϜϣ ΔΌϴϫ ϰτγϮϟ ΔϘτϨϤϟ ϲϓ ϱϭήΤμϟ, Commission for Controlling the Desert Locust in the Central Region), hosted by FAO. Both commissions are dedicated to preventing damages to crops caused by swarming desert locusts (*Schistocerca gregaria*). The use of this natural resource as foodstuff has not been contemplated so far, mostly out of the sheer size of locust swarms, and so no regulation in this issue has been established.

Besides, most African nations have more or less detailed pest legislation. There is usually one basic regulation that defines pests in a way that insects are included (Table 6) and provide measures on what to do to ensure pest reduction. In addition, many countries have specific acts dealing with plant diseases and pests in which the corresponding insect species are listed (Tables 7–10). To give an example, Morocco issued an interesting regulation for the control for the African palm weevil (*Rhynchophorus ferruguineus*). This regulation makes fighting this weevil obligatory, and a Moroccan governorate was classified as a quarantine zone, forbidding all transport of palms out of this area. Palms affected by the weevil must be destroyed (*Arrêté conjoint du ministre de l'agriculture et de la pêche maritime et du ministre de l'intérieur no 287-09 du 30 janvier 2009 édictant des mesures d'urgence destinées à la lutte contre le Charançon rouge du palmier* (*Rhynchophorus ferrugineus*)). However, for the scope of the present contribution, the fact that these species are not permitted is the decisive information rather than the measures taken to control these pest species. In this way, rearing and placing on the market this particular species would be against the law.


**Table 6.** Pest insect legislation pertaining edible insect species (contained in "all pest insect species"); No data could be obtained for Angola, Djibouti, Equatorial Guinea, Ethiopia, Gabon, Lesotho, Senegal, Sierra Leone, Somalia, South Sudan, Sudan, and Togo.


**Table 6.** *Cont.*

Swarming locusts have been a threat for the agriculture for millennia. Along with the CLCPRO and CRC initiatives, many countries have adopted national regulations. However, only some do actually include concrete measures. In other countries, the fight against locusts is documented legally by the will to build up corresponding organizations and initiatives, i.e., the national anti-locust agency (ANLA) in the Chadian *Loi no 005* /*PR*/*2007*, IFVM in Madagascar (*Décret n<sup>o</sup> 2017-064 du 31 du janvier 2017*), the CNLP in Mali (*Loi no 06-065 du 29 décembre 2006* and subsequent texts), the PLUCP in Niger (*Arrêté no 13*/*MDA*/*DPV*), and the campaigns in Morocco (*Loi n<sup>o</sup> 57-02*) and Tunisia (*Décret n<sup>o</sup> 88-1751*). In those countries, locust may be combatted efficiently, but this is not reflected in the law.


**Table 7.** Pest insect legislation pertaining edible insect species (as presented in [11]): locusts (Orthoptera; all species are Acrididae, except for *Zonocerus variegatus* (Zygomorphidae)).

\* termed "Locusta pardelina" in this act.


**Table 8.** Pest insect legislation pertaining edible insect species (as presented in [11]: butterflies and moths (Lepidoptera).

**Table 9.** Pest insect legislation pertaining edible insect species (as presented in [11]): beetles (Coleoptera); Eswatini also refers to "woodborer beetles", but without any species information, a term that, in fact, can be used to several taxa.



**Table 9.** *Cont.*

While locusts, butterfly caterpillars, and beetle grubs and larvae are relative well-known food insects, some of the species contained in Table 10 are not, particularly the cockroach and fly species. It should be stressed that the species listed are known to be edible, at least in some parts of their ranges, which may not necessarily be Africa. The record of edibility of *Periplaneta americana* comes from Brazil, that of *Anastrepha ludens* from Mexico.

**Table 10.** Pest insect legislation pertaining edible insect species (as presented in [11]): other orders.


As a summary of the previous tables, Table 11 provides an overview of the current legal situation of edible in the different African nations.


**Table 11.** Summary of the legal context of edible insects in Africa.

#### **4. Discussion**

#### *4.1. Data Availability*

One of the main difficulties in carrying out the present survey was data gathering. Getting first-hand information from the corresponding authorities was challenging. However, as the group of authors comprised African and European scientists, the African colleagues had better chances in getting in contact with these authorities. A clear cut was seen between the responses of countries where French and Arabic are spoken (attended by the African colleagues) and those in which English or Portuguese are the official languages (attended by the European colleagues), with the latter responding very late, if at all (despite several attempts made to get an answer), while the African colleagues were able to provide results within two weeks. Differences between the authorities and citizens asking for their advice is a global phenomenon, but also African researchers make special emphasis on the local conditions [17].

Data availability is also an important issue on the internet; some countries did not provide their current legislation on the corresponding government portals. Instead, data had to be traced via other sites, especially FAOLEX. Still, gaps remained, either due to technical or internet safety reasons, or simply because some governments do not put these sources online.

In this context and beyond the current survey, it was noted that most regulatory texts were written either in French, English, or Portuguese, i.e., the administrative languages from colonial times. The only exceptions were the regulations presented (sometimes exclusively) in Arabic of the North African countries, and the full set of regulations from Ethiopia and Rwanda, which were either bilingual (Amharic and English) or even trilingual (Kinyarwanda, English, and French). While this was rather advantageous for the researchers, this may pose a problem for the local African citizens. In Africa, there are more than 2000 languages spoken, and in many countries, the percentage of the population that understands these official languages completely may be relatively low. This, of course, varies strongly among countries, ranging between 35% (Mali) and 88% (Eswatini) in 2018 (http://data.uis.unesco.org/Index.aspx?queryid=166#). So, there is a risk that a certain portion of a country's population may not be able to understand the laws of their own country. However, the situation is changing in some countries. The web presence of the government of South Africa (https://www.gov.za/) has been presenting regulations in several of its eleven official languages, usually English plus another one.

#### *4.2. Edible Insects in African Food Legislations*

With the exception of phane in Botswana, edible insects have not been considered in the African food law, neither on the national nor on international level. This may be surprising in view of the rich entomophagy tradition that exists in Africa. Van Huis [6] stressed the importance of edible insects in the different regions of the continent, which range from using them in those seasons of the year in which other natural foodstuffs are rarer to the simple reason that insects are consumed because of their taste. This is a completely different scenario from, e.g., the EU where insect-consuming tradition is almost inexistent, and insects are treated as truly novel foods that enter the European food market. In this way, the EU novel food regulation opens this market, and future legal acts will incorporate insects into the public health surveillance, adopting as much as possible from existing regulation, but attending, at the same time, the idiosyncrasies of these foodstuffs, e.g., microbiological criteria. This may be flanked by national European guidelines [7]. However, food law in Africa by itself is the key to this finding.

It should be stressed that, on one hand, African food legislations are merely starting to adapt to the current standards experienced in other parts of the world, and that, on the other hand, the progress in that varies markedly among countries. Some laws cited in the present contribution date down to the 1900s and are still in power. Yet, these are exceptions, and many laws date from the 1990s to the 2010s. In some countries, no food law could be encountered, and if available, many laws seem to lack a concrete depth. In some way, many of these texts express expectations about the issues the address, leaving a very large range for interpretations, making law less transparent. However, this phenomenon is far from being exclusively African. Many EU laws also contain these kinds of expectations, e.g., *REG (EC) 178*/*2002*. However, subsequent acts provide the details of the bases set in these general laws, e.g., *REG (EC) 2073*/*2005* on the microbiological criteria for a series of foodstuffs. Still, the current EU novel food regulation (*REG (EC) 2015*/*2283*) also sets the bases for novel food certifications, but does not

contain specific indication on production, processing, or quality control. A corresponding amendment of *REG (EC) 2073*/*2005* for the EU is dearly awaited.

So, African food laws are sometimes outdated and lack depth, which would increase their applicability. However, food safety in Africa is a basic problem, regardless of how efficient the legislation is. Kussaga et al. (2013) [18] present a large list of microbiological and chemical risks detected in African foodstuffs, ranging from pesticides, mycotoxins, heavy metals, over many bacteria to a series of vermiform parasites. Apart from that, Africa is experiencing a serious problem with antibiotics residues in its foodstuffs. An extensive review concluded that in some African countries, the prevalence of veterinary drugs contained in foodstuffs amounted to up to 94% in certain countries. This may affect both the food-processing industry (e.g., fermented dairy products) and the consumer alike [19]. This shows that food safety in Africa is a very immanent problem.

This condition becomes even more complicated. On one hand, traditional food habits have changed in Africa, creating products not clearly addressed in the current legislation. As an example, for Western Africa, not only the total amount of food required has increased, but consumers' preferences have shifted to convenience products, consuming more perishable products, and a growing awareness of food quality issues [20]. Improving policy coordination and policy implementation are, in fact, two of the key recommendations the aforementioned authors give to modernize the Western African food sector.

On the other hand, the "modernization" of traditional foods does not always improve their quality. As traditional food production has experienced labor ease by means of mechanization of e.g., cutting and grating processes, the production increase has not lead to a growing awareness of food safety, good manufacturing practices, and poor hygiene. Selling food that requires a certain degree of air circulations in tight-sealing plastic bags may also affect the quality by favoring the growth of microaerophilic or even anaerobial flora [17]. Since insects are traditional foodstuffs, these risks may also apply to them.

The degree of entomophagy also varies across the continent. Table 3 shows the different amounts of REIS per country, and while insect consumption may be rather unimportant in e.g., Djibouti or São Tomé and Príncipe, in Botswana, Benin, or Madagascar it plays a larger role. Besides and strictly speaking, introducing an edible species from one African nation to another where the consumption is unknown would make this species a novel food as coined in UEMOA, Niger, or EU regulation.

Another important issue is to tell food safety from food security. Strictly speaking, food security refers to the supply with (any kind of) food (in any quality), while food safety, in contrast, means to provide a foodstuff in a quality that does not compromise the consumer's health, i.e., free of pathogens, toxic substances, foreign bodies, radiation, etc. In many countries, food security is considered more important, particularly in those in that climate and other factors may lead to food shortages. However, AU documents include food safety in food security. Given the importance of food insects in times of the year when food is scarce (the rainy season, time before harvest, etc. [21]), the lacking of the consideration of insects still remains interesting. A possible reason is the fact that a certain portion of the current food legislation originates from colonial times, and the omission of edible insects in the first place may be part of the entomophobia of the colonial rulers. In fact, many people in Europe still consider eating insects either disgusting or a staple for the poor and primitive that cannot afford any "true" food" [22], although these concepts do not, by any chance, reflect the reality. In fact, this seems to be one of the major reasons why entomophagy is still not more popular in Europe, despite corresponding awareness campaigns.

All in all and in comparison to other areas of the world, food safety regulation in many African countries appears scarce or even not existing. One possible explanation may be the fact that governments were forced to focus on food security rather than food safety in response to natural catastrophes and warfare. However, as international African documents exposed here showed, the idea that food security mandatorily has to include food safety is becoming increasingly attended. Besides, the AU has underlined that poor food safety is not only a problem for the population (with 91 million cases of food-borne diseases in Africa per year and 137,000 casualties related to them) but also a problem decreasing the competitiveness of African agriculture inside and outside the continent [23]. The goals formulated in the Malabo Declaration to end hunger in Africa by 2025 will not be reached if food safety is left unattended. In response to that, the first FAO/WHO/AU International Food Safety Conference was held in Addis Ababa in February of 2019, and edible insects were addressed in one session [24], underlining the need to establish concrete policies also with regard to farming insects since the absence of specific regulations may trigger the establishment of insect farms that use—in terms of food safety—unsafe substrates, e.g., slaughterhouse wastes. The ideas raised in Addis Ababa were presented again at a subsequent meeting in Geneva in April of 2019, where the need of harmonizing food safety regulation was stressed [25].

Taking up the misleading conceptions that appear in Western societies on entomophagy, the reality in Africa is, at least locally and seasonally, a huge variety of vivid entomophagous traditions, far from being an "emergency foodstuff" (Figures 1 and 2). Most government bodies interviewed directly consider this tradition, tolerating the consumption and the trade with these animals, even though no concise framework exists. Table 4 showed that most African countries work with foodstuff definitions that permit the inclusion of edible insects, although they may not have been considered at the moment of publishing the corresponding regulations. This is a positive fact, and future framework can be based on these definitions. The will of some of the interview partners to fill this legal gap is also a promising perspective.

**Figure 1.** Fried locusts sold on a Western African market (image by S. Tchibozo).

This was also confirmed by the minutes of a meeting of several governmental and non-governmental organisations (GO and NGO) from in and outside Africa, held in Kenya [26]. One of the meeting's goals was to create awareness of the importance of the insect sector and the need to establish a corresponding legislation, which ideally could be harmonized among countries to ensure a comparable quality. These regulations should include both food safety standards and best practice codes. The future will show what will become of this initiative.

**Figure 2.** Living caterpillars sold on a Central African Market (image by S. Tchibozo).

#### *4.3. Food Insects Obtained from the Wild*

Following the tradition, insects have been caught from the wild in order to be processed and consumed [5]. African wildlife management legislations referring to hunting and/or natural resource management (as that of forests) usually base themselves on "wildlife" definitions that do include insects. In this context, and strictly speaking of law, this can result as a disadvantage, particularly in the moment of hunting respectively gathering them. As in the food law, the application of wildlife management laws to insects may result by mere extrapolation as the regulations were written while having traditional livestock or game species in mind. In those, using some trapping and hunting techniques is clearly banned. However, they do apply to what the definitions understand as "wildlife", and so, light traps, which are typically used to attract insects in the night, may be in fact illegal. The same is true for the permits many regulations request. It may be expected that, except phane in Botswana, gathering edible insects from the wild will be done without asking for these permits, perhaps because it is a traditional way of eating and earning money, perhaps because insects do not have the perceived relevance as cattle or high-priced game species.

Still, forest and wildlife management offer an interesting way to use the insect resource in a sustainable way. These species may be managed in their corresponding biotopes. This, however, requires the awareness that only sustainable use of these insects will ensure a longer-lasting income, rather than exterminating a species by over-harvesting. For this, reliable data on the degree to which a population may be extracted without endangering its survival are necessary, and this data used to be inexistent for insects. Only local gatherers may have this knowledge out of their experience.

In any way, Table 5 shows a large degree of variation among countries. Some allow wildlife management, some do not, and some regulations only refer to specific animal or product groups. Due to the complexity of this issue, it is highly recommended to study the actual situation in a given country intensively before any major uses of insects are made. Tchibozo et al. [27] summarize the necessary requirements to use wild populations thoroughly:


With knowledge, the particular breeding behavior and the feasibility for production can be assessed. This model is laid out for satisfying a local market and is the base of obtaining a solid colony for breeding in captivity, with the option of selling the offspring also abroad [27].

Besides, food safety concerns remain, since forest-derived foodstuffs are even less subjected to quality controls than livestock-derived ones are. Although tradition is prone to cope with traditional food safety problems like spoilage or pathogens, more modern risks as contaminants like insecticides are likely to pass undetected. Besides, modern storage methods like plastic bags also may impair the quality of insect products sold on the market.

A special situation is those species of insects that are edible and a pest at the same time. The idea of consuming edible pest insects is more than tempting, particularly since many of these species have a better nutritional profile that than the crops they feed on. To give an example, teff (*Eragrostis tef*) is a typical East African crop, and contains 12 g of protein/100 g dry matter (value calculated from Baye [28], while orthopterans range between 41 and 91 g/100 g dry matter [6]. Using pest insects may be beneficial from the nutritional point of view opening up a new food resource; it reduces the damage to the crops and is, by itself, part of the environmental management of a given area. Legally, this may be difficult as many countries have established corresponding legislations to combat them. This applies mainly to locusts, but also to other species, as can be seen in Tables 7–10. From the food safety point of view however, the proper use of this food resource will depend fundamentally on the toxicological status of these animals (pesticides) and the possibility to process these animals right after harvesting into a storable product with a stable quality. In fact, orthopterans killed by insecticides are sometimes gathered and sold on West African markets [5].

Finally, some countries protect some native insect species from usage, e.g., Cape Verde and Djibouti, including some that are edible. This is a regular proceeding to protect the national fauna, particularly if the territory is relatively small and, in the case of Cape Verde, a set of island relatively far off the continental coast.

Thus, managing edible insects in the wild is an ancient tradition. However, a sound legal system to ensure sustainability will be necessary to make a larger use of edible insects.

#### *4.4. Insect Farming*

When wildlife management may be difficult because of legal uncertainties and food safety concerns, farming them may be an option [4]. Southeast Asian countries like Thailand, Cambodia, Laos, and Myanmar have started a larger attempt to rear insects and produce them as "mini-livestock" [29]. Two so-called Thai Agricultural standards that deal with crickets (*TAS 8202-2017*) and silkworms (*TAS 8201*/*2012*) are examples on how insect farming is regulated by the government. This option is basically also open to African countries.

From the legal point of view, livestock regulations in Africa are even scarcer than food-related ones and refer, if available at all, exclusively to classical and local domestic species.

Some countries allow wildlife respectively game farms, and if definitions fit, they could be nominally also applied to insects (Table 5). However, the choice of indigenous farmed species must be done carefully in order not to infringe any species protection, wildlife management, or pest control regulation (see above). Bringing foreign productive species (certain cricket and mealworm species or the black soldier fly) into the country may also be hazardous and may infringe on other nature protection or trading laws.

Raheem et al. [4] mention first insect farms for the black soldier fly (*Hermetia illucens*) in South Africa (which in fact is the largest in the world) and Nigeria, but for feed production. Edible crickets are reared in Kenya and Uganda. This implies that at least in those two countries, the setup of these farms was legal.

#### **5. Conclusions**

In this way, asking for food quality standards for edible insects may be challenging if some countries have not addressed food quality standards for meat, fish, or dairy products so far. However, the world progresses, and Africa is a part of the global community just like any other region of the world is, and if foodstuffs' quality will be addressed in the future, those for edible insects should be included. The regulatory framework should address the entire production chain, starting from two different points of primary production, i.e., wildlife resource and farmed insects.

Regarding gathering from the wild, many African countries already have a solid legal base that could be applied to insects. However, population control is vital in order to protect existing natural populations. For food safety, the quality of the gathered animals is critical, particularly in terms of residues and contaminants, and harvested animals should be tested on a regular base, e.g., using Codex Alimentarius recommendations.

The possibility of farming insects in Africa must be assessed thoroughly, taking care not to interfere with land ownership, limited possibilities of using a given area, and, if applicable, farming regulations for livestock and/or wildlife. Animal species' protection, animal imports, and pest legislation must also enter this evaluation. The farmer must be able to control the life cycle of the farmed species. Special care must be taken to avoid the escape of the farmed insects respectively the entry of insect predators into the farm. Once established, a farm ensures food quality by providing a controlled environment to the farmed animals, from the materials used for construction and bedding to the feedstuffs. This is where residues and contaminants can also enter the production chain of a farm. Farms should also be evaluated on a regular base, e.g., to obtain a certificate that it works according to the national requirements. During these evaluations, the inspectors should pay special attention to animal welfare, meaning that the five freedoms also apply to farming insects. Whenever possible, farming must be done according to national law.

Regardless the origin of the harvested animals, killing must be done according to the animal welfare state-of-the-art procedures, which currently is freezing them or mushing them quickly in a blender. As soon as possible, insects must be heated thoroughly (e.g., 100 ◦C for 10 min) to reduce bacterial counts, and rinsed. Storage of merely cooked insects must be in the refrigerator or an ice box, or, better, frozen. Insects preserved by other methods, e.g., drying, smoking, or fermenting can be stored traditionally. However, microbial counts should be assessed for these products in order to provide best-before dates for the consumer. Besides, general hygiene rules also apply to insects just as any other foodstuff.

In terms of public health surveillance, insects sold publicly, regardless if gathered or farmed, should be included in regular monitoring programs. There is no need to treat insect-based products any differently as more established foodstuffs are. Appropriate labeling follows national guidelines and should, by any chance, show the name of the insect (ideally including the scientific name), a best-before date and the information about allergens; all insects contain tropomyosin, which may lead to cross reactions of patients that are allergic to dust (mites) and crustaceans. Laboratory analyses should focus, on one hand, on the gross chemical composition (this may change from batch to batch if feeding regime was changed between batches), antibiotics (using substance specific tests rather than generic inhibitory ones as many insects contain innate inhibitors, which could lead to false-positive results), residues, and contaminants. The other focus is microbiology, with salmonellae, listeriae, total bacterial counts, coagulase-positive staphylococci, *Escherichia coli* and other Enterobacteriaceae, presumptive *Bacillus cereus*, yeasts, and fungi as the most important parameters, plus the ones established in national food law.

**Author Contributions:** Conceptualization, N.T.G. and S.T.; Methodology, N.T.G. and S.T.; Software, N.T.G., S.T., A.A., F.A., M.M.G., and W.A.A.S.; Validation, S.T., A.A., F.A., M.M.G., W.A.A.S., and M.P.; Formal Analysis, N.T.G.; Investigation, N.T.G., S.T., A.A., F.A., M.M.G., and W.A.A.S.; Resources, N.T.G., S.T., M.P.; Data Curation, N.T.G.; Writing—Original Draft Preparation, N.T.G.; Writing—Review and Editing, S.T., A.A., F.A., M.M.G., W.A.A.S., and M.P.; Visualization, S.T.; Supervision, N.T.G., S.T., and M.P.; Project Administration, N.T.G.; Funding Acquisition, M.P. and N.T.G. All authors have read and agreed to the published version of the manuscript.

**Funding:** This research was funded by Deutsche Forschungsgemeinschaft and University of Veterinary Medicine Hannover, Foundation within the funding programme Open Access Publishing.

**Acknowledgments:** The authors wish to express their gratitude to Bernard Cole (Australia, for South Africa) and Jessy Kamwi (Namibia), Embassy of the Central African Republic in Paris, and all contributors from the authors' networks.

**Conflicts of Interest:** The authors declare no conflict of interest.
