AAFCO Approves Yellow Mealworm Meal for Adult Dog Food: The U.S. Regulatory Path From Black Soldier Fly (2016) to Tenebrio Molitor (2024)

In 2024, the Association of American Feed Control Officials (AAFCO) approved a feed ingredient definition for dried Tenebrio molitor (yellow mealworm) meal for adult dogs — only the second insect species in history to receive a non-proprietary AAFCO definition, after Hermetia illucens (black soldier fly larvae) climbed the same ladder from 2016 to 2022. For mealworm processors eyeing the U.S. market, this closed a multi-year gap: yellow mealworm now has an explicit, state-adoptable legal identity in American pet food.

The timing matters as much as the approval itself. On 1 October 2024, the long-standing Memorandum of Understanding between the U.S. Food and Drug Administration (FDA) and AAFCO expired — the mechanism through which insect ingredient definitions historically reached the Official Publication. FDA responded with two guidances: GFI #293, protecting ingredients already defined in the 2024 AAFCO Official Publication, and GFI #294, creating the interim Animal Food Ingredient Consultation (AFIC) pathway.

This article walks through the whole sequence — what was approved, when, under which authority, and what a processor must actually produce to sell mealworm-based feed or pet food in the United States. It is the U.S. counterpart to our earlier guide on the EU novel food authorizations for yellow mealworm.

Why the U.S. approach is structurally different from the EU

The United States has no novel food regime and no pre-market approval for insect species. There is no EFSA dossier, no Union list, no five-year data exclusivity. Instead, insect-derived ingredients enter the market through the general framework of the Federal Food, Drug, and Cosmetic Act (FD&C Act), which classifies animal feed as food and requires every feed ingredient to satisfy at least one of three conditions:

• Approval as a food additive through a Food Additive Petition (formal, data-heavy, slow);
• GRAS status (Generally Recognized As Safe) under 21 CFR Parts 570 and 582 — via self-determination or a GRAS Notification to FDA; or
• Listing in the AAFCO Official Publication — the voluntary association’s ingredient compendium, maintained since 1920 and adopted into state feed law by most U.S. states.

In practice, route 3 has been the highway for insects. AAFCO definitions are non-proprietary, state-adopted, and — until October 2024 — scientifically supported by FDA under the MOU. That is why the phrase you will hear from U.S. pet food manufacturers is not “FDA approved” but “AAFCO defined“. For human food, the logic is even simpler: mealworm is treated as a conventional food, produced under general sanitary and labelling requirements (21 CFR Part 117 for preventive controls), with no notification or approval step before sale.

The insect protein timeline: from black soldier fly to yellow mealworm

Every milestone below is an AAFCO Official Publication action (or an FDA action on the definition process itself). Read top to bottom — it is the exact regulatory history a U.S. importer’s compliance officer will check.

Two observations from this ladder are easy to miss. First, dogs came before cats: the 2021 extension covered adult dogs only, and cats were added for the BSFL forms in 2022. Yellow mealworm currently sits where BSFL sat in 2021 — defined for adult dog food, with cat food, treats and other species still to be formalized. Second, mealworm took eight years after the first insect definition to be recognized; it was not a shortcut, it was a precedent-driven process.

What the 2024 yellow mealworm decision actually allows

The AAFCO definition covers dried yellow mealworm meal intended for adult dog food. Because most states incorporate AAFCO’s Official Publication into their feed control statutes, a manufacturer can formulate, label and sell dog food and treats containing yellow mealworm meal across state lines without a separate federal approval — provided the label uses the defined ingredient name and the product meets AAFCO’s nutrient profiles or feeding trial requirements. The practical consequences for the value chain:

• Exporters gain a defined spec sheet. “Mealworm meal for adult dog food” is no longer judged case-by-case by state feed officials; there is a public definition to contract against (particle form, drying, defat level).
• Cat food and treats remain a gap. Formulators targeting feline diets should document a safety rationale (GRAS conclusion or AFIC consultation) rather than rely on the dog-food definition.
• Human food is a separate track. Dried mealworm for human consumption needs no AAFCO definition — it must simply comply with general U.S. food law: facility registration, 21 CFR Part 117 preventive controls, correct labelling, and sanitary production. No GRAS notice for T. molitor has been identified in FDA’s inventory, and none is required for market access.
• Substrate and process documentation are the buyer’s first request. U.S. importers routinely ask for certificates of analysis, heavy-metal and microbiology panels, and a statement of rearing substrate — the EU-style traceability habit has become a commercial default.

After the MOU expired: GFI #293, GFI #294 and SRIS

The most consequential regulatory news of the period was not a species approval but a process rupture. When the FDA–AAFCO MOU expired on 1 October 2024, the industry lost the review mechanism it had used since the first insect definitions. Three developments replaced it:

GFI #293 — your existing definitions keep their standing

In October 2024, FDA’s Center for Veterinary Medicine published Guidance for Industry #293, stating that FDA does not intend to initiate enforcement action under the food additive requirements of the FD&C Act for ingredients listed in Chapter 6 of the 2024 AAFCO Official Publication. In plain terms: the BSFL definitions and the 2024 yellow mealworm meal definition retain federal standing even without the MOU. This was the guarantee the insect sector needed — no re-filing, no market withdrawal.

GFI #294 — AFIC, the interim front door for new ingredients

FDA announced draft GFI #294 in August 2024 and finalized it in January 2025, establishing the Animal Food Ingredient Consultation (AFIC). AFIC is fee-free, carries no fixed review clock, and publishes a public notice naming the firm, substance and intended use. It sits alongside — not instead of — the two classic routes: Food Additive Petitions and the GRAS Notification program remain fully available. Any company hoping to bring a third insect species (crickets, lesser mealworm, superworm) to the U.S. feed market now starts here or at SRIS.

SRIS — AAFCO’s independent review with a nine-month clock

AAFCO responded with its own pathway: the Scientific Review of Ingredient Submissions (SRIS), run through Kansas State University’s Olathe Innovation Campus. Expert panels evaluate dossiers against the FDA GRAS framework; approved definitions enter the Official Publication. SRIS is fee-based, offers a defined review timeline of roughly nine months, and keeps submission dossiers out of Freedom of Information reach — but it requires peer-reviewed safety data to be public, which can be a real constraint for proprietary processes. Choosing between AFIC and SRIS is now a strategic decision about disclosure, cost and timing certainty.

United States vs. European Union at a glance

What this means for a mealworm processing line sold to the U.S.

American buyers do not ask for a novel food certificate — they ask for evidence that the process is controlled. The regulatory demands above translate directly into equipment and line design choices:

• FSMA 21 CFR Part 507 readiness. Animal food facilities must do a written hazard analysis and implement risk-based preventive controls. A line that lets you document each batch (in-feed ID → sort → dry → packaged lot) is doing half your compliance paperwork. Shuliy’s mealworm separator line is built for batch-traceable sorting of larvae, pupae, dead worms and frass.
• Drying that is provable, not anecdotal. Dried mealworm meal must sit at a low, consistent moisture (typically under 6%) to control microbial growth. Shuliy’s مجفف الميكروويف المستمر holds final moisture under 6% with logged parameters your QA team can attach to a certificate of analysis.
• Defatting for meal formulations. Dog food diets frequently use partially defatted meal to hit protein and fat targets. Shuliy’s mealworm oil extraction machine pairs pressing with the dryer to produce press-cake meal plus a saleable insect oil fraction.
• Grading consistency. The AAFCO definition assumes a defined, uniform meal. Upstream grading with Shuliy’s pupa sorting sifter keeps raw material uniform before drying and milling.
• Black soldier fly lines benefit from the same rules. If your facility runs BSFL as well, the industrial BSF separator covers the 2016–2022 BSFL definitions — the same documentation discipline applies.

One caution worth stating plainly: because the U.S. back-loads oversight rather than front-loading it, the burden of proof sits with the producer. If FDA or a state feed official challenges a product after it is on shelf, you need batch records, lab panels and process specifications to defend it. Buying a line that produces uniform, logged, repeatable output is the cheapest insurance available.

Frequently asked questions

Sources & official references

• FDA CVM Guidance for Industry #293 — Enforcement Policy for AAFCO Defined Animal Feed Ingredients: fda.gov GFI #293
• FDA CVM Guidance for Industry #294 — Animal Food Ingredient Consultation (AFIC): fda.gov GFI #294
• Federal Register — draft GFI #294 availability, confirming expiry of the FDA–AAFCO MOU on 1 October 2024: Federal Register 2024-17778
• AAFCO — Official Publication and ingredient definitions: aafco.org
• Scientific Review of Ingredient Submissions (SRIS), Kansas State University Olathe Innovation Campus: sris.k-state.edu
• 21 CFR Part 507 — CGMP and hazard analysis for animal food (FSMA): eCFR Part 507
• 21 CFR Part 570 — Food additives: GRAS status: eCFR Part 570
• 21 CFR Part 117 — Preventive controls for human food: eCFR Part 117

Last reviewed: 27 October 2026. This article is informational only and does not constitute legal or regulatory advice. Confirm the current AAFCO Official Publication and FDA guidances before formulating or exporting feed and pet food products to the United States.

Talk to Shuliy about a U.S.-ready mealworm line

If you are building a line to supply U.S. pet food or feed manufacturers, send us your target monthly output, raw material form (live larvae or pre-dried) and required end product (dried whole larva, defatted meal, or oil plus cake). We will reply with a sizing proposal, a moisture-and-throughput specification, and the documentation package your buyer’s compliance team will ask for.

Request a sizing proposal → https://mealwormmachine.com/contact/