Work package 1 : advancing algae-based alternatives in eu aquafeeds : pathways to reducing fish-based ingredients : annex to the final report.
Date: 2025-08-14
Institutions: European Climate, Infrastructure and Environment Executive Agency, Seligmann, Tina Maria
Subjects: algae, aquaculture, carbon capture and storage, climate change policy, food industry, food safety, organic farming, organic fertiliser, report, sustainable development, wastewater

European Climate, Infrastructure and  

Environment Executive Agency - CINEA 

Work Package 1 

Advancing algae-based 
alternatives in EU 
aquafeeds: pathways to 
reducing fish-based 
ingredients 

Annex to the Final Repot 

European Maritime, Aquaculture and Fisheries Fund (EMFAF)

Main author: Tina Maria Seligmann (s.Pro - sustainable projects)  

Contributors: Foivos Petsinaris (Trinomics), Kiron Viswanath (Nord University), Freya Robinson,  
Isabel Romero, Efthalia Arvaniti, Ferdinand Bulmer, Angela Schultz-Zehden (s.Pro - sustainable projects) 

June 2025 

 
 
 
 
 
 
EUROPEAN COMMISSION 

European Climate, Infrastructure and Environment Executive Agency 
Unit D.3 — Sustainable Blue Economy 

Contact:  CINEA EMFAF CONTRACTS 

E-mail:   CINEA-EMFAF-CONTRACTS@ec.europa.eu 
https://cinea.ec.europa.eu/  

European Commission 
B-1049 Brussels 

 
 
 
EUROPEAN COMMISSION 

Work Package 1: Advancing algae-
based alternatives in EU aquafeeds: 
pathways to reducing fish-based 
ingredients 
Annex to the Final Report 

CINEA/2023/OP/0006/SI2.906327

2025 

 EN 

European Climate, Infrastructure and Environment Executive Agency 

 
 
 
 
 
 
 
Manuscript completed in June 2025. 

This document has been prepared for the European Climate, Infrastructure and Environment Executive 
Agency (CINEA), however, it reflects the view of the authors and the European Commission or the 
European Climate, Infrastructure and Environment Executive Agency (CINEA) are not liable for any 
consequence stemming from the reuse of this publication. 

Luxembourg: Publications Office of the European Union, 2025 

© European Climate, Infrastructure and Environment Executive Agency, 2025 

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Unless otherwise noted, the reuse of this document is authorised under a Creative Commons Attribution 
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ISBN 978-92-9405-302-2      doi:10.2926/9094435      HZ-01-25-112-EN-N 

 
 
 
Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing 
fish-based ingredients 
Annex to the Final Report 

Contents 

List of figures .................................................................................................. 9 

List of tables .................................................................................................. 10 

Executive Summary ....................................................................................... 11 

Acknowledgement .......................................................................................... 16 

Abbreviations ................................................................................................ 17 

Glossary 19 

1. 

Introduction ............................................................................................ 22 

1.1. 

Introduction .......................................................................................... 22 

1.2.  Scope and methodology ...................................................................... 23 

2.  Algae suitable for aquafeed .................................................................. 25 

2.1.  Nutritional considerations .................................................................... 25 

2.1.1.  Nutritional  requirements  of  key  European  fish  species  and  optimal  feed 
composition ............................................................................................ 25 
2.1.2.  Nutritional value of micro and macroalgae as a feed component ............ 30 

2.2.  Enhancing  nutrient  digestibility  and  bioavailability  through  optimal 
processing methods ............................................................................. 40 

2.3.  High  potential  algae  ingredients  candidates  for  the  use  in  aquaculture 
feed ...................................................................................................... 43 

2.3.1.  Availability, scalability and reliability of these species to meet the demand 
of the aquaculture industry ...................................................................... 44 
2.3.1.1.  The algae market: globally and in Europe .......................................... 44 
2.3.1.2.  Selected microalgae species .............................................................. 45 
2.3.1.3.  Reliability ........................................................................................... 46 

2.4.  Conclusion ........................................................................................... 46 

3.  Benefits and challenges of algae-containing feed .............................. 48 

3.1.  Comparison  of  different  fish  feed  ingredients  and  formulations  (Multi-
Criteria Analysis) .................................................................................. 48 

3.1.1.  Definition of the objective and scope ....................................................... 49 
3.1.2.  Identification of feed options to be analysed ........................................... 50 
3.1.3.  Identification of criteria ............................................................................ 51 

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Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing 
fish-based ingredients 
Annex to the Final Report 

3.1.4.  Performance of the four feed options against each set of criteria ............ 51 
3.1.4.1.  Fish and Feed Performance ............................................................... 52 
3.1.4.2.  Economic criteria................................................................................ 55 
3.1.4.3.  Environmental criteria ........................................................................ 56 
3.1.5.  Allocation of weights to criteria ................................................................ 58 
3.1.6.  Development of decision matrix .............................................................. 58 
3.1.7.  Sensitivity analysis .................................................................................. 61 
3.1.8.  MCA-based recommendations ................................................................ 62 

3.2.  Forage fish dependency ratio (FFDR) ................................................. 64 

3.2.1.  Understanding significance of the FFDR ................................................. 64 
3.2.1.1.  Metrics for assessing marine ingredients for aquaculture ................... 64 
3.2.1.2.  Sustainability considerations regarding the FFDR and the use of forage 
fish .......................................................................................................... 65 
3.2.2.  Examples and FFDR calculation for a potential algal ingredient inclusion 67 
3.2.2.1.  The FFDR thresholds set by the ASC Standard ................................. 67 
3.2.2.2.  FFDR development and current values .............................................. 68 
3.2.2.3.  Calculation for a hypothetical inclusion of 5% algal ingredients .......... 69 
3.2.3.  Recommendations for adjusting the current FFDR ................................. 70 

3.3.  Contaminants  in  fish  and  algae  oil  and  application  of  the  ‘as  low  as 
reasonably achievable’ (ALARA) principle for contaminants ............... 71 

3.3.1.  Contaminant content in fish oil and algae oil destined for aquafeeds ...... 71 
3.3.1.1.  Contaminants in meals and oils derived from fish and algae .............. 71 
3.3.1.2.  Dioxins and PCBs in fish oil ............................................................... 72 
3.3.1.3.  Dioxins and PCBs in algae oil ............................................................ 72 
3.3.2.  Processing  techniques  and  ingredient  sourcing  options  for  reducing 
contaminants .......................................................................................... 73 
for 
contaminants .......................................................................................... 75 
3.3.4.  Inclusion levels of algae .......................................................................... 78 
3.3.4.1.  Optimal inclusion levels of algae ........................................................ 78 
3.3.5.  Recommendations  for  minimum  levels  of  EPA  and  DHA  from  non-fish-
sources in aquafeeds .............................................................................. 81 

3.3.3.  Recommendations 

the  ALARA  principle 

the  application  of 

for 

3.4.  Conclusion ........................................................................................... 85 

4.  Economic viability ................................................................................. 87 

4.1.  Financial incentives for algae-based fish feed ..................................... 87 

4.1.1.  Strategies and financial incentive systems used in the agriculture sector 87 
4.1.2.  Exploring options for financial incentives for algae-based fish feed ......... 88 
4.1.2.1.  Financial instruments and incentives in the EU Green Deal ............... 88 
4.1.2.2.  Types of incentives for the use of algae-based fish feed in sustainable 
aquaculture ............................................................................................. 90 
4.1.3.  Feasibility and recommendations for financial incentives ........................ 96 

4.2.  Conclusion ........................................................................................... 99 

5.  Regulatory framework and compliance ............................................. 100 

5.1.  Regulations relevant to algae as a feed ingredient in the EU ............ 100 

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Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing 
fish-based ingredients 
Annex to the Final Report 

5.1.1.  EU Regulations relevant to algae as a feed ingredient .......................... 102 
5.1.2.  EU Regulations relevant to algae production ........................................ 103 
5.1.3.  National regulations regarding algae feed ............................................. 104 
5.1.4.  Regulatory barriers ............................................................................... 105 

5.2. 

Industry standards and certification ................................................... 106 

5.2.1.  Certification ........................................................................................... 107 
5.2.2.  CEN Standards ..................................................................................... 108 
5.2.3.  Recommendations for additional new standards ................................... 109 

6.  Market examples .................................................................................. 111 

6.1.  Example 1: Algae ingredient producer ............................................... 112 

6.2.  Example 2: Feed producer ................................................................ 116 

6.3.  Example 3: Aquaculture producer ...................................................... 117 

7. 

Future trends ........................................................................................ 120 

7.1.  Global and EU status of fish-based ingredients in aquafeeds ........... 120 

7.2.  Historical market trend data and expected developments ................. 123 

7.2.1.1.  Developments in aquaculture and fisheries ...................................... 123 
7.2.1.2.  Developments for fish oil and fishmeal ............................................. 124 

7.3.  Potential  of  algae-based  ingredients  to  replace  fishmeal  and  fish  oil  in 
aquafeeds .......................................................................................... 127 

7.3.1.  Algae meal for the replacement of fishmeal .......................................... 128 
7.3.2.  Algae oil for the replacement of fish oil ................................................. 129 

7.4.  Requirements for replacing fish-based ingredients with algae-based feed 
ingredients in the current EU aquaculture .......................................... 130 

7.4.1.  Required algae species ........................................................................ 130 
7.4.2.  Technological and spatial feasibility ...................................................... 132 
7.4.2.1.  Optimisation of algae utilisation and technology ............................... 132 
7.4.2.2.  Algae cultivation inside and outside of Europe and side stream utilisation
 ......................................................................................................... 133 

7.5.  Conclusions on future trends ............................................................. 138 

8.  Conclusions and summary of recommendations ............................. 140 

8.1.  Conclusions ....................................................................................... 140 

8.2.  Summary of recommendations .......................................................... 143 

Annexes ........................................................................................................ 145 

Annex I – Tables ......................................................................................... 145 

7 

  
Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing 
fish-based ingredients 
Annex to the Final Report 

1.1  Nutritional requirements for European key fish species ..................... 145 

1.2  Composition of selected algae species .............................................. 149 

1.3  Contaminants in fish oil ...................................................................... 151 

1.4. Limits for dioxins and PCBs ................................................................. 153 

1.5. Limits for dioxins and PCBs ................................................................. 154 

Annex II – Calculations ............................................................................... 158 

1.1  FFDR Calculations ............................................................................. 158 

Annex III – Multi Criteria Analysis (MCA) .................................................... 160 

1.1 

Identification of Criteria ...................................................................... 160 

1.2  Allocation of weights to criteria .......................................................... 162 

1.3  List of literature sources utilised for the MCA .................................... 165 

Annex  IV  –  Strategies  and  financial  incentive        systems  used  in  primary 
production sector ............................................................................... 167 

1.1  Overview  of  the  strategies  and  financial  incentive  systems  used  in  the 
agriculture sector ............................................................................... 167 

1.1.1  Direct financial support ......................................................................... 167 
1.1.2  Market-based instruments .................................................................... 168 
1.1.3  Trade policy tools .................................................................................. 168 
1.1.4  Risk-sharing instruments ...................................................................... 169 
1.1.5  Support mechanisms ............................................................................ 169 

1.2  Strategies  and  financial  incentive  systems  used  in  primary  production 
sector ................................................................................................. 170 

1.2.1  Direct Financial Support ........................................................................ 171 
1.2.2  Market-based financial instruments ....................................................... 173 
1.2.3  Trade policy tools .................................................................................. 175 
1.2.4  Risk-sharing instruments ...................................................................... 176 
1.2.5  Support mechanisms ............................................................................ 176 

Annex V – Additional graphics .................................................................... 178 

1.1  Summary graphic: benefits of algae-containing feed as a replacement for 
fish-containing feeds .......................................................................... 178 

Annex  VI  –  Summary  of  recommendations  including  summarised  rationale

179 

1.1  Summary of recommendations including summarised rationale ........ 179 

8 

 
 
Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing 
fish-based ingredients 
Annex to the Final Report 

List of figures 

Figure 1 – Feed ingredients [%] commonly used in feeds for the grower phases 
of selected species (grower) in 2016 ................................................................ 27 

Figure 2 – Changing trends in feed ingredient use in the salmon feed sector 
from 1990 to 2030 ............................................................................................ 29 

Figure 3 – Performance of the feed options under four weighting scenarios .... 62 

Figure 4 – World’s marine fisheries stocks from 1975 to 2021 ......................... 66 

Figure 5 – FIFO and FFDR for salmonids and marine finfish from 2000 to 2020
 ......................................................................................................................... 68 

Figure 6 – Sources of marine ingredients in Norwegian salmon feed in 2020 .. 80 

Figure 7 – Modelled global flows of EPA and DHA for fish oil and fishmeal 
production [kilotonnes] ..................................................................................... 82 

Figure 8 – World fishmeal use by sector ........................................................ 121 

Figure 9 – World fish oil use by sector ........................................................... 121 

Figure 10– World fisheries and aquaculture production of aquatic animals 
1980-2032 ...................................................................................................... 124 

Figure 11 – World fishmeal production ........................................................... 125 

Figure 12 – Fishmeal and fish oil prices in Europe ......................................... 126 

Figure 13 – Algae as a replacement for fish-based feed ingredients .............. 178 

9 

 
 
 
Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing 
fish-based ingredients 
Annex to the Final Report 

List of tables 

Table 1 – Target species of algae and fish ....................................................... 23 

Table  2  – Nutritional  requirements  for  different  European  key  fish  species 
(grower) ............................................................................................................ 27 

Table  3 – Proximate  composition  of  the  selected  microalgae  and  macroalgae 
species [% per dry matter] ................................................................................ 32 

Table 4 – EPA and DHA in selected fish species and algae [mg/g dry weight]  34 

Table 5 – Amino acids in selected algae that are deemed essential for fish [g/100 
g protein] .......................................................................................................... 36 

Table  6 – Application  summary  for  selected  micro-  and  macroalgae  as  a 
replacement in aquafeed. ................................................................................. 40 

Table 7 – Decision matrix comparing all types of feed against three categories of 
criteria. ............................................................................................................. 60 

Table 8 – Suggestions for the lowering of legal upper limits for dioxins and PCBs 
in fish oil and selected compound feed (Current value → suggestion) ............. 77 

Table 9 – Indicative requirements for EPA, DHA, and EPA + DHA for selected 
species  and  suggested  minimum  target  for  replacement  with  non-fish  derived 
EPA and DHA [g/kg diet] .................................................................................. 84 

Table 10 – Overview of relevant EU regulations ............................................ 101 

Table 11 – Fishmeal and fish oil production in the EU, including quantity and value 
of imports and exports in 2022. ...................................................................... 122 

Table 12 – Nutritional requirements for Atlantic salmon, Salmo salar ............ 145 

Table 13 – Nutritional requirements for European seabass, Dicentrarchus labrax
 ....................................................................................................................... 146 

Table 14 – Nutritional requirements for gilthead seabream, Sparus aurata ... 147 

Table 15 – Nutritional requirements for rainbow trout, Oncorhynchus mykiss 148 

Table 16 – Proximate composition of selected algae [%] ............................... 149 

Table 17 – Contaminants in fish oil that are used to make feed in Norway .... 151 

Table  18  -  Legal  upper  limits  for  dioxins  and  PCBs  in  selected  animal  feed 
products ......................................................................................................... 153 

Table 19 – Relevant CEN standards on animal feeding stuffs (CEN 327) ..... 154 

Table  20 – Relevant  CEN  standards  on  algae  and  algae  products  (CEN  454)
 ....................................................................................................................... 155 

Table  21 – Selection  of  Sustainability-,  GHG-,  CFP-,  LCA-related  standards 
applicable to algae ......................................................................................... 157 

Table 22 – Summary of recommendations including summarised rationale .. 179 

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Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing 
fish-based ingredients 
Annex to the Final Report 

Executive Summary 

Background  

The  global  population  currently  exceeds  8  billion  and  is  projected  to  continue 
growing  rapidly  in  the  coming  years.  This  population  increase  necessitates  a 
corresponding  rise  in  food  production,  particularly  of  high-quality  proteins  and 
essential  nutrients.  Aquatic  foods  account  for  about  15%  of  the  global  animal 
protein supply and even exceed 50% in several countries across Asia and Africa, 
serving as a vital nutritional resource.  

As  wild  fish  stocks  are  limited,  the  role  of  aquaculture  has  grown  significantly, 
developing into the fastest-growing food sector. In 2022, a milestone was reached 
when  the  production  of  aquatic  species  through  aquaculture  surpassed  that  of 
capture fisheries for the first time (1). To enable fish to be raised in aquaculture, 
substantial amounts of feed are required.  

Traditionally, carnivorous species such as salmon have been fed primarily on wild 
forage fish, which are specifically caught for this purpose. Over the past decades, 
reliance on fishmeal and fish oil derived from these forage fish has decreased, 
largely  due  to  the  increasing  use  of  plant-based  ingredients  as  replacements. 
Despite  this  progress,  approximately  22%  of  the  world’s  wild-caught  fish 
continues  to  be  processed  into  fishmeal  and  fish  oil  for  non-food  purposes, 
primarily  for  aquafeed,  as  of  2022.  This  practice,  combined  with  rising 
aquaculture  production,  has  contributed  to  overfishing,  which  poses  significant 
challenges for marine ecosystems. Alarmingly, around 88% of forage fish stocks 
are currently either overfished or exploited at their maximum sustainable yield (2).  

Considering  these  challenges,  there  is  an  urgent  need  for  sustainable 
alternatives.  European  initiatives,  such  as  the  Green  Deal,  the  Farm  to  Fork 
Strategy,  and  the  Sustainable  Blue  Economy  Communication,  alongside 
numerous  research  studies,  highlight  the  potential  of  algae  as  a  sustainable 
solution for aquaculture. Several companies are already producing and utilising 
algae-based ingredients to replace traditional fish-based components.  

While the use of algae may initially seem unconventional, they represent a logical 
choice when examining the aquatic food chain. In simplified terms, carnivorous 
fish  consume  other  fish,  which  obtain  their  nutrients  from  smaller  aquatic 
organisms that, in turn, feed on micro-organisms such as algae. By incorporating 

(1)  FAO  (2024).  The  State  of  World  Fisheries  and  Aquaculture  2024  –  Blue  Transformation  in 
action. Rome, https://doi.org/10.4060/cd0683en.  
(2)  FAO  (2024).  The  State  of  World  Fisheries  and  Aquaculture  2024  –  Blue  Transformation  in 
action. Rome, https://doi.org/10.4060/cd0683en. 

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Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing 
fish-based ingredients 
Annex to the Final Report 

algae directly into aquafeed, we can effectively eliminate the forage fish, while 
still delivering the required nutrients. Certain algae are especially rich in essential 
nutrients, providing protein and specific valuable omega-3 fatty acids, including 
eicosapentaenoic acid (EPA) and docosahexaenoic acid (DHA). These nutrients 
are crucial for both fish and human health. The omega-3 fatty acids that are found 
in  fish  in  fact  primarily  originate  from  their  (direct  or  indirect)  consumption  of 
algae, which are the original source of EPA and DHA – nutrients rarely found in 
other  organisms.  This  distinctive  characteristic  makes  algae  a  particularly 
promising  alternative  for  aquafeed.  Additionally,  algae  have  the  potential  to 
provide  a  range  of  ecosystem  services  that  could  benefit  society.  However, 
several challenges must be addressed before they can be used in large quantities 
in aquafeeds. 

Purpose, scope and methodology of this work package 

The  purpose  of  this  work  package  is  to  evaluate  the  potential  of  micro-  and 
macroalgae as alternatives to fish-derived ingredients in aquafeed, with a focus 
on  establishing  minimum  inclusion  targets  for  non-fish-derived  EPA  and  DHA, 
reducing  forage  fish  dependency  (FFDR)  and  contaminants,  and  developing 
financial and policy frameworks to support the transition toward more sustainable, 
algae-based feeds in line with the EU Algae Initiative. Furthermore, it provides 
specific  recommendations  for  the  transition  from  fish-based  to  algae-based 
aquafeed ingredients and explores future trends and opportunities for advancing 
the algae feed industry. 

Conducted  over  a  period  of  1.5  years,  this  report  aligns  with  the  European 
Commission  Communication  from  the  EU  Algae  Initiative  (2022),  Towards  a 
Strong  and  Sustainable  EU  Algae  Sector.  It  directly  supports  the  policy  action 
outlined  therein  to  “develop  a  guidance  document  to  promote  replacing  fish-
based  feed  with  algae-based  feed”  and  aims  to  accelerate  the  growth  of  the 
European algae sector. While the primary target audience for this report includes 
the Directorate-General for Maritime Affairs and Fisheries (DG MARE) and the 
European Climate, Infrastructure and Environment Executive Agency (CINEA), it 
also serves as a valuable resource for industry stakeholders, researchers, and 
the general public. 

This work package focused on the following species: 

•  Microalgae: Schizochytrium sp., Nannochloropsis sp., Chlorella sp. 

•  Macroalgae: Ulva sp., Saccharina latissima, Palmaria palmata 

•  Fish species: Atlantic salmon, rainbow trout, European seabass, gilthead 

seabream  

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Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing 
fish-based ingredients 
Annex to the Final Report 

This  work  package  synthesises  knowledge  from  both  literature  and  industry 
experts  regarding  the  potential  of  micro-  and  macroalgae  as  aquafeed 
ingredients. It evaluates several types of aquafeed and the nutritional suitability 
of algae using around 260 literature sources (mainly from 2020 onward), as well 
as 12 stakeholder interviews across the value chain and expert consultations. A 
Multi-Criteria  Analysis  (MCA)  was  carried  out  to  compare  the  performance  of 
algae-, insect-, and fish-based feeds using only directly comparable sources and 
weighted  criteria.  The  report  also  includes  written  responses  from  an  algae 
ingredient producer, a feed producer and an aquaculture producer, each utilising 
algae. Moreover, a forecast analysis on future algae inclusion in aquafeeds was 
performed. To further validate the results, feedback from the EU4Algae working 
group was incorporated, along with a survey whose feedback informed the final 
recommendations. 

Key Findings 

Based on the nutritional analysis of the selected algae species, microalgae were 
found to be the superior choice compared to macroalgae for integration into feed 
as a replacement for fish oil and fishmeal. 

It  should  nevertheless  be  noted  that  both  micro-  and  macroalgae  contain 
bioactive compounds that may serve as high-value feed additives and contribute 
positively  to  overall  fish  health.  Among  the  analysed  microalgae  species, 
Schizochytrium  sp.  was  deemed  particularly  relevant  for  the  production  of  the 
omega-3  fatty  acid  DHA,  as  it  is  one  of  the  few  species  capable  of  doing  so. 
Certain  Schizochytrium  strains  can  also  produce  EPA.  However,  higher 
quantities  of  EPA  can  be  obtained  from  Nannochloropsis  sp.  Moreover, 
Nannochloropsis  sp.  and  Chlorella  sp.  are  especially  rich  in  protein,  with  a 
suitable  amino  acid  profile  for  replacing  fishmeal.  While  Schizochytrium  sp. 
contains lower protein levels, it remains suitable for inclusion in aquafeeds. 

Although  the  thick  cell  walls  of  some  microalgae  species  can  affect  nutrient 
digestibility when used in feeds, pre-treatments such as cell-wall disruption or the 
application of specific enzymes have been shown to improve digestibility. 

As a component in aquafeeds, a significant advantage for microalgae compared 
to fish-based ingredients is that they can be produced in controlled environments, 
enhancing both safety and reliability as ingredients. Currently, Schizochytrium sp. 
is  the  most  widely  used  microalgae  in  aquafeeds  as  a  source  of  algae  oil.  In 
addition,  Nannochloropsis  sp.  and  Chlorella  sp.  is  also  cultivated  in  significant 
amounts in the EU. The market for algae ingredients has seen notable growth in 
the recent past and is expected to keep expanding in the future.  

The  results  of  the  Multi-Criteria  Analysis  (MCA)  revealed  that  fish  feeds 
containing  significant  amounts  of  algal  ingredients  –  as  replacements  for  fish-

13 

Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing 
fish-based ingredients 
Annex to the Final Report 

based ingredients – can achieve feed conversion ratios (FCR), specific growth 
rates  (SGR),  and  overall  fish  health  outcomes  comparable  to  those  of 
conventional feeds. Furthermore, the use of algae-containing feeds improved fish 
quality  and  reduced  contaminant  levels,  providing  clear  benefits  for  both  the 
aquaculture industry and consumers. 

Economically,  production  of  algae-based  feeds  is  often  more  expensive  than 
conventional  feeds.  However,  they  offer  greater  price  stability  and  supply 
reliability, especially when algae are cultivated in controlled environments. The 
environmental  performance  of  algae-containing  feeds  varies  depending  on 
production  conditions.  Nevertheless,  some  studies  suggest  that  large-scale, 
circular  production  methods  can  result  in  algae-based  feeds  that  are  more 
sustainable  than  traditional  fish  feeds.  Crucially,  the  shift  towards  algae-
containing feeds can help reduce pressure on wild fish stocks, thereby supporting 
marine ecosystems and enhancing biodiversity. 

The  current  regulatory  landscape  is  already  suitable  for  the  inclusion  of  algal 
ingredients,  and  several  certifications  already  consider  alternative 
feed 
ingredients, including algae. 

Although the use of algae in fish feeds for the grow-out stages – from juvenile to 
market-ready – is still relatively new, algae are already being incorporated, with 
an  estimated  average  inclusion  rate  of  1%.  Projections  suggest  that  a  5% 
inclusion rate may be realistic within the next five years. 

The algae oil market is already more mature than that for algae meal. It has been 
calculated that an average inclusion of 5% algae oil in European aquafeeds could 
reduce total fish oil usage by approximately two-thirds – equivalent to more than 
100,000 tonnes of fish oil per year. However, the industry does not yet appear 
ready to incorporate more than 3% algae meal, despite research indicating that 
inclusion rates of 10% or more may be feasible, depending on the farmed fish 
species. 

Further advancements in technology and the utilisation of side streams from other 
industries can support the growth of the algae market. In developing the algae 
feed industry, a focus on circular approaches can enhance both economic and 
environmental sustainability. While most current large-scale producers of algae 
oil import ingredients into Europe, studies suggest that domestic production could 
offer  significant  advantages.  The  cultivation  of  heterotrophic  algae,  such  as 
Schizochytrium  sp.,  requires  an  appropriate  carbon  source,  and  several 
European sugar side streams have been identified as feasible options. The most 
suitable choice may vary depending on location and other contextual factors. 

the  sustainable 
Current  real-world 
production of algae is not only feasible on a large scale but also increasingly in 
demand  within  the  aquaculture  industry.  As  fish-based  feed  options  become 

industry  examples  demonstrate 

that 

14 

Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing 
fish-based ingredients 
Annex to the Final Report 

depleted,  the  algae  feed  sector  is  poised  for  growth.  Given  the  current 
circumstances,  the  implementation  of  appropriate  support  measures  without 
further delay is urgently required. 

With forage fish availability being limited and overfishing remaining a persistent 
issue, timely support is crucial to encourage greater investments in sustainable 
algae-based  feed.  Without  such  support,  companies  may  divert  their  focus  to 
other  sectors,  potentially  hindering  the  development  of  the  algae  ingredient 
market for aquafeeds. 

To enable the incorporation of algal ingredients as substitutes for larger quantities 
of  fish  oil  and  fishmeal  in  the  near  future,  policy  changes  at  the  governmental 
level will be necessary. This report aims to support such efforts by outlining both 
the  advantages  and  the  challenges  associated  with  the  adoption  of  algae 
ingredients in aquafeeds. A range of relevant aspects has been explored, and the 
following recommendations have been identified as feasible. 

Conclusion and Recommendations 

Conclusions based on WP1 findings as well as corresponding recommendations 
are laid down in Chapter 8 Conclusions and summary of recommendations. 

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Acknowledgement 

We would like to express our gratitude to the individual experts, as well as the 
respective  companies  and  organisations,  for  generously  sharing  their  valuable 
insights  and  opinions  throughout  this  work.  We  also  greatly  appreciate  the 
feedback received during the working group meetings and the validation process, 
which significantly enhanced the quality of this report. 

We would like to extend a special thanks to Corbion, AllerAqua, and Cermaq for 
providing  extensive  insights  in  the  Market  Example  section,  as  well  as  for 
participating  in  industry  interviews.  We  also  want  to  thank  Veramaris,  FEAP 
(Federation of European Aquaculture Producers), EATiP (European Aquaculture 
Technology  & 
the  Danish  Aquaculture  Producer 
Organisation, Atlantik Fish - Pescado da Maré and several other companies that 
must remain unnamed due to data protection  reasons, for their participation in 
the  industry interviews.  Their  insights  were  invaluable. We  also appreciate  the 
contributions from Silvio Mangini from Archimede Ricerche srl, especially for his 
significant support in the regulatory and standards section. 

Innovation  Platform), 

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Annex to the Final Report 

Abbreviations 

Abbreviation 

Definition 

ASC-MSC 

Aquaculture Stewardship Council (ASC) - Marine Stewardship Council (MSC) 

BAP 

CEN 

Best Aquaculture Practices 

European Committee for Standardization 

CINEA 

European Climate, Infrastructure and Environment Executive Agency 

DG MARE 

The Directorate-General for Maritime Affairs and Fisheries 

DHA 

Docosahexaenoic acid 

EC 

EU 

European Commission 

European Commission 

eFCR 

Economic feed conversion ratio 

EMFAF 

European Maritime, Fisheries and Aquaculture Fund 

EPA 

EU 

Eicosapentaenoic acid 

European Union 

EUMOFA 

European Market Observatory for Fisheries and Aquaculture products 

FCR 

FAO 

FCR 

Feed conversion ratio 

Food and Agriculture Organization of the United Nations 

Feed conversion ratio 

FFDR 

Forage fish dependency ratio 

FIFO 

GMP 

GWP 

Fish in : fish out ratio 

Good manufacturing practices 

Global warming potential 

HACCP 

Hazard analysis critical control point 

IFFO 

IMTA 

International Fishmeal and Fish Organisation 

Integrated multi-trophic aquaculture 

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Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing 
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Abbreviation 

Definition 

LCA 

MCA 

PCBs 

PES 

POPs 

PUFA 

SGR 

WHO 

WTO 

Life cycle assessment 

Multi criteria analysis 

Polychlorinated biphenyls 

Payment for Ecosystem Services 

Persistent organic pollutants 

Polyunsaturated fatty acids 

Specific growth rate 

World Health Organisation 

World Trade Organisation 

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Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing 
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Glossary 

Term 

Definition 

Algae 

According to the European standard EN 17399:2024, algae are a functional group 
of organisms consisting of microalgae, macroalgae (seaweeds), cyanobacteria 
and labyrinthulomycetes. 

Algae-
containing feed, 
algae-feed 

In this report, algae-containing feed or algae feed refers to aquafeed that 
contains algae, for example in the form of algae oil or algae meal, which exceeds 
minimal additive levels, and replaces a meaningful portion of the fish oil or 
fishmeal typically found in conventional feed. 

In the comparison between different feed options, the Multi Criteria Analysis 
(MCA) that is part of this work package, the following four feed types are 
specifically defined as: 

1)  “Standard” feed without alternative feed ingredients 

Alternative feeds: 

2)  Algae-containing feed containing at least 3% microalgae 
3)  Algae-containing feed without fish oil or without fishmeal: containing 
at least 3% microalgae but with an entire replacement of either fish oil or 
fishmeal with other ingredients 
Insect-containing feed: containing a significant amount of insect-derived 
ingredients, primarily as a protein source, and no algal ingredients 

4) 

Algae biomass: refers to the entire algal material, including all its components 
without separating or biorefining 

Algal 
ingredients, 
algae-based 
ingredients 

Algae oil: the oil extracted from algae, primarily valued for its high omega-3 fatty 
acid content, particularly EPA (eicosapentaenoic acid) and DHA 
(docosahexaenoic acid). While "algae oil" primarily highlights these fatty acids, it 
may also contain other lipid fractions.  

Algae meal: the by-product remaining after the extraction of oil from algae. It is 
often characterised by a high protein content and can be used as a nutrient-rich 
feed ingredient.  

Algae protein: refers to the isolated protein fraction obtained from algae. This 
component can also be valued for its nutritional and functional properties. 

Alternative 
ingredients 

This can include algae, insect meal, single cell proteins, such as bacteria or fungi 
and fermented products. 

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Term 

Definition 

Hatchery stage: involves the breeding and early rearing of larvae under 
controlled conditions. 

Nursery stage: includes the fry and fingerling phases, where young fish are 
grown until they are large enough to be transferred to grow-out systems. 

Aquaculture 
production 
stages 

Grower stage: the developmental phase during which fish or shellfish are raised 
from juvenile to market size. The feed used during this stage is referred to as 
“grower feed”. 

Broodstock stage: the phase involving mature, reproductively active fish or 
shellfish to produce healthy offspring. 

Every stage requires a specific type of feed tailored to the unique nutritional 
needs at that stage of development (comparison Annex I Section 1.1). 

Autotrophic: being able to produce complex organic nutrients from simple 
inorganic sources like carbon dioxide, water, and nitrates by utilising energy from 
the sun (3). 

Heterotrophic: being able to use only organic materials as a food source (4). 

The terms "by-products," "trimmings" (or “trimmings and offal”)" are used 
interchangeably in this context. They refer to the remains after fish processing, 
which can originate from both wild-caught fish and aquaculture processing. 

Long-chain omega-3 fatty acids that are primarily found in fish oil and certain 
algae. 

“Feed (or “feeding stuff”) means any substance or product, including additives, 
whether processed, partially processed or unprocessed, intended to be used for 
oral feeding to animals”. (Regulation (EC) No 178/2002, Article 4) 

While "feed additives" are also categorised as feed, and they are governed via 
Regulation (EC) No 1831/2003 on additives for use in animal nutrition. According 
to Article 2 of this regulation, “Feed additives means substances, micro-
organisms or preparations, other than feed material and premixtures, which are 
intentionally added to feed or water in order to perform, in particular, one or more 
of the functions mentioned in Article 5 (3).” Those functions can be to improve 
feed quality, enhance animal products, meet nutritional needs, benefit animal 
welfare, reduce environmental impacts, or provide specific health effects. 

Autotrophic, 
heterotrophic 

By-products, 
trimmings 
(trimmings & 
offal) 

EPA (Eicosa-
pentaenoic Acid), 
DHA (Docosa-
hexaenoic Acid) 

Feed 

Feed additives 

Feed materials, 
feed ingredients 

Regulation (EC) No 767/2009 defines feed materials as “products of vegetable or 
animal origin, whose principal purpose is to meet animals’ nutritional needs, in 
their natural state, fresh or preserved, and products derived from the industrial 
processing thereof, and organic or inorganic substances, whether or not 
containing feed additives, which are intended for use in oral animal-feeding either 
directly as such, or after processing, or in the preparation of compound feed, or 
as carrier of premixtures.” 

(3) Dictionary.com (n.d.). Autotrophic. https://www.dictionary.com/browse/autotrophic.  
(4) Dictionary.com (n.d.). Heterotrophic. https://www.dictionary.com/browse/heterotrophic. 

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Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing 
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Term 

Definition 

Fish oil, 
Fishmeal 

Fish oil is a substance that is extracted from fatty fish, such as anchovy, sprat, or 
herring, and is rich in omega-3 fatty acids. Fishmeal is the protein-rich powder 
that is left after the oil extraction (5).  

Forage fish, 
Whole fish,  
Wild fish 

The terms "forage fish," "whole fish," and "wild fish" are used interchangeably in 
this context. They refer to wild fish that are caught and used in feed production as 
a whole. 

A group of algae (see definition “algae”), that are typically single-celled and found 
in marine and freshwater environments. 

This report will focus on the following microalgae:  

Microalgae 

1.  Chlorella sp., a microalga that can grow autotrophically 

heterotrophically or mixotrophically (a combination of both).  

2.  Nannochloropsis sp., an autotrophic microalga. 
3.  Schizochytrium sp., a heterotrophic microalga (Taxonomically a protist, 
Class: Labyrinthulomycetes), known for its high content of omega-3 
fatty acids. 

A larger, multicellular type of algae (see definition “algae”), that is found in marine 
and freshwater environments and is classified into three main groups based on 
their colour: green, brown, and red algae.  

Macroalgae 
(=seaweeds) 

This report will focus on the following macroalgae:  

1.  Ulva sp., also known as sea lettuce, a type of green seaweed. 
2.  Palmaria palmata, also known as dulse, a type of red seaweed. 
3.  Saccharina latissima., also known as sugar kelp, a type of brown 

seaweed. 

(5) EUMOFA (2023). Fishmeal and Fish Oil. Available here. 

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1.  Introduction 

1.1.  Introduction 

17 million tonnes of wild caught fish – accounting for approximately 22% of the globally 
captured  fish  –  were  processed  into  fish  oil  and  fishmeal  for  non-food  purposes  in 
2022, primarily as feed for aquaculture (6). As aquaculture remains the fastest-growing 
sector  in  the  food  industry,  and  with  overfishing  continuing  to  present  a  major 
challenge, identifying alternative feed sources is essential. 

This  work  package  investigates  the  suitability  of  algae-based  ingredients  as 
replacements for fish-based components in aquafeeds within the EU. It concludes that 
algae  –  particularly  certain  microalgae  –  can  serve  as  a  viable  alternative.  Several 
methodologies for supporting the substitution of fish-based ingredients with algae were 
thoroughly  examined,  resulting  in  the  development  of  recommendations  based  on 
these  analyses.  Additionally,  a  forecast  analysis  was  carried  out  to  assess  future 
trends. 

In 2022, the EU Algae Initiative announced in a Communication from the Commission 
Towards  a  Strong  and  Sustainable  EU  Algae  Sector,  23  specific  policy  actions  to 
accelerate the development of the European algae sector.  

The  objective  of  this  work  package  is  to  identify  feasible  methods  for  the 
replacement of fish-containing feed ingredients with algae, in line with EU Algae 
Initiative’s Action 7: To develop a guidance document to promote replacing fish-based 
feed with algae-based feed. 

This  report  will  provide  specific  recommendations  for  replacing  fish-based  feed 
ingredients with algae-based products, while also consolidating scientific knowledge 
on the potential of algae species as aquafeed ingredients. Different alternative feed 
ingredients and blends have been investigated to determine the best results in terms 
of performance, cost, and environmental impact.  

This  work  package  is  intended  for  the  Directorate-General  for  Maritime  Affairs  and 
Fisheries  (DG  MARE)  and  European  Climate,  Infrastructure  and  Environment 
Executive  Agency  (CINEA),  as  well  as  for  industry,  researchers,  and  the  general 
public. 

(6) FAO (2024). The State of World Fisheries and Aquaculture 2024  – Blue Transformation in action. 
Rome, https://doi.org/10.4060/cd0683en. 

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1.2.  Scope and methodology 

The methodology is in accordance with the service requested by CINEA. 

A literature review has been conducted to collect and summarise nutritional data on 
selected  microalgae  and  macroalgae.  Furthermore,  reports  on  optimal  processing 
methods  to  enhance  the  bioavailability  of  nutrients  were  assessed.  For  the  Multi-
Criteria Analysis (MCA), data on growth performance, feed utilisation, and fish health 
parameters were analysed, alongside information on contaminants, production costs, 
retail  prices,  carbon  emissions,  and  environmental  impact.  The  focus  is  on  the 
requirements of four key fish species farmed in Europe. 

Table 1 – Target species of algae and fish 

Organism 

Species 

Microalgae 

Nannochloropsis sp., Chlorella sp., Schizochytrium sp. 

Macroalgae 

Ulva sp., Saccharina latissima, Palmaria palmata 

Fish 

Atlantic salmon, rainbow trout, 
European seabass, gilthead seabream  

The literature review primarily focused on sources published within the past six years 
(from  2019  onwards).  However,  older  publications  of  particular  relevance,  or  those 
addressing specific research gaps, were also included. This was supplemented by key 
literature  recommended  by  various  algae-feed  experts  to  ensure  comprehensive 
coverage.  In  addition,  the  knowledge  base  of  the  EU  Aquaculture  Assistance 
Mechanism  was  systematically  screened  for  relevant  materials.  Where  necessary, 
further  sources  were  identified  through  targeted  searches  in  databases  such  as 
Google Scholar. In total, 260 sources were deemed relevant to the research and were 
analysed accordingly. 

A detailed analysis assessed the suitability of algae-containing feeds for European fish 
species in comparison to conventional feeds, including an evaluation of contaminant 
levels in fish oil and algae oil used in aquafeeds. A Multi-Criteria Analysis (MCA) was 
developed  to  compare  the  performance  of  different  feed  types  and  to  recommend 
optimal  inclusion  levels  based  on  these  findings.  To  perform  the  MCA,  literature 
sources  were  combined  with  the  results  of  12  industry  interviews  –  seven  with 
aquafeed  or  algae  ingredient  producers  and  five  with  aquaculture  producers  or 
associations. These interviews covered topics such as feed performance, pricing, and 
operational costs. Additionally, a workshop with the EU4Algae working group on algae 
feed further contextualised the data and finalised the recommendations. More details 
on the MCA methodology can be found in Section 3.1. 

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In the following sections, various aspects and methodologies for replacing fish-based 
ingredients with algae are analysed and  discussed. These include optimal inclusion 
levels  of  algae;  minimum  blend-in  targets  for  non-fish-derived  EPA  and  DHA;  the 
forage fish dependency ratio (FFDR); contaminants and the application of the ‘as low 
as reasonably achievable’ (ALARA) principle; economic considerations and financial 
incentives; and the regulatory framework for algae production and algae use in feed, 
including  certification  and  standards.  The  content  and  recommendations  in  each  of 
these sections are based on the results of the MCA, additional scientific literature, and 
expert  and  stakeholder  discussions  related  to  each  specific  topic,  to  gain  further 
insight. 

Each recommendation has undergone a validation process: the recommendations and 
the  rationale  behind  them  were  summarised  and  shared  with  stakeholders  from 
various sectors to ensure a broad range of perspectives across the value chain were 
considered. Feedback from stakeholders at seven different organisations – including 
algae ingredient producers, aquafeed manufacturers, farmers using algae-containing 
feeds,  and  an  aquaculture  association  –  was  received  and  incorporated  into  this 
report. 

Section 6 presents three successful market cases of companies already using algae. 
Each  set  of  questions,  as  listed  in  the  section,  was  distributed  to  the  respective 
companies, and their responses were included directly in the report. 

Finally,  a  forecast  analysis  was  performed  for  the  replacement  of  fish-based  feed 
ingredients  by  algae-based  feed  ingredients  in  the  EU.  This  was  based  on  the 
expected inclusion rates for algae for the next five years in combination with data from 
the most recent reports on fishmeal and fish oil demand, especially from the European 
Market Observatory for Fisheries and Aquaculture products (EUMOFA) and the Food 
and Agriculture Organization of the United Nations (FAO). 

The use of artificial intelligence (AI) tools in the WP1 

The  AI  tool  "Ecosia  Chat"  was  utilised  to  enhance  the  writing  style  by  providing 
suggestions  for  improvement  in  selected  sections  of  this  report.  Additionally,  both 
"Ecosia Chat" and "Perplexity" were employed to generate supplementary ideas on 
specific topics, facilitating the exploration of additional concepts that may have been 
overlooked. In cases where these additional AI-generated suggestions were deemed 
relevant, further research was conducted to evaluate their significance, and content 
from scientific articles was incorporated to substantiate the integration of these ideas. 

24 

 
 
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2.  Algae suitable for aquafeed 

Aquaculture  is the  fastest-growing  segment of  the  food  industry and  is projected  to 
increase  its  global  production  by  17%  by  2032  compared  to  2022 (7).  Traditionally, 
fishmeal and fish oil have been the primary protein and lipid sources in aquaculture 
feeds. In 2022, 17 million tonnes of harvested aquatic animals (from both capture and 
aquaculture) were processed into fishmeal and fish oil. Of this, over 87% of fishmeal 
(2022) and 74% of fish oil (2021) was used in aquaculture (8). This continued reliance 
on  fish-based  ingredients  has  placed  substantial  pressure  on  wild  fish  populations, 
which are critical components of marine ecosystems. 

To  promote  sustainability  and  reduce  dependence  on  fish-based  ingredients,  the 
aquaculture sector has been actively exploring alternative ingredients from land-based 
sources,  such  as  high-quality  plant  components  like  soya,  as  well  as  ingredients 
derived from algae and seafood side streams. Algae – both micro- and macroalgae – 
have emerged as promising alternatives due to their nutritional value and potential for 
improved  sustainability  compared 
ingredients.  However,  many 
challenges  remain  to  be  addressed  before  their  full  potential  in  aquafeeds  can  be 
realised. 

fish-based 

to 

Addressing  sustainability  has  become  a  global  priority  across  policy,  research,  and 
science,  with  food  security  and  climate  change  mitigation  at  the  forefront.  The 
European Green Deal, the Farm to Fork Strategy, and the Sustainable Blue Economy 
Communication  all  recognise  the  potential  of  algae  in  tackling  these  challenges. 
Understanding the risks, obstacles, and barriers to developing the algae sector – along 
with addressing knowledge gaps – is essential for enabling future progress. 

2.1.  Nutritional considerations 

2.1.1.  Nutritional requirements of key European fish species and 

optimal feed composition 

There  is  no  one-size-fits-all  formulation  for  fish  feed.  Each  species  has  specific 
nutritional requirements, and even within the same species, different life stages have 
distinct nutrient needs, which directly influence feed composition (Annex I, Table 12 - 

(7) FAO (2024). The State of World Fisheries and Aquaculture 2024  – Blue Transformation in action. 
Rome, https://doi.org/10.4060/cd0683en. 
(8) FAO (2024). The State of World Fisheries and Aquaculture 2024  – Blue Transformation in action. 
Rome, https://doi.org/10.4060/cd0683en. 

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Table 14). 

The  main  nutrient  in  most  aquafeeds  is  protein,  typically  constituting  between  18% 
and 50% of the feed, depending on the species. Lipids are the second most prominent 
nutrient for most species, particularly for carnivorous aquatic organisms that require 
high  energy  levels.  Although  carbohydrates  are  not  a  direct  nutrient  source  for 
carnivorous species, they serve as an energy source for their gut bacteria. In addition 
to macronutrients, fish feeds also contain essential vitamins and minerals, along with 
trace amounts of phosphorus (less than 1.5%) and water (less than 10%) (9). 

Also, even though feed composition varies between species, the overall grower diet 
for rainbow trout, salmon, seabass and seabream is relatively similar (10). The table 
below  presents  the  proximate  composition  of  feeds  for  these  key  European  fish 
species.  

In  Tables  12-14  in  Annex  I,  more  detailed  information  regarding  the  composition, 
including  optimal  amino  acid  profiles  and  recommended  nutrient  compositions  for 
different stages of these species can be found. 

(11) Yarnold, J., Hakan, K., Oey, M., & Hankamer, B. et al. (2019). Microalgal Aquafeeds as Part of a 
Circular Bioeconomy. Trends in Plant Science, 24(10). https://doi.org/10.1016/j.tplants.2019.06.005  
(10) Mathieu-Resuge et al. (2023). Red muscle of small pelagic fishes’ fillets are high-quality sources of 
essential 
120. 
https://doi.org/10.1016/j.jfca.2023.105304  

Composition 

Analysis, 

Journal 

acids, 

Food 

fatty 

and 

of 

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Table 2 – Nutritional requirements for different European key fish species (grower) 

Proximate 
composition  
(% dry feed basis) 

Atlantic 
salmon, Salmo 
salar (marine 
grower) 

Rainbow trout, 
Oncorhynchus 
mykiss 

European 
seabass, 
Dicentrarchu
s labrax 

Gilthead 
seabream, 
Sparus 
aurata 

Crude protein, min [%]  

40-45 

42 

45 

Crude lipid [%] 

24-30 

16-24 

15-18 

45-50 

12-25 

20 

12 

1,1-1,2 

1,2-1,25 

19 

19 

Carbohydrate, max [%] 

12 

EPA+DHA [%] 

1-2,6 

Digestible energy [kJ/g] 

20 

Sources: (11;12;13;14;15). 

12 

1,5 

15,5 

Figure 1 – Feed ingredients [%] commonly used in feeds for the grower phases of 
selected species (grower) in 2016 

Source: This graphic has been adapted from Kreiss et al., 2020 (16). 

sources, 

(11) National Research Council. (2011). Nutrient Requirements of Fish and Shrimp. Washington, DC: 
The National Academies Press. https://doi.org/10.17226/13039  
(12) Zhang, et al. (2023). Omega-3 long-chain polyunsaturated fatty acids in Atlantic salmon: Functions, 
requirements, 
strategies. 
biosynthesis 
https://doi.org/10.1111/raq.12882  
(13) FAO (n.d.). FAQs. Aquaculture Feed and Fertilizer Resources Information System. Available here. 
(14) Qian, C., Hart, B., Colombo, S.M. (2020). Re-evaluating the dietary requirement of EPA and DHA 
for Atlantic salmon in freshwater. Aquaculture, 518. https://doi.org/10.1016/j.aquaculture.2019.734870  
(15) FAO (n.d.). Summary of dietary nutrient requirement and utilization of rainbow trout, Oncorhychus 
mykiss. Available here. 

selective 

breeding 

novo 

and 

de 

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Figure 1 illustrates the composition of feeds for salmon, rainbow trout, seabass, and 
seabream. As the feed composition of seabass and seabream is very similar, they are 
presented  together  in  a  single  bar.  Likewise,  the  feed  composition  of  salmonids  – 
including rainbow trout and salmon – is also comparable. The figure highlights the high 
proportion  of  plant-derived  ingredients  in  feeds  for  carnivorous  fish,  despite  their 
natural diet being heavily reliant on marine sources. 

Shift towards plant-based feed ingredients 

The shift towards plant-based ingredients reflects efforts to reduce the dependency on 
fish-based ingredients in aquafeeds. Currently, fish-based ingredients make up only 
from 
approximately  20%  of  salmon 
approximately  75%  in  1990  (Figure  2).  This  reduction  is  the  result  of  extensive 
research and innovation within the Atlantic salmon farming sector. Since 2015, novel 
ingredients  such  as  insect  meal,  single-cell  proteins,  fermented  products,  and 
microalgae have been incorporated into salmon feeds. For a more detailed analysis 
of the fishmeal and fish oil sectors, refer to Chapter 7 of this report. 

feeds,  marking  a  significant  decrease 

Since 2010 a positive development has been the increasing use of marine by-products 
–  such  as  those  from  aquaculture  processing  –  to  replace  wild-caught  marine 
ingredients in feed. 

(16) Kreiss, C.M., Papathanasopoulou, E., Harmon, K.G. et al. (2020). Future Socio-Political Scenarios 
for Aquatic Resources in Europe: An Operationalized Framework for Aquaculture Projections. Front. 
Mar. Sci., 7, https://doi.org/10.3389/fmars.2020.568159  

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Figure 2 – Changing trends in feed ingredient use in the salmon feed sector from 1990 
to 2030 

Source: IFFO (17). 

EPA and DHA 

The omega-3 long-chain polyunsaturated fatty acids eicosapentaenoic acid (EPA) and 
docosahexaenoic acid (DHA) play a crucial role in maintaining cell membrane integrity 
– not only in humans but also in aquatic species, including carnivorous fish such as 
salmon and trout. In the wild, fish obtain these fatty acids by consuming omega-3-rich 
prey, highlighting the importance of including EPA and DHA in feed formulations for 
farmed fish. Traditionally, fish oil and fishmeal derived from wild marine fish have been 
used  for this purpose in  aquaculture feeds (18).  However, to  reduce the  reliance on 
these  finite  resources,  the  inclusion  levels  of  fish  oil  and  fishmeal  have  been 
progressively lowered over the years by replacing them with alternative ingredients, 
as shown in Figure 2. For example, soybean, canola, corn, lupin, wheat, and barley 
are now widely used to replace fishmeal in feeds, while plant oils have largely replaced 
fish oil (19). These substitutions have led to the overall reduction of EPA and DHA in 
fish products, resulting in a lower nutritional quality of farmed fish. 

(17) IFFO (2021). Is feed evolution driving us towards new ingredients or into circularity?. Available here. 
(18)  Tocher,  D.R.,  Betancor,  M.B.,  Sprague,  M.  et  al.  (2019).  Omega-3  Long-Chain  Polyunsaturated 
Fatty  Acids,  EPA  and  DHA:  Bridging  the  Gap  between  Supply  and  Demand.  Nutrients,  11(1). 
https://doi.org/10.3390/nu11010089  
(19)  Yarnold  et  al.  (2019).  Microalgal  Aquafeeds  As  Part  of  a  Circular  Bioeconomy.  Trends  in  Plant 
Science, 24(10). https://doi.org/10.1016/j.tplants.2019.06.005  

29 

 
 
 
 
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based ingredients 
Annex to the Final Report 

Therefore,  an  ideal  strategy  is  to  incorporate  marine  micro-organisms,  including 
microalgae – the primary producers of omega-3 fatty acids – into feed formulations. 
These micro-organisms not only provide a source of EPA and DHA but also contain 
high-quality  protein  and  other  bioactive  compounds,  making  them  a  promising 
replacement  for  fishmeal  and  fish  oil  in  aquafeeds.  Recently,  the  inclusion  of 
microalgal  oils  has  been  explored  as  an  alternative  to  both  fish  oil  and  plant  oil  in 
aquafeeds (20). Additionally, the application of pigments derived from microalgae has 
become a growing focus within the aquaculture industry in recent years (21). 

2.1.2.  Nutritional value of micro and macroalgae as a feed 

component 

The use of algae in aquafeeds is not a novel concept and has been practised for many 
years. Microalgae have been commonly used as feeds in hatcheries and nurseries, as 
well  as  for  broodstock (22)  during  periods  when  high  lipid  content  is  essential  for 
meeting  their  biological  needs (23).  Microalgae  are  also  used  as  a  live  feed  for 
zooplankton, which in turn are fed to juvenile fish. Traditionally, live algae have been 
used at these life stages, but more recently, the use of algae concentrates and pastes 
in place of live algae has become increasingly popular (24). 

While microalgae have been commonly used in aquaculture for a significant period, 
macroalgae have not been historically incorporated into aquafeeds (25). However, in 
recent  years,  the  use  of  seaweeds  within  the  aquaculture  industry  has  increased, 
primarily  as  part  of  the  integrated  multi-trophic  aquaculture  systems  and  as  natural 
feed sources. For example, macroalgae species such as Ulva sp. are now integrated 
into the cultivation of abalone and sea urchins (26). 

(20)  Tocher,  D.R.,  Betancor,  M.B.,  Sprague,  M.  et  al.  (2019).  Omega-3  Long-Chain  Polyunsaturated 
Fatty  Acids,  EPA  and  DHA:  Bridging  the  Gap  between  Supply  and  Demand.  Nutrients,  11(1). 
https://doi.org/10.3390/nu11010089 
(21) CEVA (2024). Report of the current algae industry in Europe. Available here. 
(22)  Shields,  R.,  &  Lupatsch,  I.  (2013).  "5  Algae  for  aquaculture  and  animal  feeds".  Microalgal 
Biotechnology:  Integration  and  Economy,  edited  by  Clemens  Posten  and  Christian  Walter,  Berlin, 
Boston: De Gruyter, pp. 79-100. https://doi.org/10.1515/9783110298321.79  
(23) Bruce et al. (1999). Development of broodstock diets for the European Sea Bass (Dicentrarchus 
labrax)  with  special  emphasis  on  the  importance  of  n−3  and  n−6  highly  unsaturated  fatty  acid  to 
reproductive performance. Aquaculture, 144(1-4). https://doi.org/10.1016/S0044-8486(99)00071-X  
(24)  Yarnold  et  al.  (2019).  Microalgal  Aquafeeds  As  Part  of  a  Circular  Bioeconomy.  Trends  in  Plant 
Science, 24(10). https://doi.org/10.1016/j.tplants.2019.06.005 
(25)  Shields,  R.,  &  Lupatsch,  I.  (2013).  "5  Algae  for  aquaculture  and  animal  feeds".  Microalgal 
Biotechnology:  Integration  and  Economy,  edited  by  Clemens  Posten  and  Christian  Walter,  Berlin, 
Boston: De Gruyter, pp. 79-100. https://doi.org/10.1515/9783110298321.79  
(26) CEVA (2024). Report of the current algae industry in Europe. Available here. 

30 

 
 
 
Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing fish-
based ingredients 
Annex to the Final Report 

The quality of an aquafeed depends on the ingredients used in its formulation. When 
considering algae as an alternative feed ingredient, it is important to ensure that they 
provide the essential nutrients required for optimal fish performance. 

The nutritional composition of certain microalgae species can be comparable to that 
of  commonly  used  feed  ingredients.  Depending  on  the  species  and  cultivation 
conditions,  microalgae  can  contain  up 
to  60%  protein,  70%  oil,  or  60% 
carbohydrates (27).  Additionally,  fibre  –  a  type  of  complex  carbohydrate  –  typically 
ranges from 5% to 18% in microalgae (28). 

However,  the  nutritional  profile  of  algae  can  vary  significantly  between  species. 
Environmental  factors  such  as  light  intensity,  temperature,  nutrient  availability,  and 
harvesting methods also play a crucial role in determining the biochemical composition 
of algae (29). 

Macroalgae can also serve as an ingredient for fish feeds to supply nutrients such as 
protein,  lipids,  and  minerals (30).  The  protein  content  varies  significantly  between 
different macroalgae species, ranging from 5% to 47% dry weight, with red seaweed 
generally having a higher protein content than brown or green seaweed (31). The fat 
content is usually no more than 5%, while carbohydrates make up 20 to 76% of the 
total  composition.  Most  of  the  carbohydrates  in  seaweeds  are  dietary  fibre,  which 
account for about 33 to 62% of the dry matter (32). 

While  Table  3  presents  data  for  protein,  lipids,  and  carbohydrates  with  only  few 
examples, a more comprehensive table can be found in Annex I (Table 16) which also 
highlights  the  significant  variability  in  nutrients  composition,  even  within  the  same 
species.  

Aside  from these major nutrients, there  are  many  other nutritional  components  that 
vary from species to species. These additional nutrients also make algae a valuable 

feed 

ingredient: 

(27) Ahmad, A., Hassan, S.W., Banat, F. (2022). An overview of microalgae biomass as a sustainable 
food  security  and  circular  economy,  Bioengineered,  13(4). 
aquaculture 
https://doi.org/10.1080/21655979.2022.2061148  
(28) Nagappan et al. (2021). Potential of microalgae as a sustainable feed ingredient for aquaculture, 
Journal of Biotechnology, 341. https://doi.org/10.1016/j.jbiotec.2021.09.003  
(29) Ahmad, A., Hassan, S.W., Banat, F. (2022). An overview of microalgae biomass as a sustainable 
food  security  and  circular  economy,  Bioengineered,  13(4). 
aquaculture 
https://doi.org/10.1080/21655979.2022.2061148 
(30) Mwendwa et al. (2023). Potential for Use of Seaweed as a Fish Feed Ingredient: A Review. Journal 
of Agricultural Science, 152(2). http://dx.doi.org/10.5539/jas.v15n2p96  
(31)  Morais  et  al.  (2020).  Seaweed  Potential  in  the  Animal  Feed:  A  review.  J.  Mar.  Sci.  Eng.,  8(8). 
https://doi.org/10.3390/jmse8080559  
(32) Mwendwa et al. (2023). Potential for Use of Seaweed as a Fish Feed Ingredient: A Review. Journal 
of Agricultural Science, 152(2). http://dx.doi.org/10.5539/jas.v15n2p96 

ingredient: 

feed 

31 

 
 
 
Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing fish-
based ingredients 
Annex to the Final Report 

ingredient  in  aquaculture  feed.  It  is  important  to  note  that  pigments,  vitamins  and 
bioactive substances contained in algae can be of great benefit to fish (33). 

Table 3 – Proximate composition of the selected microalgae and macroalgae species 
[% per dry matter] 

Algae species 

Protein 

Lipid 

Carbohydrate 

Chlorella sp. 

Schizochytrium sp. 

Nannochloropsis sp. 

Ulva lactuca 

Saccharina latissima 

Palmaria palmata 

52.0 

12.5 

33-44 

10-25 

6-6.3 

8-35 

7.5 

40.2 

22-31 

0.6-1.6 

0.5–1.1 

0.7–3 

24.3 

38.9 

8-14 

36-43 

52–61 

46–56 

Sources:  Chlorella  sp.  (34),  Schizochytrium  sp.  (35),  Nannochloropsis  sp.  (36),  Ulva  lactuca  (37),  Saccharina 
latissima (38), Palmaria palmata (39). 

Highly unsaturated fatty acids 

Microalgae 

The total lipid content of microalgae ranges usually from 20% to 70% of dry weight. 
Unlike  other  plant  sources,  algae  can  also  produce  highly  unsaturated  fatty  acids 

feed 

ingredient: 

(33) Ahmad, A., Hassan, S.W., Banat, F. (2022). An overview of microalgae biomass as a sustainable 
food  security  and  circular  economy,  Bioengineered,  13(4). 
aquaculture 
https://doi.org/10.1080/21655979.2022.2061148 
(34)  Shields,  R.,  &  Lupatsch,  I.  (2013).  "5  Algae  for  aquaculture  and  animal  feeds".  Microalgal 
Biotechnology:  Integration  and  Economy,  edited  by  Clemens  Posten  and  Christian  Walter,  Berlin, 
Boston: De Gruyter, pp. 79-100. https://doi.org/10.1515/9783110298321.79  
(35)  Shields,  R.,  &  Lupatsch,  I.  (2013).  "5  Algae  for  aquaculture  and  animal  feeds".  Microalgal 
Biotechnology:  Integration  and  Economy,  edited  by  Clemens  Posten  and  Christian  Walter,  Berlin, 
Boston: De Gruyter, pp. 79-100. https://doi.org/10.1515/9783110298321.79  
(36) Ahmad, A., Hassan, S.W., Banat, F. (2022). An overview of microalgae biomass as a sustainable 
food  security  and  circular  economy,  Bioengineered,  13(4). 
aquaculture 
https://doi.org/10.1080/21655979.2022.2061148 
(37)  Morais  et  al.  (2020).  Seaweed  Potential  in  the  Animal  Feed:  A  review.  J.  Mar.  Sci.  Eng.,  8(8). 
https://doi.org/10.3390/jmse8080559 
(38)  Morais  et  al.  (2020).  Seaweed  Potential  in  the  Animal  Feed:  A  review.  J.  Mar.  Sci.  Eng.,  8(8). 
https://doi.org/10.3390/jmse8080559 
(39)  Morais  et  al.  (2020).  Seaweed  Potential  in  the  Animal  Feed:  A  review.  J.  Mar.  Sci.  Eng.,  8(8). 
https://doi.org/10.3390/jmse8080559 

ingredient: 

feed 

32 

 
 
 
 
 
 
 
 
 
 
 
 
Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing fish-
based ingredients 
Annex to the Final Report 

(HUFAs), such as EPA and DHA (40). Depending on the species, the EPA and DHA 
content can range from 20% to up to 45% of the total fatty acids. Schizochytrium sp. 
is  an  example  of  algae  with  an  exceptionally  high  content  of  polyunsaturated  fatty 
acids (PUFA) (41;42). 

Macroalgae 

Macroalgae, commonly known as seaweeds, have a low lipid content, ranging from 
1% to 5% of their dry weight. A significant portion of these lipids consists of PUFAs, 
notably EPA (43). Certain red seaweed species can contain up to 48% EPA of  their 
total  fatty  acids.  Generally  brown  and  red  seaweeds  exhibit  higher  levels  of  EPA 
compared to green algae (44).  

The  following  table  presents  the  EPA  and  DHA  content  in  selected  micro-  and 
macroalgae species, as well as in fish species commonly used for the extraction of 
fish oil. It is important to note that EPA content can vary significantly between different 
species  of  Nannochloropsis (Table  4).  As  mentioned  previously,  the  composition  is 
influenced not only by species-specific traits but also  by various environmental and 
nutrient-related factors (45). 

Table 4 highlights the high level of EPA in Nannochloropsis sp. and the low content of 
EPA and DHA in the selected macroalgae species. Of the listed species, the only one 
containing high levels of DHA is Schizochytrium sp. Based on their fatty acid profiles, 
oils from the species could be particularly suitable as fish oil replacers in aquafeeds. 

feed 

ingredient: 

(40) Bature et al. (2022). Microalgae as feed ingredients and a potential source of competitive advantage 
in livestock production: A review. Livestock Science, 259. https://doi.org/10.1016/j.livsci.2022.104907  
(41) Ahmad, A., Hassan, S.W., Banat, F. (2022). An overview of microalgae biomass as a sustainable 
aquaculture 
food  security  and  circular  economy,  Bioengineered,  13(4). 
https://doi.org/10.1080/21655979.2022.2061148 
(42)  Yarnold  et  al.  (2019).  Microalgal  Aquafeeds  As  Part  of  a  Circular  Bioeconomy.  Trends  in  Plant 
Science, 24(10). https://doi.org/10.1016/j.tplants.2019.06.005 
(43) Mwendwa et al. (2023). Potential for Use of Seaweed as a Fish Feed Ingredient: A Review. Journal 
of Agricultural Science, 152(2). http://dx.doi.org/10.5539/jas.v15n2p96 
(44) Mwendwa et al. (2023). Potential for Use of Seaweed as a Fish Feed Ingredient: A Review. Journal 
of Agricultural Science, 152(2). http://dx.doi.org/10.5539/jas.v15n2p96 
(45) Ahmad, A., Hassan, S.W., Banat, F. (2022). An overview of microalgae biomass as a sustainable 
aquaculture 
food  security  and  circular  economy,  Bioengineered,  13(4). 
https://doi.org/10.1080/21655979.2022.2061148 

ingredient: 

feed 

33 

 
 
 
Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing fish-
based ingredients 
Annex to the Final Report 

Table 4 – EPA and DHA in selected fish species and algae [mg/g dry weight] 

Algae oil and fish oil 

EPA 

DHA 

Menhaden oil 

Anchovy oil 

Sardine oil 

8.5 

4.4 

10.3 

Nannochloropsis oceanica 

23 

Nannochloropsis oculata 

23.3 

Nannochloropsis limnetica 

28.1 

Nannochloropsis gaditana 

54.9 

Chlorella vulgaris  

1.47 

6.2 

15.4 

19.8 

/ 

/ 

/ 

0.2 

/ 

Schizochytrium sp.  

(Not  specified  per  dry 
weight) 

51-60.5 

Ulva sp. 

0.7-1.4 

/ 

Saccharina latissima 

0.17-1.09 

0.02-0.42 

Palmaria palmata 

8.3 

/ 

Sources:  Menhaden  oil  (46),  Anchovy  oil  (47),  Sardine  oil  (48),  Nannochloropsis  oceanica  (49),  Nannochloropsis 
oculate (50), Nannochloropsis limnetica (51), Nannochloropsis gaditana (52), Chlorella vulgaris (53), Schizochytrium 
sp. (54), Ulva sp. (55), Saccharina latissima (56), Palmaria palmata (57). 

of 

and 

fatty 

fatty 

Food 

acids. 

acids. 

Journal 

Composition 

(46) Watters, C.A. (2012). Nutrition Considerations in Aquaculture: the importance of omega-3 fatty acids 
in fish development and human health. Available here. 
(47) Mathieu-Resuge et al. (2023). Red muscle of small pelagic fishes’ fillets are high-quality sources of 
120. 
essential 
https://doi.org/10.1016/j.jfca.2023.105304  
(48) Mathieu-Resuge et al. (2023). Red muscle of small pelagic fishes’ fillets are high-quality sources of 
120. 
essential 
https://doi.org/10.1016/j.jfca.2023.105304 
(49) Zanella, L., Vianello, F. (2020). Microalgae of the genus Nannochloropsis: Chemical composition 
foods,  68. 
and 
https://doi.org/10.1016/j.jff.2020.103919  
(50) Zanella, L., Vianello, F. (2020). Microalgae of the genus Nannochloropsis: Chemical composition 
foods,  68. 
and 
https://doi.org/10.1016/j.jff.2020.103919 
(51) Zanella, L., Vianello, F. (2020). Microalgae of the genus Nannochloropsis: Chemical composition 
foods,  68. 
and 
https://doi.org/10.1016/j.jff.2020.103919 

for  human  nutrition. 

for  human  nutrition. 

for  human  nutrition. 

Composition 

Journal  of 

Journal  of 

Journal  of 

implications 

implications 

implications 

functional 

functional 

functional 

functional 

functional 

functional 

Analysis, 

Analysis, 

Journal 

Food 

and 

of 

34 

 
 
 
 
Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing fish-
based ingredients 
Annex to the Final Report 

Amino Acids 

Composed of amino acids, proteins are abundant in many microalgae species, with 
protein content reaching up to 60%. Some studies have reported even levels as high 
as 70% in specific species (58). In macroalgae, the protein content is lower and ranges 
from 5 to 47% dry weight of seaweed (59). 

Essential amino acid requirement for selected key European fish species is presented 
in the following table (Table 5). Additionally, the table outlines the content of essential 
amino  acids  in  selected  microalgae  and  macroalgae  species.  The  amino  acid 
composition of fishmeal is also provided for comparison. 

Of  the  selected  algae,  biomasses  from  Chlorella  vulgaris,  Nannochloropsis  sp., 
Schizochytrium sp., and protein concentrates from Saccharina latissima and Palmaria 
palmata  exhibit  an  amino  acid  profile  comparable  to  that  of  fishmeal  (see  Table  5). 
While these species may be good candidates for replacing fishmeal, it should be noted 
that certain varieties of Chlorella sp. and Nannochloropsis sp. also display a high total 
protein content, as shown in Table 3 (60;61). 

(52)  Paterson  et  al.  (2023).  Bioactivity  and  Digestibility  of  Microalgae  Tetraselmis  sp.  and 
Nannochloropsis  sp.  as  Basis  of  Their  Potential  as  Novel  Functional  Foods.  Nutrients,  15(2). 
https://doi.org/10.3390/nu15020477  
(53) Waqalevu et al. (2019). Enrichment effect on two Brachionus plicatilis sp. complex morphotypes fed 
three nutritional enrichment diets. http://dx.doi.org/10.11233/aquaculturesci.67.139  
(54)  Zeng  et  al.  (2010).  Development  of  a  Temperature  Shift  Strategy  for  Efficient  Docosahexaenoic 
Acid  Production by  a Marine Fungoid  Protist,  Schizochytrium sp. HX-308. Applied  Biochemistry and 
Biotechnology. 164(3). http://dx.doi.org/10.1007/s12010-010-9131-9  
(55) McCauley et al. (2018). Effects of nutrients and processing on the nutrionally important metabolites 
of Ulva sp. (Chlorophyta). Algal Research, 35. https://doi.org/10.1016/j.algal.2018.09.016  
(56) Marinho, G. S., Holdt, S. L., Jacobsen, C., & Angelidaki, I. (2015). Lipids and Composition of Fatty 
Acids of Saccharina latissima Cultivated Year-Round in Integrated Multi-Trophic Aquaculture. Marine 
Drugs, 13(7), 4357-4374. https://doi.org/10.3390/md13074357  
(57) van Ginneken, V. J., Helsper, J. P., de Visser, W., van Keulen, H., & Brandenburg, W. A. (2011). 
Polyunsaturated fatty acids in various macroalgal species from North Atlantic and tropical seas. Lipids 
in health and disease, 10, 104. https://doi.org/10.1186/1476-511X-10-104  
(58) Ahmad, A., Hassan, S.W., Banat, F. (2022). An overview of microalgae biomass as a sustainable 
aquaculture 
food  security  and  circular  economy,  Bioengineered,  13(4). 
https://doi.org/10.1080/21655979.2022.2061148 
(59)  Morais  et  al.  (2020).  Seaweed  Potential  in  the  Animal  Feed:  A  review.  J.  Mar.  Sci.  Eng.,  8(8). 
https://doi.org/10.3390/jmse8080559 
(60)  Shields,  R.,  &  Lupatsch,  I.  (2013).  "5  Algae  for  aquaculture  and  animal  feeds".  Microalgal 
Biotechnology:  Integration  and  Economy,  edited  by  Clemens  Posten  and  Christian  Walter,  Berlin, 
Boston: De Gruyter, pp. 79-100. https://doi.org/10.1515/9783110298321.79 
(61) Ahmad, A., Hassan, S.W., Banat, F. (2022). An overview of microalgae biomass as a sustainable 
aquaculture 
food  security  and  circular  economy,  Bioengineered,  13(4). 
https://doi.org/10.1080/21655979.2022.2061148 

ingredient: 

ingredient: 

feed 

feed 

35 

 
 
 
 
Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing fish-based ingredients 
Annex to the Final Report 

Table 5 – Amino acids in selected algae that are deemed essential for fish [g/100 g protein] 

Nr.  Algae and fishmeal  Arginine  Histidine 

Isoleucine  Leucine 

Lysine  Methionine 

Phenylala
nine 

Threonine  Tryptophan  Valine 

1 

2 

3 

4 

5 

6 

7 

8 

9 

Fishmeal 

5.8-6.4 

2-2.4 

3.7-4.5 

6.5-7.5 

6.9-7.7 

2.6-2.9 

3.3-3.9 

3.9-4.3 

0.9-1.2 

4.5-5.4 

Chlorella vulgaris 

Nannochloropsis 
oceanica 

Nannochloropsis 
granulata 

Nannochloropsis 
gaditana 

8 

5.7 

2.4 

1.7 

7.4 

2.3 

6.5 

2.0 

4.8 

4.2 

5.6 

4.9 

10.8 

7.1 

8.4 

5.9 

2.2 

2.2 

11.0 

8.5 

3.5 

9.9 

5.3 

2.3 

6 

5.0 

6.2 

5.3 

5.6 

5.0 

5.4 

5.2 

2.3 

 - 

2.8 

2.3 

7.9 

5.6 

7.1 

6.0 

Schizochytrium sp. 

7.81 

1.57 

3.52 

9.96 

5.79 

1.35 

5.27 

3.93 

3.93 

5.17 

Ulva capensis,  

U. lactuca, U. rigida 

3.3-4.6 

1.4-1.8 

3.1-3.7 

5.2-6.8 

3.7-4.2 

1.5-1.6 

3.3-4.0 

4.7-5 

 - 

5.6-6.3 

Saccharina 
whole biomass 

latissima, 

4.4 

0.6 

Saccharina latissima, 
protein concentrate 

5.7 

1.7 

4.1 

5.0 

7.0 

8.6 

4.3 

1.7 

5.2 

2.4 

3.8 

5.6 

4.8 

5.5 

1.6 

1.8 

5.3 

6.1 

10 

Saccharina latissima  

3.3-8.1 

0.3-1.2 

1.2-4.3 

5.3-12.9 

4.6-6.5 

2.3-6.0 

3.4-11.3 

2.4-4.3 

- 

2.2-6.4 

11 

Palmaria palmata,  
whole biomass 

12 

Palmaria palmata 

3.0 

6.3 

0.7 

1.6 

2.0 

3.8 

3.3 

6.1 

2.9 

5.8 

0.8 

1.7 

2.1 

4.2 

2.5 

4.8 

0.6 

1.2 

3.0 

6.1 

Sources: 1 (62), 2 (63), 3 (64), 4 (65), 5 (66), 6 (67), 7 (68), 8 (69), 9 (70), 10 (71), 11 (72),12 (73). 

36 

 
 
 
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Annex to the Final Report 

(62) FAO (n.d.). Fish meal.  
(63) Ru, I. T. K., Sung, Y. Y., Jusoh, M., Wahid, M. E. A., & Nagappan, T. (2020). Chlorella vulgaris: a perspective on its potential for combining high biomass 
with high value bioproducts. Applied Phycology, 1(1), 2–11. https://doi.org/10.1080/26388081.2020.1715256  
(64) Guo, X., et al. (2024). Comprehensive insights into microalgae proteins: Nutritional profiles and innovative applications as sustainable alternative proteins 
in health and food sciences, Food Hydrocolloids, 154. https://doi.org/10.1016/j.foodhyd.2024.110112  
(65) Tibbets et al. (2014). Chemical composition and nutritional properties of freshwater and marine microalgal biomass cultured in photobioreactors. Journal of 
Applied Phycology, 27(3). http://dx.doi.org/10.1007/s10811-014-0428-x  
(66) Qazi et al. (2021). Protein Enrichment of Wheat Bread with Microalgae:  Microchloropsis gaditana, Tetraselmis chui and Chlorella vulgaris.  Foods, 10(12). 
https://doi.org/10.3390/foods10123078  
(67) Cai et al. (2017). In Vitro Antioxidant Activities of Enzymatic Hydrolysate from Schizochytrium sp. and Its Hepatoprotective Effects on Acute Alcohol-Induced 
Liver Injury In Vivo. Mar. Drugs., 15(4). https://doi.org/10.3390/md15040115  
(68) Shuuluka, D. et al. (2012). Protein content, amino acid composition and nitrogen-to-protein conversion factors of Ulva rigida and Ulva capensis from natural 
populations and Ulva lactuca from an aquaculture system, in South Africa. Journal of Applied Phycology, 25(2). http://dx.doi.org/10.1007/s10811-012-9902-5  
(69) Krogdahl et al. (2021). Protein value and health aspects of the seaweeds Saccharina latissima and Palmaria palmata evaluated with mink as model for 
monogastric animals. Animal Feed Science and Technology, 276. https://doi.org/10.1016/j.anifeedsci.2021.114902  
(70) Krogdahl et al. Protein value and health aspects of the seaweeds Saccharina latissima and Palmaria palmata evaluated with mink as model for monogastric 
animals. Animal Feed Science and Technology, 276. https://doi.org/10.1016/j.anifeedsci.2021.114902 
(71) Marinho et al. Seasonal variations in the amino acid profile and protein nutritional value of Saccharina latissima cultivated in a commercial IMTA system. 
Journal of Applied Phycology. 27(5). http://dx.doi.org/10.1007/s10811-015-0546-0  
(72) Krogdahl et al. (2021). Protein value and health aspects of the seaweeds Saccharina latissima and Palmaria palmata evaluated with mink as model for 
monogastric animals. Animal Feed Science and Technology, 276. https://doi.org/10.1016/j.anifeedsci.2021.114902 
(73) Krogdahl et al. (2021). Protein value and health aspects of the seaweeds Saccharina latissima and Palmaria palmata evaluated with mink as model for 
monogastric animals. Animal Feed Science and Technology, 276. https://doi.org/10.1016/j.anifeedsci.2021.114902  

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Annex to the Final Report 

Vitamins and Minerals 

Microalgae 

The mineral content in microalgae ranges from 2.2% to 4.8% of dry matter. Microalgae 
contain  calcium,  potassium,  iron,  copper,  sodium,  sulphur,  zinc,  phosphorous,  and 
magnesium.  The  content  of  vitamins  in  microalgae  is  typically  high,  with  vitamin  E 
being  one  of  the  most  accumulated  vitamins (74).  Furthermore,  microalgae  such  as 
Spirulina  sp.  contain  a  higher  amount  of  vitamin  B12  than  plant-  or  animal-based 
foods (75).  

Macroalgae 

Macroalgae are rich in minerals, which they  primarily absorb from seawater. These 
minerals  can  constitute  up  to  36%  of  their  dry  matter.  Essential  minerals  such  as 
iodine,  calcium,  sodium,  selenium,  iron,  zinc,  potassium,  and  phosphorus  are 
commonly  found  in  macroalgae.  Notably,  brown  seaweeds  contain  higher  levels  of 
minerals  compared  to  red  seaweeds.  In  addition  to  minerals,  seaweeds  are  also 
sources of vitamins A, E, and C, as well as various B-group vitamins (76). 

The  substantial  vitamin  and  mineral  content  in  algae  underscore  their  potential  as 
alternatives to inorganic mineral salts in animal feed. However, challenges arise due 
to  significant  variations  in  vitamin  content,  which  are  influenced  by  factors  such  as 
species, growing season, culture conditions, and processing methods (77). 

Pigments 

Pigments in algae are especially relevant for the aquaculture industry as the aquafeed 
industry primarily  relies  on  synthetic  pigments  to  improve  flesh  and  skin  coloration. 
Algae-derived pigments, such as carotenoids (e.g. astaxanthin from Haematococcus 

(74) Nagappan et al. (2021). Potential of microalgae as a sustainable feed ingredient for aquaculture. 
Journal of Biotechnology, 342. https://doi.org/10.1016/j.jbiotec.2021.09.003  
(75) Ahmad, A., Hassan, S.W., Banat, F. (2022). An overview of microalgae biomass as a sustainable 
aquaculture 
food  security  and  circular  economy,  Bioengineered,  13(4). 
https://doi.org/10.1080/21655979.2022.2061148 
(76)  Morais  et  al.  (2020).  Seaweed  Potential  in  the  Animal  Feed:  A  review.  J.  Mar.  Sci.  Eng.,  8(8). 
https://doi.org/10.3390/jmse8080559 
(77) CEVA (2024). Report of the current algae industry in Europe. Available here. 

ingredient: 

feed 

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based ingredients 
Annex to the Final Report 

pluvialis),  offer  a  natural  alternative (78).  These  pigments  play  a  crucial  role  in 
enhancing fillet coloration in farmed fish like Atlantic salmon and rainbow trout, which 
is a key characteristic for market acceptance and consumer preference (79). 

Microalgae 

Carotenoids such as β-carotene, lutein, phycobiliproteins, fucoxanthin are important 
microalgal photosynthetic pigments (80). Certain pigments can enhance the quality and 
health  of  fish  due  to  their  colouring,  antioxidant  and  immunomodulatory  properties, 
making them valuable for aquaculture (81). The carotenoid pigment, astaxanthin, found 
in  certain  microalgae  is  key  to  imparting  the  sought-after  pink  and  orange  hues 
characteristic of market-size salmon fillet (82). 

Macroalgae 

Macroalgae  also  contain  valuable  pigments  and  are  commonly  classified  based  on 
their surface pigmentation into green, red, and brown seaweeds. The green colour in 
green  seaweeds  results  from  a  high  concentration  of  chlorophyll.  These  seaweeds 
also  contain  β-carotene  and  xanthophylls.  The  brown  colour  of  brown  seaweeds  is 
primarily due to their high content of fucoxanthin, a potent carotenoid that masks the 
green  chlorophyll  pigment.  The  red  colour  of  red  seaweeds  can  be  attributed  to 
phycobiliproteins  such  as  phycoerythrin  and  phycocyanin.  These  protein-based 
pigments contribute significantly to the higher protein content  found in red seaweed 
compared to brown and green seaweed (83). 

feed 

feed 

ingredient: 

(78) Ahmad, A., Hassan, S.W., Banat, F. (2022). An overview of microalgae biomass as a sustainable 
aquaculture 
food  security  and  circular  economy,  Bioengineered,  13(4). 
https://doi.org/10.1080/21655979.2022.2061148 
(79)  Morais  et  al.  (2020).  Seaweed  Potential  in  the  Animal  Feed:  A  review.  J.  Mar.  Sci.  Eng.,  8(8). 
https://doi.org/10.3390/jmse8080559 
(80) Ahmad, A., Hassan, S.W., Banat, F. (2022). An overview of microalgae biomass as a sustainable 
aquaculture 
food  security  and  circular  economy,  Bioengineered,  13(4). 
https://doi.org/10.1080/21655979.2022.2061148 
(81)  Yarnold  et  al.  (2019).  Microalgal  Aquafeeds  As  Part  of  a  Circular  Bioeconomy.  Trends  in  Plant 
Science, 24(10). https://doi.org/10.1016/j.tplants.2019.06.005 
(82) Ahmad, A., Hassan, S.W., Banat, F. (2022). An overview of microalgae biomass as a sustainable 
food  security  and  circular  economy,  Bioengineered,  13(4). 
aquaculture 
https://doi.org/10.1080/21655979.2022.2061148 
(83)  Morais  et  al.  (2020).  Seaweed  Potential  in  the  Animal  Feed:  A  review.  J.  Mar.  Sci.  Eng.,  8(8). 
https://doi.org/10.3390/jmse8080559 

ingredient: 

ingredient: 

feed 

39 

 
 
 
Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing fish-
based ingredients 
Annex to the Final Report 

Table 6 – Application summary for selected micro- and macroalgae as a replacement 
in aquafeed 

Organism 

Species 

Applications in aquafeed 

Microalgae 

Schizochytrium sp. 

DHA (+Protein) 

Nannochloropsis sp.  

EPA + Protein 

Chlorella sp. 

Protein 

(additionally, e.g. for 
bioactive compounds/ 
functional additives, 
such as pigments) 

Macroalgae 

Ulva sp. 

Saccharina latissima  

Palmaria palmata 

(not as a replacement for fishmeal or fish oil, 
but e.g. for bioactive compounds/functional 
additives, such as pigments) 

2.2.  Enhancing nutrient digestibility and bioavailability 

through optimal processing methods 

When evaluating the nutritional properties of feed ingredients, it is crucial to consider 
their  digestibility,  as  it  serves  as  a  key  indicator  of  their  nutritional  value.  The 
digestibility of nutrients in algae varies significantly among different fish species due 
to  their  distinct  digestive  capabilities (84).  Protein  digestibility  in  fishmeal  typically 
ranges between 70% and 92%. In comparison, the apparent digestibility coefficients 
(ADCs)  for  dry  matter  and  protein  in  Schizochytrium  sp.,  Chlorella  vulgaris, 
Nannochloropsis oceanica, and Nannochloropsis oculata can exceed 80% in rainbow 
trout and  European  seabass (85). These  digestibility  values may  vary  depending on 
the processing methods, algal species, and fish species.  

While the protein digestibility in some seaweed species can reach up to 88% (86), it 
has been concluded that fishes can digest microalgae generally more efficiently than 
macroalgae (87). For example, the protein digestibility of the seaweed species Ulva sp. 

feed 

ingredient: 

(84) Ahmad, A., Hassan, S.W., Banat, F. (2022). An overview of microalgae biomass as a sustainable 
aquaculture 
food  security  and  circular  economy,  Bioengineered,  13(4). 
https://doi.org/10.1080/21655979.2022.2061148 
(85)  Annamalai,  S.  N.,  Das,  P.,  Thaher,  M.  I.  A.,  et  al.  (2021).  Nutrients  and  Energy  Digestibility  of 
13211. 
Biomass 
Microalgal 
https://doi.org/10.3390/su132313211  
(86) Pereira et al. (2012). Apparent nutrient digestibility of seaweeds by rainbow trout (Oncorhynchus 
mykiss) 
1(1). 
https://doi.org/10.1016/j.algal.2012.04.002  
(87)  Annamalai,  S.  N.,  Das,  P.,  Thaher,  M.  I.  A.,  et  al.  (2021).  Nutrients  and  Energy  Digestibility  of 
Microalgal 
13211. 
Biomass 
https://doi.org/10.3390/su132313211  

Applications. Sustainability, 13(23), 

Applications. Sustainability, 13(23), 

(Oreochromis 

Research, 

niloticus). 

tilapia 

Feed 

Feed 

Algal 

Fish 

Fish 

Nile 

and 

for 

for 

40 

 
 
 
 
 
Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing fish-
based ingredients 
Annex to the Final Report 

was  reported  to  be  around  60%  in  rainbow  trout (88).  One  reason  for  the  generally 
lower protein digestibility of seaweeds is their high total phenolic content compared to 
microalgae (89). These antinutritional factors, when consumed in high amounts, can 
negatively  affect  fish  growth (90).  Other  antinutritional  factors  in  macroalgae  include 
lectins,  phytic  acid,  trypsin  inhibitors  and  amylase  inhibitors (91).  Microalgae  also 
contain  antinutritional  factors  such  as  phytic  acid  and  polyphenols.  Another  factor 
contributing to the reduced digestibility of nutrients in macroalgae and microalgae is 
the presence of complex polysaccharides, which are difficult to break down (92).  

None of the literature reviewed suggested specific solutions for effectively eliminating 
antinutritional factors in algae. However, Ahmad et al. (93) highlighted that a reduction 
in  these  components  has  been  achieved  in  other  protein  sources  through  pre-
treatments  such  as  extraction,  frying,  blanching,  or  soaking.  Given  that  several  of 
these treatments have proven effective for certain plant-based protein sources, it can 
be assumed that some may also have a beneficial effect on algae. Further research 
in this area would be valuable to enhance the digestibility and nutritional potential of 
algae. 

In general, microalgae with thick cell walls – such as Nannochloropsis or Chlorella – 
are more difficult for fish to digest than algae with thin or no cell walls (94). Several 
studies have found that physical and enzymatic processing of these algae are effective 
in  improving  the  nutrient  digestibility (95;96).  In  trials  with  Nannochloropsis  species, 
physical processing such as bead milling and cold pasteurisation, as well as extrusion 
and enzymatic processing, were found to significantly increase digestibility. Specific 

for 

and 

Nile 

Fish 

feed 

Algal 

Feed 

tilapia 

niloticus). 

Research, 

ingredient: 

(Oreochromis 

Applications. Sustainability, 13(23), 

(88) Pereira et al. (2012). Apparent nutrient digestibility of seaweeds by rainbow trout (Oncorhynchus 
mykiss) 
1(1). 
https://doi.org/10.1016/j.algal.2012.04.002 
(89)  Annamalai,  S.  N.,  Das,  P.,  Thaher,  M.  I.  A.,  et  al.  (2021).  Nutrients  and  Energy  Digestibility  of 
Microalgal 
13211. 
Biomass 
https://doi.org/10.3390/su132313211 
(90) Ahmad, A., Hassan, S.W., Banat, F. (2022). An overview of microalgae biomass as a sustainable 
food  security  and  circular  economy,  Bioengineered,  13(4). 
aquaculture 
https://doi.org/10.1080/21655979.2022.2061148 
(91) Nagappan et al. (2021). Potential of microalgae as a sustainable feed ingredient for aquaculture. 
Journal of Biotechnology, 342. https://doi.org/10.1016/j.jbiotec.2021.09.003 
(92) Nagappan et al. (2021). Potential of microalgae as a sustainable feed ingredient for aquaculture. 
Journal of Biotechnology, 342. https://doi.org/10.1016/j.jbiotec.2021.09.003 
(93) Ahmad, A., Hassan, S.W., Banat, F. (2022). An overview of microalgae biomass as a sustainable 
aquaculture 
food  security  and  circular  economy,  Bioengineered,  13(4). 
https://doi.org/10.1080/21655979.2022.2061148 
(94) Ahmad, A., Hassan, S.W., Banat, F. (2022). An overview of microalgae biomass as a sustainable 
aquaculture 
food  security  and  circular  economy,  Bioengineered,  13(4). 
https://doi.org/10.1080/21655979.2022.2061148 
(95) Nagappan et al. (2021). Potential of microalgae as a sustainable feed ingredient for aquaculture. 
Journal of Biotechnology, 342. https://doi.org/10.1016/j.jbiotec.2021.09.003 
(96)  Annamalai,  S.  N.,  Das,  P.,  Thaher,  M.  I.  A.,  et  al.  (2021).  Nutrients  and  Energy  Digestibility  of 
Microalgal 
13211. 
Biomass 
https://doi.org/10.3390/su132313211 

Applications. Sustainability, 13(23), 

ingredient: 

ingredient: 

Feed 

feed 

feed 

Fish 

for 

41 

 
 
 
Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing fish-
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Annex to the Final Report 

enzymatic treatment has also shown positive impacts on the digestibility of protein in 
Chlorella vulgaris (97).  

Several  studies  have  reported  high  digestibility  values  for  protein  and  DHA  in 
Schizochytrium whole algal biomass. In a digestibility study by Hart et. al. (98), Atlantic 
salmon  were  able  to  efficiently  digest  both  the  DHA  and  protein  contained  in 
Schizochytrium whole-cell biomass included in their diets. Unlike Nannochloropsis and 
Chlorella, Schizochytrium lacks a thick cellulose-based cell wall and contains relatively 
low  protein  content  (12.5%,  compared  to  44%  in  Nannochloropsis  and  52%  in 
Chlorella) (99).  The  digestibility  of  PUFAs  and  protein  in  the  whole  cell  biomass  of 
Schizochytrium  was  reported  to  be  94%  and  97%,  respectively (100).  Similarly,  high 
digestibility of these nutrients in Schizochytrium biomass has been observed in trout. 
Notably, a lower temperature of 8°C compared to 15°C resulted in an improved DHA 
digestibility (101).  

Schizochytrium sp.-derived algae oil has also been used as a replacement for fish oil 
in the diet of rainbow trout, with the authors reporting very high digestibility values – 
above  99%  for  both  EPA  and  DHA (102).  Additionally,  similarly  high  digestibility  of 
saturated fatty acids was observed when algae oil was used as a fish oil replacement 
in Atlantic salmon diets, even when algal cell walls were not disrupted prior to extrusion 
or vacuum coating of the pellets (103). 

The effectiveness of pre-treating algae can vary greatly between algae species, fish 
species,  and  other  factors.  Therefore,  providing  a  generalised  recommendation  for 
optimal  processing  would  be  misleading.  For  instance,  while  one  enzyme  may 
enhance digestibility for a specific algae species, another may have no effect on the 
same  species  or  on  a  different  fish  type.  Nevertheless,  although  the  overall 
digestibility  of  microalgae  is  comparable  to  that  of  fish-  and  plant-based 
ingredients,  many  studies  have  shown  that  cell  disruption  methods  can 

and  Enzymatic  Disruption.  Fermentation, 10(12), 

(97) Nagappan et al. (2021). Potential of microalgae as a sustainable feed ingredient for aquaculture. 
Journal of Biotechnology, 342. https://doi.org/10.1016/j.jbiotec.2021.09.003 
(98) Hart et al. (2021). Digestibility of Schizochytrium sp. whole cell biomass by Atlantic salmon (Salmo 
salar). https://doi.org/10.1016/j.aquaculture.2020.736156  
(99)    Shivakumar  et  al.  (2024).  Cell  Walls  of  Lipid-Rich  Microalgae:  A  Comprehensive  Review  on 
Characterisation,  Ultrastructure, 
608. 
https://doi.org/10.3390/fermentation10120608  
(100) Hart et al. (2021). Digestibility of Schizochytrium sp. whole cell biomass by Atlantic salmon (Salmo 
salar). https://doi.org/10.1016/j.aquaculture.2020.736156 
(101) Bélanger, A., Sarker, P. K., Bureau, D. P., Chouinard, Y., & Vandenberg, G. W. (2021). Apparent 
Digestibility of Macronutrients and Fatty Acids from Microalgae (Schizochytrium sp.) Fed to Rainbow 
Trout  (Oncorhynchus  mykiss):  A  Potential  Candidate  for  Fish  Oil  Substitution. Animals, 11(2),  456. 
https://doi.org/10.3390/ani11020456  
(102)  Santigosa  et  al.  (2020).  A  novel  marine  algal  oil  containing  both  EPA  and  DHA  is  an  effective 
source 
(Oncorhynchus  mykiss). 
http://dx.doi.org/10.1111/jwas.12699  
(103) Samuelson et al. (2024). Microalgae suspension as a source of n-3 long-chain PUFA in feed for 
Atlantic  Salmon  (Salmo  salar  L)  –  Technical  constraints  and  nutritional  quality.  Aquculture,  581. 
https://doi.org/10.1016/j.aquaculture.2023.740459  

omega‐3 

rainbow 

acids 

trout 

fatty 

for 

of 

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significantly improve digestibility – particularly in algae species with thick cell 
walls. In contrast, for algae oil or biomass derived from Schizochytrium sp., high 
digestibility  can  be  achieved  even  without  the  application  of  pre-treatment 
processes. 

2.3.  High potential algae ingredients candidates for the use 

in aquaculture feed 

In  Sections  2.1  and  2.2,  a  detailed  literature  review  was  conducted  on  six  algae 
species that were selected for their potential relevance in meeting the nutritional needs 
of the key European farmed fish species. The selected algal species are found to be 
beneficial  in  different  ways.  For  instance,  they  can  be  utilised  for  their  bioactive 
compounds, which can serve as additives in aquafeeds. Some of these algae have 
been identified as ideal substitutions for fish oil and fishmeal.  

For  the  replacement  of  fish  oil,  Schizochytrium  sp.  was  deemed  the  most  relevant 
species, as it is the only one among those examined in this report known for its high 
levels  of  DHA,  an  essential  fatty  acid  in  fish  diets.  However,  Schizochytrium  sp. 
typically produces little to no EPA, another fatty acid essential for marine fish species. 
Nevertheless, some studies have shown that it is possible to engineer Schizochytrium 
sp.  to  co-produce  EPA.  For  example,  in  the  study  by  Wang  Ma  et  al. (104),  the 
activation of a specific endogenous gene (MetE-like complex) and the use of mixed 
carbon sources led to an increase in the EPA production from 4.19 to 29.83 mg per g 
cell dry weight. 

However, there are other species that are richer in EPA, as discussed in Section 2.1.2. 
Therefore,  combining  Schizochytrium  sp.  with  other  EPA-rich  species  is  a  viable 
option in aquafeed formulations. An especially high content of EPA has been found in 
the  phototrophic  microalga  Nannochloropsis  sp.,  particularly  in  Nannochloropsis 
gaditana. 

For the replacement of fishmeal, Nannochloropsis sp. and Chlorella sp. have proven 
to  be  suitable  for  aquafeed  formulation,  depending  on  the  strain  selected.  While 
Schizochytrium sp. also has a favourable amino acid profile, it contains lower amounts 
of protein than the other two species. 

To produce algae as replacements for both fishmeal and fish oil, Schizochytrium 
sp.  and  Nannochloropsis  sp.  can  serve  as  complementary  sources: 

(104)  Ma,  W.,  Liu,  M.,  Zhang,  Z. et  al. (2022).  Efficient  co-production  of  EPA  and  DHA 
by Schizochytrium sp.  via  regulation  of 
the  polyketide  synthase  pathway. Commun  Biol,  5, 
https://doi.org/10.1038/s42003-022-04334-4  

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Schizochytrium primarily for the fish oil component, and the protein fractions of 
both species as substitutes for fishmeal. 

There may be other combinations or algae species not included in this  research, or 
even species that are yet to be explored. It is also important to consider that nutritional 
properties  can  vary  greatly  within  species,  depending  on  the  specific  strain  and  its 
growing conditions, as discussed in previous chapters. For example, should a high-
EPA-yielding Chlorella strain become available, a combination of Chlorella sp. and 
Schizochytrium  sp.  for  algae  meal  and  oil  production  could  also  hold 
considerable promise. 

2.3.1.  Availability,  scalability  and  reliability  of  these  species  to 

meet the demand of the aquaculture industry 

2.3.1.1.  The algae market: globally and in Europe 

Approximately 35.82 million tonnes of algae were produced in 2019, with more than 
97% of total production originating from Asia, and 99% of the produced algae being 
macroalgae (105). 

Europe  accounts  for  only  about  0.8%  of  global  algae  production.  In  2019,  287,390 
tonnes of algae were produced in Europe, the majority of which was macroalgae. Only 
around 1% of this total consisted of microalgae. Most of the microalgae companies 
were based in Spain, Germany, France, and Italy (106). 

In  2022,  it  was  estimated  that  approximately  130,000  tonnes  of  microalgae  (dry 
weight) were produced globally, with a market value of 2.6 billion euros. This figure 
including  cyanobacteria  and 
likely 
Labyrinthulomycetes, such as Schizochytrium sp. (107). 

types  of  microalgae,  also 

includes  all 

The  microalgae  products  marketed  in  Europe  were  estimated  at  6,266  tonnes  and 
valued at 918.2 million US$ in 2021. This is projected to reach 9,720 tonnes, with an 
estimated value of 1.6 billion US$ by 2031 (108). 

(105) Kuech, A., Breuer, M., Popescu, I., 2023, Research for PECH Committee – The future of the EU 
algae sector, European Parliament, Policy Department for Structural and Cohesion Policies, Brussels. 
Available here.  
(106) Kuech, A., Breuer, M., Popescu, I., 2023, Research for PECH Committee – The future of the EU 
algae sector, European Parliament, Policy Department for Structural and Cohesion Policies, Brussels 
Available here. 
(107) CEVA (2024). Report of the current algae industry in Europe. Available here. 
(108) Transparency Market Research (n.d.) Europe Microalgae Products Market. Available here. 

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In  2021,  the  global  market  for  algae  oils  accounted  for  approximately  2,034 
tonnes (109).  However,  depending  on  the  source  used,  these  estimates  can  vary 
greatly. Glencross et al. estimated that algal oils contributed already for approximately 
12,000 tonnes of EPA and DHA globally in 2023 (110). 

2.3.1.2.  Selected microalgae species 

Nannochloropsis  sp.  is  an  autotrophic  species,  using  light  and  CO2  to  grow.  In 
Europe, it is mainly produced in photobioreactors (111). 

Approximately  73%  of  global  Nannochloropsis  production  is  used  in  the  aquafeed 
market.  This  species  is  primarily  utilised  in  hatcheries  due  to  its  nutritional  value, 
its  protein,  EPA,  and  pigment  content (112).  The  production  of 
particularly 
Nannochloropsis in the EU was estimated to be 21 tonnes in 2021, originating from 
25 companies. However, this production volume may be an underestimate, as other 
sources have suggested significantly higher figures (113). 

Looking ahead, a compound annual growth rate (CAGR) of 9.4% is projected for the 
global  Nannochloropsis  market  between  2024  and  2031,  reaching  122  tonnes  by 
2031, with an estimated market value of 14 million USD. The growing demand for algal 
protein is expected to be the primary driver of this growth. Europe is estimated to hold 
a 35.7% share of the total value of the Nannochloropsis market (114). 

As previously mentioned, Chlorella sp. also contains a large amount of protein and 
possesses a favourable protein composition. In 2020, its global production exceeded 
3,500  tonnes  annually.  Europe  contributes  approximately  82  tonnes  per  year, 
produced  by  30  companies,  with  most  of  it  used  for  food  and  feed  applications. 
Chlorella  can  be  produced 
in  photobioreactors,  open  pond  systems,  or 
fermenters (115).  

Schizochytrium sp. is cultivated heterotrophically, meaning it does not require light 
but  instead  uses  a  carbon  source  such  as  sugar  or  glycerol  for  growth (116).  This 

(109) CEVA (2024). Report of the current algae industry in Europe. Available here. 
(110)  Glencross,  B.  D.  et  al.  (2024).  Omega-3  Futures  in  Aquaculture:  Exploring  the  Supply  and 
Demands for Long-Chain Omega-3 Essential Fatty Acids by Aquaculture Species. Reviews in Fisheries 
Science & Aquaculture, 33(2), 167–216. https://doi.org/10.1080/23308249.2024.2388563  
(111) CEVA (2024). Report of the current algae industry in Europe. Available here. 
(112) Lawande & Bombe (2024). Nannochloropsis Market Size, Share, Forecast, & Trends Analysis by 
Form (Frozen, Liquid, Powder, Fresh Pastes), Application (Aquafeed, Extraction Companies)—Global 
Forecast to 2031. Available here. 
(113) CEVA (2024). Report of the current algae industry in Europe. Available here. 
(114) Lawande & Bombe (2024). Nannochloropsis Market Size, Share, Forecast, & Trends Analysis by 
Form (Frozen, Liquid, Powder, Fresh Pastes), Application (Aquafeed, Extraction Companies)—Global 
Forecast to 2031. Available here. 
(115) CEVA (2024). Report of the current algae industry in Europe. Available here.  
(116) Monterey Bay Aquarium (2023). Forage species feed a lot of marine life. Available here. 

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species has attracted significant interest in aquaculture since 2020. Although current 
production volumes are not publicly  available, commercial large-scale production of 
Schizochytrium sp. for algae oil extraction is already underway. For example, Corbion 
and  Veramaris  are 
from 
Schizochytrium  sp.  for  use  in  aquafeeds.  It  is  important  to  note  that  there  are  also 
other producers of this type of oil for aquaculture feed, with production facilities both 
within the EU and in other regions (117). 

two  well-known  producers,  supplying  oil  derived 

2.3.1.3.  Reliability 

in 

this 

report.  The  production  of 

The great strength of microalgae as a source of protein or oil to replace fish-based 
ingredients  lies  in  their  reliability.  Unlike  forage  fish  sourced  from  the  ocean, 
microalgae  are  typically  cultivated  in  controlled  environments,  offering  increased 
protection from external factors. This advantage has been frequently emphasised by 
various stakeholders during the consultations and applies to the microalgae species 
discussed 
the  autotrophic  microalgae 
Nannochloropsis sp. and Chlorella sp. is also possible in open ponds (for Chlorella, 
only  about  10%  in  Europe);  however,  in  Europe,  the  majority  is  produced  in 
photobioreactors (118). Schizochytrium sp. is typically produced in fermenters. These 
closed and controlled systems protect the product from environmental impacts.  This 
production method also significantly reduces exposure to harmful substances such as 
PCBs  and  dioxins,  ensuring  a  more  consistent  and  safer  product  for  consumption. 
This stands in stark contrast to forage fish used as sources for fishmeal and fish oil, 
which are exposed to contaminants in the ocean, leading to their accumulation over 
time, as detailed in Chapter 3.3 on contaminants. Furthermore, climatic events such 
as the El Niño Southern Oscillation affect the catchability of forage fish species (119). 
Such natural events can have a significant impact on the availability of fishmeal and 
fish oil, and subsequently on their prices, as illustrated in Chapter 7 of this report.  

2.4.  Conclusion  

The  increasing  interest  in  the  use  of  algal  ingredients  can  further  increase  their 
production  and  consequently  reduce  the  demand  for  fish  oil  and  fishmeal  in 
aquafeeds. While plant oils have helped reduce reliance on fish oil in recent years, 
they  do  not  offer  essential  omega-3  fatty  acids  like  EPA  and  DHA.  A  further 
replacement  of  the  remaining  fish-based  ingredients  with  plant-based  ingredients 
would  therefore  negatively  impact  the  nutritional  quality  of  farmed  fish.  In  contrast, 

(117) CEVA (2024). Report of the current algae industry in Europe. Available here. 
(118) CEVA (2024). Report of the current algae industry in Europe. Available here. 
(119) FAO (2024). The State of World Fisheries and Aquaculture 2024 – Blue Transformation in action. 
Rome, https://doi.org/10.4060/cd0683en 

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algae-based oils  offer a  more promising  alternative, as  they  naturally  contain high 
concentrations  of  these  vital  nutrients,  helping  maintain  both  fish  health  and  the 
nutritional value of aquaculture products. 

The microalgal sources include Nannochloropsis sp. and Schizochytrium sp. that can 
provide  high  levels  of  EPA  and  DHA,  respectively.  Additionally,  Chlorella  sp.  and 
Nannochloropsis sp. exhibit favourable amino acid profiles and a high protein content. 
Although  macroalgae  also  produce  protein  and  omega-3  fatty  acids,  the  overall 
composition  and  quantities  found  in  microalgae  make  them  the  preferred  source. 
Furthermore, both micro- and macroalgae offer valuable micronutrients and pigments, 
which can improve fish health and quality. 

To support the wider application of microalgae in aquafeeds, treating the algal biomass 
to  disrupt  cell  walls  –  using  mechanical  or  enzymatic  methods  –  can  increase 
bioaccessibility, and in turn improve the digestibility and bioavailability of nutrients for 
fish. However, the necessity of such treatments depends on the specific algae species; 
many can be used in feeds without any pre-processing. 

The algae ingredient market has experienced significant growth in recent years and is 
projected  to  continue  expanding.  The  nutritional  properties  of  algae  are  especially 
valuable as alternatives to fish-derived proteins and lipids. Since algae are typically 
produced  in  controlled  environments,  they  also  enhance  safety  and  reliability  as 
aquafeed ingredients. 

Thus, algae can serve as a suitable alternative to fish-based ingredients in aquafeeds. 

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3.  Benefits and challenges of algae-containing feed 

This section explores relevant aspects pertaining to the inclusion of algal ingredients 
in aquafeed, such as fish and feed performance, economic viability, and environmental 
implications. A comprehensive Multi-Criteria Analysis (MCA) is employed to compare 
these  aspects  across  different  categories  of  feed  –  those  containing  significant 
amounts  of  fish-,  algae-,  or  insect-based  ingredients.  The  MCA  is  based  on  an 
extensive review of scientific literature and insights gathered from interviews with 12 
different  organisations  across  the  value  chain.  This  comparative  analysis  aims  to 
explore the benefits and challenges associated with the use of algae in aquafeeds. 

Strategies to lower the current forage fish dependency ratio (FFDR), thereby reducing 
pressure on wild fish populations, are presented, along with approaches to minimise 
contaminant levels in aquafeeds. 

Building on the findings of the MCA, optimal inclusion levels of algal ingredients as a 
percentage of total feed were calculated, considering the specific feed compositions 
for different fish species. Furthermore, the establishment of minimum inclusion levels 
for essential fatty acids (EPA and DHA) sourced from non-fish origins was explored. 

For  each  of  these  aspects,  recommendations  are  developed  based  on  the  MCA 
outcomes, relevant scientific literature, and expert insights from industry stakeholders. 
These  findings  and  recommendations  were  further  validated  in  collaboration  with 
multiple organisations across the value chain. 

3.1.  Comparison  of  different  fish  feed  ingredients  and 

formulations (Multi-Criteria Analysis) 

This section outlines the MCA process conducted to assess the suitability of various 
fish  feed  formulations  and  ingredients  for  aquaculture  in  Europe.  The  MCA 
methodology  was  implemented  through  a  systematic  and  structured  approach, 
following eight distinct and sequential steps: 

1.  Definition of the objective and scope – the aim was to articulate the purpose 

of the MCA.  

2.  Identification of options to be analysed – a list of fish feeds, each containing 
specific  ingredients,  was  developed  to  be  assessed  in  the  analysis.  These 
options were selected to represent viable alternatives currently available on, or 
emerging in, the market. 

3.  Identification  of  criteria  –  the  goal  was  to  determine  the  key  criteria  to 
evaluate each option, considering environmental, economic, and performance-

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related  factors.  These  criteria  were  selected  to  reflect  the  priorities  and 
requirements of aquaculture stakeholders. 

4.  Identification  of  performance  of  each  option  against  criteria  –  this  step 
focused  on  assessing  how  each  fish  feed  option  performs  in  relation  to  the 
identified criteria. This step involved synthesising data from literature reviews 
and expert judgment. 

5.  Allocation  of  weights  to  criteria  –  this  step  was  included  to  capture  the 
relative  importance  of  each  criterion  based  on  stakeholder  priorities  and 
objectives. The weighting process ensures that the MCA reflects the trade-offs 
inherent in decision-making. 

6.  Development  of  the  decision  matrix  and  application  of  weights  to 
calculate  scores  –  the  aim  was  to  build  a  decision  matrix  where  the 
performance ratings of all options were combined with the assigned weights. 
This step enabled the calculation of an overall score for each fish feed option. 
7.  Sensitivity Analysis – the robustness of the results was tested by varying the 
weights  assigned  to  criteria  and  analysing  how  these  changes  affected  the 
ranking of the feed options. 

8.  Results and recommendations – the findings of the MCA were synthesised 

to identify the fish feed options that best align with WP1’s objectives. 

Each  of  the  steps  described  above  is  elaborated  upon  in  the  following  sections, 
detailing the methodology, data sources, and outputs at each stage of the process. 

3.1.1.  Definition of the objective and scope 

The first step in the MCA process involves clearly defining the objective and scope. 
This  step  lays  the  foundation  for  the  analysis  by  establishing  the  purpose  of  the 
assessment, the expected outputs, and the constraints that will shape the  research. 
In  this  report,  the  primary  objective  of  the  MCA  is  to  evaluate  the  performance  of 
various aquafeed types to support decision-making in the adoption of sustainable feed 
practices within European aquaculture. 

The  analysis  focused  specifically  on  key  European  fish  species  –  namely  Atlantic 
salmon,  rainbow  trout,  European  seabass,  and  gilthead  seabream.  While  these 
species  are  predominantly  carnivorous  and  share  similar  dietary  needs,  it  was 
considered necessary to distinguish between the salmonids (salmon and trout) and 
the  seabass  and  seabream  species.  This  distinction  was  made  because  these  two 
categories exhibit different biological, physiological, and environmental requirements, 
which  may  result  in  varying  responses  to  different feed  formulations.  As  for the  life 
stage of the fish considered in the MCA, the analysis focused solely on the grower 
stage of fish farming. This stage, in which fish are raised to market size, requires the 
largest  feed  input  and  has  the  most  significant  impact  on  aquaculture  outcomes. 
Regarding  the  inclusion  of  feed  ingredients,  when  sources  presented  multiple 

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inclusion levels for alternative feed types, only the formulation showing the best results 
was selected as the optimal composition for this research. 

3.1.2. 

Identification of feed options to be analysed 

The second step in the MCA process involves selecting the feed types (or options) to 
be analysed. These feed options represent the alternatives to be compared based on 
the predefined criteria. Four feed types were identified for detailed analysis: 

1.  “Standard”  feed  without  alternative  ingredients:  it  corresponds  to  the 
baseline option reflecting the most common feed formulation currently used in 
European aquaculture. This feed contains conventional ingredients, including 
fish oil and fishmeal, without any inclusion of alternative ingredients.  

Alternative feeds: 

2.  Algae-containing feed with fish oil and fishmeal: feed containing at least 3% 
microalgae, for example in the form of algae oil or algae meal, as well as fish 
oil and fishmeal. Algae oil or algae meal under this type of feed replaced only 
a portion of the fish oil or fishmeal included in the conventional feeds.  

3.  Algae-containing feed without fish oil or without fishmeal: feed containing 
at least 3% microalgae, but which differs from the previous category by entirely 
replacing either fish oil or fishmeal with other ingredients. While 3% of algal-
based  ingredients  is  the  minimum  inclusion  level  for  this  type,  the  full 
replacement of fishmeal or fish oil may have been achieved by combining algal 
and plant-based ingredients.  

4.  Insect-containing  feed:  this  feed  includes  a  significant  proportion  of  insect-
derived ingredients, primarily as a protein source. Unlike the algae-containing 
options, this category does not contain algal components and focuses on the 
potential of insects as a sustainable alternative to fishmeal. 

The algae-containing options (feeds #2 and #3) focused primarily on the microalgae 
species Schizochytrium sp., Nannochloropsis sp., and Chlorella sp., though literature 
covering additional microalgae species was also considered. For insect-based feeds, 
all insect species documented in aquaculture feeds were included in the analysis. 

Other  feed  types  –  such  as  those  based  solely  on  plant  ingredients,  macroalgae, 
yeast,  or  fungi  –  were  initially  reviewed.  However,  insufficient  data  prevented  their 
inclusion  in  the  MCA.  Similarly,  plant-based  feeds  that  excluded  both  fish  and 
alternative ingredients were evaluated during the preliminary research phase. Despite 
their  economic  advantages,  these  formulations  showed  significantly  lower  fish  and 
feed performance for the selected species and were therefore excluded from further 
consideration. 

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3.1.3. 

Identification of criteria 

The criteria used in this MCA were carefully selected to reflect a holistic evaluation of 
aquafeed  performance.  Each  category  represents  an  important  dimension  of  the 
overall  assessment,  and  the  specific  criteria  within  these  categories  were  chosen 
based on their relevance to the aquaculture sector and their measurable impact. The 
following criteria were chosen: 

1.  Fish and Feed Performance 

a.  Feed conversion ratio (FCR);  
b.  Specific growth rate (SGR);  
c.  Fish health; 
d.  Fish quality;  
e.  Contaminants. 

2.  Economic criteria 

a.  Production costs; 
b.  Retail price; 
c.  Price stability. 

3.  Environmental criteria 

a.  Impact from feed production; 
b.  Forage fish dependency ratio (FFDR). 

Each of these individual criteria is explained in detail in Annex III. 

3.1.4.  Performance of the four feed options against each set of 

criteria 

The  performance  of  the  four  feed  options  was  evaluated  using  a  comprehensive 
approach  that  integrated  both  primary  and  secondary  information  sources.  This 
included data from laboratory and industry-scale contexts, ensuring a robust and well-
rounded assessment. 

The analysis was based on two main sources of information: interviews with industry 
stakeholders,  and  an  extensive  literature  review.  The  literature  review  prioritised 
publications  from  the  past  six  years  but  also  incorporated  earlier  studies  where 
necessary to address data gaps. In total, 122 relevant sources were initially screened. 
Of these, 67 were reviewed in detail, and 27 were considered directly applicable to the 
MCA. A full list of these sources is available in Annex III, Section 9.9. The reviewed 
studies  included  data  from  both  experimental  trials  and  real-world  industry 
applications. To complement the literature review, twelve interviews were conducted 
with  a  range  of  stakeholders:  fish  producers,  feed  manufacturers,  algae  ingredient 
suppliers, and representatives from aquaculture associations. Among these, data from 
two fish producers and five feed manufacturers were deemed directly relevant to the 
analysis.  The  interviewees  represented  both  large  and  small  organisations  across 

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varied  geographical  regions,  with  a  focus  on  feeds  designed  for  Atlantic  salmon, 
rainbow trout, European seabass, and gilthead seabream. 

It  is  important  to  note  that  integrating  insights  from  both  interviews  and  literature 
introduces a level of variability, owing to differing methodologies, production contexts, 
and  operational  scales.  For  instance,  some  sources  reflect  large-scale  commercial 
operations,  while  others  derive  from  controlled  laboratory  experiments.  To  mitigate 
inconsistencies,  findings  were  validated  through  consultation  with  a  specialised 
working group focusing on algae-containing feeds. This validation ensured alignment 
between academic research and practical, real-world experience. 

The methodology for assessing feed performance involved synthesising data across 
sources  and  conducting  a  comparative  analysis.  Each  feed  type  was  evaluated 
against defined criteria, using quantitative metrics where available. In instances where 
quantitative data were lacking or inconsistent, qualitative insights were incorporated 
to contextualise and support the findings. 

The key findings of the literature review and interviews are presented below organised 
according to the three main criteria: Fish and Feed Performance, Economic Criteria, 
and Environmental Criteria. 

3.1.4.1. 

 Fish and Feed Performance 

Regarding the feed conversion ratio (FCR), the analysis found that the performance 
of the four feed types was broadly similar, with only Feed 3 – “algae-containing feed 
without fish oil or without fishmeal” – exhibiting slightly higher FCR values. Variations 
in FCR depended heavily on factors such as fish species, size, feed formulations, and 
the  experimental  setting,  whether  conducted  in  industry  or  laboratory  trials.  For 
instance, standard feeds for Atlantic salmon and rainbow trout weighing 400 grams or 
more yielded FCR values ranging from 1.0 to 1.3 (120;121), while feeds for seabream 
and seabass yielded FCR values between 1.5 and 1.7 (122;123). While some studies 
types  containing  algae-based 
indicated  a  higher  FCR 
ingredients (124) or insect substitutes (125) others reported lower FCRs under different 

for  alternative 

feed 

(120) AllerAqua (2025). Atlantic Salmon, Atlantic Flux, Grower Feed. Available here. 
(121) AllerAqua (2025). Rainbow Trout, Aller Gold, Grower Feed. Available here. 
(122) AllerAqua (2025). Sea bream, Ocean Pearl, Grower Feed. Available here. 
(123) AllerAqua (2025). Sea Bass – Europe, Ocean Blue, Grower Feed. Available here. 
(124) Scholz, B. (2021). Northern Icelandic marine microalgae as health promoting multi-functional feed 
protein  and 
-  A  whole  algae  concept. 
http://dx.doi.org/10.13140/RG.2.2.25481.98405  
(125) Reyes, M., Rodríguez, M., Montes, J. et al. (2020). Nutritional and Growth Effect of Insect Meal 
Inclusion 
16. 
https://doi.org/10.3390/fishes5020016  

for  Atlantic  salmon 

Feeds. Fishes, 5(2), 

(Dicentrarchuss 

(Salmo  salar) 

lipid  source 

Seabass 

labrax) 

on 

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conditions (126), underscoring the variability in results. Overall, most sources showed 
similar  FCR  values  when  comparing  conventional  feeds  to  algae-based  or  insect-
containing feeds  (127;128); however,  a  few studies  examining feeds  containing  plant-
based  ingredients  as  substitutes  to  fishmeal  or  fish  oil  showed  slightly  higher  FCR 
values (129;130). Nevertheless, most interviewees indicated that FCR values are similar 
across all types of feeds. 

Regarding specific growth rate (SGR), similar trends were observed, as noted for FCR. 
While some articles revealed a significant increase in growth rate for some alternative 
feed types compared to the standard feed (131;132), some other sources demonstrated 
adverse effects (133). However, other studies (134) showed that feeds that completely 
replaced fishmeal or fish oil resulted in slightly lower SGR, as observed for FCR. This 
was also indicated during the interviews, where a stakeholder mentioned that there is 
a  clear  correlation  between  lower  SGR  values  and  the  substitution  of  fish-based 
ingredients with plant-based ingredients.  On average, no feed type demonstrated a 
consistent advantage over others, although a correlation between FCR and SGR was 
noted  within  individual  studies,  meaning  that  studies  that  showed  that  feeds 
associated with improved FCR often showed corresponding improvements in SGR, 
and  vice  versa.  As  such,  all  alternative  feeds  exhibit  a  similar  SGR  with  the 
standard  feed,  apart  from  Feed  3  “algae-containing  feed  without  fish  oil  or 
without fishmeal” exhibiting slightly lower SGR values. 

In terms of most health parameters, algae-containing feeds demonstrated comparable 
performance  compared  to  standard  feeds,  with  slight  improvements  observed  in 

lipid  source 

for  Atlantic  salmon 

(126) Nagappan et al. (2021). Potential of microalgae as a sustainable feed ingredient for aquaculture. 
Journal of Biotechnology, 342. https://doi.org/10.1016/j.jbiotec.2021.09.003 
(127) Santigosa et al. (2023). Algal oil gives control of long-chain omega-3 levels in full-cycle production 
of Atlantic salmon, without detriment to zootechnical performance and sensory characteristics. Journal 
of the World Aquaculture Society, 54(4). https://doi.org/10.1111/jwas.12947  
(128) Samuelsen et al. (2024). Microalgae suspension as a source of n-3 long-chain PUFA in feed for 
Atlantic  Salmon  (Salmo  salar  L)  –  Technical  constraints  and  nutritional  quality,  Aquaculture,  581. 
https://doi.org/10.1016/j.aquaculture.2023.740459  
(129) Scholz, B. (2021). Northern Icelandic marine microalgae as health promoting multi-functional feed 
protein  and 
-  A  whole  algae  concept. 
http://dx.doi.org/10.13140/RG.2.2.25481.98405 
(130) Nagappan et al. (2021). Potential of microalgae as a sustainable feed ingredient for aquaculture. 
Journal of Biotechnology, 342. https://doi.org/10.1016/j.jbiotec.2021.09.003 
(131) Santigosa et al. (2023). Algal oil gives control of long-chain omega-3 levels in full-cycle production 
of Atlantic salmon, without detriment to zootechnical performance and sensory characteristics. Journal 
of the World Aquaculture Society, 54(4). https://doi.org/10.1111/jwas.12947 
(132) Biancarosa et al. (2019). Replacing fish meal with insect meal in the diet of Atlantic salmon (Salmo 
salar) does not impact the amount of contaminants in the feed and it lowers accumulation of arsenic in 
the fillet. Food Additives and Contaminants, 36. https://doi.org/10.1080/19440049.2019.1619938  
(133) Scholz, B. (2021). Northern Icelandic marine microalgae as health promoting multi-functional feed 
-  A  whole  algae  concept. 
protein  and 
http://dx.doi.org/10.13140/RG.2.2.25481.98405 
(134) Nagappan et al. (2021). Potential of microalgae as a sustainable feed ingredient for aquaculture. 
Journal of Biotechnology, 342. https://doi.org/10.1016/j.jbiotec.2021.09.003 

for  Atlantic  salmon 

(Salmo  salar) 

(Salmo  salar) 

lipid  source 

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immunological  response  (135) and  intestinal microbiota  (136). Insect-containing feeds 
showed  even  more  improvements  in  overall  fish  health  than  algae-containing 
feeds (137), particularly in terms of gut health (138) and disease resistance. Importantly, 
no significant adverse effects on fish health were observed for any of the alternative 
feed types. Therefore, it can be concluded that algae-containing feeds can enhance 
fish health while insect-containing feed may provide notable health benefits. 

All three alternative feed types demonstrated improvements in fillet quality compared 
to standard feeds, with improved EPA and DHA (139), enhanced phenotypic traits (140) 
and  increased  fillet  firmness  (interview  results).  Specific  algae-containing  feeds 
contributed  to  higher  omega-3  fatty  acid  content  in  fish,  boosting  their  nutritional 
value (141).  This  was  also  reflected  in  the  interviews,  where  many  stakeholders 
expressed positive views about fish quality, including better taste, pigmentation, and 
nutrient content in the fillets. This suggests that all alternative feeds enhance fish 
quality, with algae-containing feeds demonstrating better results compared to 
insect-containing feeds. 

Alternative  feed  types  outperformed  standard  feeds  with  respect  to  contaminants. 
Insect-containing  feeds  were  reported  to  contain  lower  levels  of  heavy  metals (142), 
while  algae-containing  feeds  exhibited  reduced  dioxin  concentrations (143).  These 
findings were corroborated through interviews and working group consultations, where 
stakeholders  consistently  linked  the  lower  contaminant  levels  to  the  controlled 
production environments in which both algae and insects are cultivated. In contrast, 
marine-sourced fishmeal and fish oil tend to accumulate contaminants such as dioxins 
and heavy metals from the ocean, making standard feeds more susceptible to such 
risks. Among the alternatives, insect-based feeds and algae-based feeds without 
fishmeal or fish oil showed the best performance in terms of contaminant reduction. 

lipid  source 

(Salmo  salar) 

for  Atlantic  salmon 

(135)  Eroldoğan  et  al.  (2022).  From  the  sea  to  aquafeed:  A  perspective  overview.  Reviews  in 
Aquaculture, 15(3). https://doi.org/10.1111/raq.12740  
(136) Scholz, B. (2021). Northern Icelandic marine microalgae as health promoting multi-functional feed 
protein  and 
-  A  whole  algae  concept. 
http://dx.doi.org/10.13140/RG.2.2.25481.98405 
(137) Belforti et al. (2015). Tenebrio Molitor Meal in Rainbow Trout (Oncorhynchus Mykiss) Diets: Effects 
on Animal Performance, Nutrient Digestibility  and Chemical Composition of Fillets. Italian Journal of 
Animal Science, 14(4). http://dx.doi.org/10.4081/ijas.2015.4170  
(138) Frontier Economics (2023). Delivering insect-based feed at scale. Available here. 
(139) Santigosa et al. (2023). Algal oil gives control of long-chain omega-3 levels in full-cycle production 
of Atlantic salmon, without detriment to zootechnical performance and sensory characteristics. Journal 
of the World Aquaculture Society, 54(4). https://doi.org/10.1111/jwas.12947  
(140)  Eroldoğan  et  al.  (2022).  From  the  sea  to  aquafeed:  A  perspective  overview.  Reviews  in 
Aquaculture, 15(3). https://doi.org/10.1111/raq.12740 
(141) Santigosa et al. (2023). Algal oil gives control of long-chain omega-3 levels in full-cycle production 
of Atlantic salmon, without detriment to zootechnical performance and sensory characteristics. Journal 
of the World Aquaculture Society, 54(4). https://doi.org/10.1111/jwas.12947 
(142) Frontier Economics (2023). Delivering insect-based feed at scale. Available here 
(143)  Santigosa,  E.,  Brambilla,  F.,  &  Milanese,  L.  (2021).  Microalgae  Oil  as  an  Effective  Alternative 
Source  of  EPA  and  DHA  for  Gilthead  Seabream  (Sparus  aurata)  Aquaculture. Animals, 11(4),  971. 
https://doi.org/10.3390/ani11040971  

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While algae-containing feeds that still include fishmeal or fish oil performed better 
than  standard  feed,  they  did  not  match  the  contaminant  profile  of  fully  fish-free 
formulations. 

Table 17 in the Annex presents the average levels of relevant contaminants in fish oils 
used to produce feeds in Norway. The results showed that the levels of contaminants 
in  the  tested  fish  oils  were  below  the  established  limits  set  by  the  World  Health 
Organisation  (WHO)  for  toxicants.  While  contaminant  levels  in  fish  oil  are  well 
documented, corresponding information on algae oil is yet to be published. 

3.1.4.2.  Economic criteria 

To  determine  the  economic  performance  of  standard  feed  and  the  three  other 
alternative feeds, the analysis relied primarily on insights from the industry interviews. 
Production  costs  encompass  the  cost  of  ingredient  production,  packaging  and 
distribution, as well as processing and formulation. The interviewees emphasised that 
the production costs of alternative feeds vary significantly, depending on the quality of 
the  feed  produced.  The  cost  of  producing  ingredients  alone  can  vary  greatly.  For 
example,  algae-containing  feed  costs  ranged  from  €0.62/kg  for  low-cost  production 
methods  to €5.00/kg for higher-cost  methods (144).  During  the  industry  interviews,  it 
was mentioned that adding a significant number of algae to a standard feed generally 
results in a 10% increase in production costs. A price increase of 10 to 20% can be 
expected  for  insect-containing  feeds.  Plant-based  replacements,  however,  can  be 
approximately 10% cheaper than standard feeds, and their inclusion could offset the 
higher costs of algae-based ingredients. The price of fish oil is highly volatile, as shown 
in  Chapter  7  of  this  report.  Therefore,  the  production  costs  of  algae-containing 
feed with fish oil and fishmeal, as well as insect-containing feed, can be higher 
than that of standard feed. In contrast, the production costs of algae-containing 
feed without fish oil or without fishmeal are considered comparable to standard 
feed, as the inclusion of plant matter to replace fish ingredients could compensate for 
the higher costs associated with the algal ingredients.  

While the production costs vary among the four feed types, interviewees indicated that 
the  commercial  margin  will  mostly  remain  unchanged.  The  difference  between 
production costs and the retail selling price is estimated to be around 10 to 20%. For 
example, standard seabass and seabream feed was reported to cost approximately 
€1.35/kg,  while  insect-containing  feed  could  currently  be  sold  for about  €1.70/kg.  It 
should be noted that these estimations were given by two different interviewees, and 
differences in the quality of feeds should be expected. Therefore, the retail selling price 
criterion follows the same trend as the production costs across different feed types.  

(144) Nagappan et al. (2021). Potential of microalgae as a sustainable feed ingredient for aquaculture. 
Journal of Biotechnology, 342. https://doi.org/10.1016/j.jbiotec.2021.09.003  

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Price stability emerged as a distinct advantage for alternative feeds. Unlike standard 
feeds, which rely heavily on fishmeal and fish oil and are subject to significant price 
fluctuations, alternative feeds demonstrated more consistent pricing. Between 2011 
and  2023,  the  price  of  fish  oil  increased  by  181%,  while  fishmeal  prices  rose  by 
67% (145). The variations in the prices for these fish-based ingredients are described 
in more detail in Chapter 7. These fluctuations highlight the vulnerability of standard 
feeds to supply chain disruptions and climatic events. Alternative feeds, with reduced 
dependence on marine ingredients, offer greater stability in this regard. In years with 
very high prices for fish oil and fishmeal, the feed options with alternative ingredients 
as  a  replacement  for fish-based  ingredients may even  become  less  costly  than  the 
standard feed. As a result, the two algae-containing feeds offer a significant price 
stability  advantage  compared  to  the  standard  feed.  In  contrast,  the  insect-
containing  feed  offers  a  smaller  advantage,  as  insect  production  is  still  in  its 
infancy.  

3.1.4.3.  Environmental criteria 

The  environmental  impact  from  feed  production  encompasses  several  factors, 
including land use, freshwater consumption, and energy requirements associated with 
producing different types of feed. However, it is important to note that not all reviewed 
articles  considered  every  aspect  uniformly,  and  the  lack  of  a  standardised 
methodology  across  sources  resulted  in  varying  results.  This  inconsistency  is 
particularly evident in studies that assessed the environmental impact of alternative 
feeds in comparison to standard feed. Alternative feeds, especially those containing 
algae,  often  demonstrate  a  worse  environmental  performance  than  standard  feeds 
when  CO2  emissions  are  evaluated  as  a  stand-alone  impact.  Nevertheless,  CO2 
emissions were not rated separately in this analysis, as they are typically incorporated 
in most LCAs. LCAs have shown that the environmental footprint of algae-containing 
feed varies significantly depending on production scale and methods. For instance, a 
review (146)  revealed  that  while  microalgae-containing  feeds  might  exhibit  a  much 
higher  carbon  footprint  than  fishmeal  when  produced  on  a  small  scale  (0.024  ha), 
large-scale  algae  production  (2.5  ha)  demonstrated  a  20-fold  reduction  in  carbon 
emissions compared to pilot-scale setups. Additionally, using circular approaches in 
algae feed production has been shown to enhance environmental performance. 

In contrast, insect-containing feeds show a generally favourable environmental profile. 
Studies  have  indicated  that due  to  the  climate  change  burdens  associated  with  the 
low-cost diet, insect proteins are comparable to, or even better than, crop-based fish 

(145) EUMOFA (2023). Fishmeal and Fish Oil. Available here. 
(146) Nagappan et al. (2021). Potential of microalgae as a sustainable feed ingredient for aquaculture. 
Journal of Biotechnology, 342. https://doi.org/10.1016/j.jbiotec.2021.09.003 

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insect 

fishmeal  protein.  Furthermore, 

feed  ingredients  currently  used  in  Norway (147).  For  instance,  three  out  of  the  four 
insect-based proteins analysed were found to rival the environmental performance of 
farming  offers  significant 
blue  whiting 
advantages over traditional livestock production, especially in terms of land and water 
resource usage (148). In addition,  insect  meal production  requires  only 32m² of  land 
per tonne of dry matter, and its global warming potential (GWP) is substantially lower 
than that of fishmeal, at 169kg CO2 equivalent per tonne (or 497kg CO2 equivalent, 
including  indirect  effects)  compared  to  an  average  of  1,400kg  CO2  equivalent  for 
fishmeal (149). The environmental impact of insect-containing feed is further reduced 
when  low-value  resources  or  organic  by-products  used  as  input  for  larvae  farming, 
particularly in terms of land use and water consumption. 

In summary, the two algae-containing feeds demonstrated a slight tendency toward 
higher  environmental  damage  (mostly  when  on  pilot  scale)  compared  to  standard 
feed, largely due to the greenhouse gas emissions associated with algae production, 
although  large-scale  and  circular  production  methods  can  mitigate  this  impact.  In 
contrast, insect-containing feed exhibited a slightly better environmental performance 
than standard feed, attributed to its lower land use and water footprint, as well as its 
lower global warming potential. 

In terms of the FFDR, which measures the reliance of aquaculture feed on wild-caught 
forage  fish,  all  feed  alternatives  constitute  a  better  alternative  than  standard  feed. 
Between 2010 and 2020, significant reductions in FFDR were observed, with values 
decreasing from 1.43 to 0.67 for salmonids and from 0.71 to 0.53 for marine finfish like 
seabass  and  seabream  (150). Replacing all  forage  fish used  in  feed with  alternative 
ingredients would ultimate reduce FFDR to zero. Among the feeds analysed, algae-
containing feed without fish oil or fishmeal performs the best, as it replaces the largest 
proportion of forage fish, effectively contributing to a substantial reduction in FFDR. 
The algae-containing feed with fish oil and fishmeal, as well as the insect-containing 
feed, also outperformed standard feed in this regard, as both can replace some forage 
fish. However, their contribution to reducing FFDR is less significant than that of the 
algae-containing feed without fish oil or fishmeal. In summary, the algae-containing 
feed without fish oil or fishmeal scores the highest in reducing FFDR, while the 
other two alternative feeds also contribute positively to FFDR reduction, though 
to a lesser extent than the former. 

(147) Modahl & Brekke (2022). Environmental performance of insect protein: a case of LCA results for 
fish feed produced in Norway. SN Applied Sciences, 4(6). http://dx.doi.org/10.1007/s42452-022-05065-
1  
(148) Modahl & Brekke (2022). Environmental performance of insect protein: a case of LCA results for 
fish feed produced in Norway. SN Applied Sciences, 4(6). http://dx.doi.org/10.1007/s42452-022-05065-
1 
(149)  Su,  M.,  Bastiaens,  L.,  Verspreet,  J.,  &  Hayes,  M.  (2023).  Applications  of  Microalgae  in  Foods, 
Pharma and Feeds and Their Use as Fertilizers and Biostimulants: Legislation and Regulatory Aspects 
for Consideration. Foods, 12(20), 3878. https://doi.org/10.3390/foods12203878  
(150) IFFO (n.d.). FFDR Data. 

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3.1.5.  Allocation of weights to criteria 

The allocation of weights to the selected criteria in this analysis was based on both 
stakeholder  input  and  the  fundamental  objectives  of  feed  performance,  economic 
feasibility,  and  environmental  sustainability.  Each  weight  reflects  the  relative 
importance of each criterion, which was derived from expert feedback collected during 
a  dedicated  workshop  involving  industry  stakeholders,  ensuring  that  the  assigned 
weights  align  with  the  perspective  of  aquaculture  professionals.  The  detailed 
explanation and reasoning for each criteria weighting can be found in Annex III. 

3.1.6.  Development of decision matrix 

The decision matrix was developed to compare the performance of four feed options 
against the identified criteria. Each feed option was evaluated qualitatively, with scores 
assigned to reflect their relative performance compared to the standard feed baseline. 

The  scoring  system  was  designed  to  capture  the  direction  of  change  rather  than 
absolute quantitative differences. Due to inconsistencies in available quantitative data, 
the analysis adopted a qualitative scoring approach, which categorised performance 
changes as follows: 

•  +1,5: Significantly better than baseline; 
•  +1: Better than baseline; 
•  +0,5: Slightly better than baseline; 
•  0: Similar to baseline; 
• 
• 
• 

-0,5: Slightly worse than baseline; 
-1: Worse than baseline; 
-1,5: Significantly worse than baseline. 

The  Standard  Feed  was  assigned  a  score  of  0  across  all  criteria,  serving  as  the 
reference point for comparison. The remaining feed options were evaluated relative to 
this baseline feed. 

As  can  be  seen  in  the  decision  matrix  below  (Table  7),  the  algae-containing  feed 
without fish oil or fishmeal demonstrated the most promising overall results. It 
excelled in economic and environmental criteria, with improved performance in terms 
of fish quality (+1) and contaminant levels (+1). Furthermore, it had the best economic 
performance  compared  to  the  other  feeds,  with  production  costs  and  retail  prices 
similar to the standard feed. In contrast, the other alternative feeds exhibited higher 
production costs and prices, while also offering price stability benefits. Regarding the 
environmental  impacts  of  the  algae-containing  feed  without  fish  oil  or  fishmeal,  the 
provided score (+1.5) was particularly high considering the low FFDR, demonstrating 
significant environmental benefits.  

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The insect-containing feed has also performed well compared to the other feeds. Its 
main advantages pertain to fish health (+0.5) and environmental performance (+0.5), 
where it outscored all other feeds. Its main disadvantage lies in the production costs 
(-1)  and  retail  price  (-1),  where  it  scored  worse  than  all  other  feeds,  including  the 
standard feed. 

While  the  insect-containing  feed  improves  fish  health  and  is  less  prone  to 
contaminants,  the  incorporation  of  insects  significantly  increases  production  costs, 
without offering strong price stability yet. Therefore, while the insect-containing feed 
brings significant benefits in terms of fish performance and the environment, its main 
drawback lies in the economic criteria. 

The algae-containing feed with fish oil and fishmeal performed comparably to 
the insect-containing feed. In terms of fish and feed performance criteria, it scored 
better  than  the  algae-containing  feed  without  fish  oil  or  fishmeal,  mainly  due  to  the 
slightly lower score the latter achieved in the FCR and SGR criteria.  

In  summary,  of  the  four  options,  algae-containing  feed  without  fish  oil  or  fishmeal 
demonstrated the most promising results compared to the other feed options. Algae-
containing  feed  with  fish  oil  and  fishmeal,  as  well  as  insect-containing  feed,  also 
performed well and better than the standard feed type without alternative ingredients. 
Overall, the results highlight several key trade-offs among the three main categories. 
While alternative feeds demonstrate significant biodiversity benefits (i.e., reducing the 
FFDR), they often face challenges related to production costs and retail price. 

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Table 7 – Decision matrix comparing all types of feed against three categories of criteria. 

Feed and fish performance criteria 

Economic criteria 

Environmental criteria 

Total 
score 

Weights 

30% 

15% 

25% 

20% 

10% 

35% 

30% 

35% 

50% 

50% 

Feeds 

FCR 

SGR 

Fish 
health 

Fish 
quality 

Conta-
minants 

Sub-
total 

Production 
costs 

Retail 
price 

Price 
stability 

Sub-
total 

Impact 
from feed 
production 

FFDR 

Sub-
total 

No. 

Score 

Score 

Score 

Score 

Score 

Score 

Score 

Score 

Score 

Score 

1 

Standard feed 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

2 

3 

Algae-containing feed 
with fish oil and fishmeal 

Algae-containing feed 
without fish oil or without 
fishmeal 

0.00 

0.00 

0.25 

1.00 

0.50 

0.31 

-0.50 

-0.50 

1.00 

0.03 

-0.50 

1.00 

0.25 

0.20 

-0.25 

-0.25 

0.25 

1.00 

1.00 

0.25 

0.00 

0.00 

1.00 

0.35 

-0.50 

1.50 

0.50 

0.37 

4 

Insect-containing feed 

0.00 

0.00 

0.50 

0.50 

1.00 

0.33 

-1.00 

-1.00 

0.50 

-0.48  0.50 

1.00 

0.75 

0.20 

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3.1.7.  Sensitivity analysis 

The  sensitivity  analysis  reveals  that  the  rankings  of  the  four  feeds  across  the 
different  weighting  scenarios  are  relatively  stable  for  the  best-  and  worst-
performing  feeds,  while  the  ranking  of  the  second  and  third  best  option  shifts 
depending on the emphasis placed on different criteria categories. 

Under the equal weighting scenario (top-left graph in Figure 3 below), the algae-
containing  feed  without  fish  oil  or  fishmeal  achieved  the  highest  score  and  is 
ranked  first.  The  insect-containing feed  secured  the  second place, followed  by 
the  algae-containing  feed  with  fish  oil  and  fishmeal  in  third  place,  while  the 
standard feed ranked last. This scenario balances the performance of all criteria 
equally, resulting in a straightforward representation of how each feed performs 
across  environmental,  economic,  and  fish  and  feed  performance  categories 
without bias toward any single category. 

In the fish and feed performance weighting scenario (top-right graph), where 
fish  and  feed  performance  criteria  were  weighted  at  50%  and  the  other  two 
categories were given 25% each, the overall ranking remains the same. However, 
the scores for all feeds improved in this scenario, except for the algae-containing 
feed without fish-oil or fishmeal. Notably, the algae-containing feed without fish 
oil or fishmeal retains its lead due to its consistently high performance across all 
categories. 

The  economic  weighting  scenario  assigns  50%  weight  to  economic  criteria, 
with  the  environmental  and  feed  performance  criteria  each  weighted  at  25%. 
While  in  this  scenario  the  algae-containing  feed  without  fish-oil  or  fishmeal 
remains  the  best  option,  the  algae-containing  feed  with  fish  oil  and  fishmeal 
advances to second place, overtaking the insect-containing feed by a significant 
margin. In fact, the score of the insect-containing feed drops significantly that it 
nearly  aligns  with  the  standard  feed.  This  shift  highlights  the  relatively  weak 
economic  performance  of  the  insect-containing  feed,  which  require  high 
production costs and commands a high retail price.  

Finally,  the  environmental  weighting  scenario  assigns  50%  weight  on 
environmental  criteria  and  25%  weight  on  the  other  two  categories  of  criteria. 
Here, the insect-containing feed achieved second position, overtaking the algae-
containing feed with fish oil and fishmeal. This highlights the strong environmental 
advantages,  such  as  lower  greenhouse  gas  emissions  and  resource  use.  The 
algae-containing  feed  without  fish  oil  or  fishmeal  remains  the  most  suitable 
option, supported by its positive environmental profile, particularly its significant 
contributing to reducing the FFDR.  

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Figure 3 – Performance of the feed options under four weighting scenarios 

The sensitivity analysis demonstrates the robustness of the algae-containing feed 
without  fish  oil  or  fishmeal  as  the  most  suitable  option  across  all  weighting 
scenarios. This analysis verifies the results of this MCA and provides a detailed 
trade-offs  between  competing  (environmental  and 
understanding  of 
economic)  sustainability  criteria,  assisting  the  identification  of  the  most 
appropriate feed in different contexts. 

the 

3.1.8.  MCA-based recommendations 

Based  on  the  findings  of  this  analysis,  algae-containing  feeds  show  great 
potential as a sustainable alternative to standard feeds, particularly in increasing 
fish quality, enhancing price stability, and reducing dependency on forage fish. 
their 
However,  several  challenges  should  be  addressed 
environmental and economic performance. More specifically, the environmental 
impact of algae-containing feeds is heavily influenced by the scale of production. 
Studies 
lower 
greenhouse  gas  emissions  compared  to  smaller-scale  installations (151),  with 
emissions  per  unit  decreasing  as  production  capacity  increases.  Therefore, 
investments in scaling up algae production facilities should be prioritised to 

farms  have  significantly 

larger-scale  algae 

to  optimise 

indicate 

that 

(151)  Nagappan  et  al.  (2021).  Potential  of  microalgae  as  a  sustainable  feed  ingredient  for 
aquaculture. Journal of Biotechnology, 342. https://doi.org/10.1016/j.jbiotec.2021.09.003 

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realise  these  environmental  benefits.  Especially  in  combination  with  research 
and  development  of  technologies  in  photobioreactors (152)  and  open-pond 
systems (153)  optimised  for  large-scale  production  can  further  enhance  the 
effectiveness and efficiency of algae farming and its environmental sustainability. 

In addition, integrating algae production into circular economy frameworks 
can  significantly  improve  environmental  performance (154).  For  example,  algae 
cultivation could utilise industrial by-products, such as CO2 from power plants or 
nutrients  from  water  used  in  food  production  systems,  reducing  resource 
consumption and emissions. Policymakers and the industry must encourage the 
development  of  algae  farms  that  leverage  these  synergies,  fostering  industrial 
symbiosis  with  the  view  to  minimising  environmental  impacts  and  reducing 
production costs by valorising waste or unused resources.  

There is also significant potential to improve the economic viability of algae 
cultivation through economies of scale. Algae-containing feeds are currently 
less economically viable than standard feeds due to their high production costs. 
However,  as  algae  production  scales  up,  costs  are  expected  to  decrease 
significantly  per unit  of  algae  produced  due  to  economies  of  scale (155). Public 
and private investments can accelerate this transition, making algae-containing 
feeds more competitive in the marketplace.  

An additional important factor that can enhance the use of algae-containing feeds 
in  aquaculture  is  fostering  consumer  awareness  and  market  demand. 
Educating  consumers about  the  benefits  of  algae-containing  feeds  could  drive 
demand for fish produced with these feeds and further enhance the growth of the 
aquaculture industry. Certifications or eco-labels showing the type of feed used 
for growing fish can help differentiate such products in the market.  

Finally, given the strong performance of insect-containing feeds, especially their 
low land and water footprint, supporting the development of insect-containing 
feeds as a complementary option to algae feeds could give rise to additional 
benefits. Diversifying feed alternatives ensures that the aquaculture industry can 
have multiple sustainable options to meet varying needs and conditions. 

(152) Razzak et al. (2024). Microalgae cultivation in photobioreactors: sustainable solutions for a 
greener future. Green Chemical Engineering, 5(4). https://doi.org/10.1016/j.gce.2023.10.004  
(153)  Qin  et  al.  (2023).  Biotechnologies  for  bulk  production  of  microalgal  biomass:  from  mass 
cultivation 
16, 
131.https://doi.org/10.1186/s13068-023-02382-4  
(154)  Greene  et  al.  (2022).  Transforming  the  future  of  marine  aquaculture:  a  circular  economy 
approach. Oceanography, 35(4). https://doi.org/10.5670/oceanog.2022.213  
(155)  Cai  et  al.  (2021).  Seaweeds  and  microalgae:  an  overview  for  unlocking  their  potential  in 
global aquaculture development. FAO. https://doi.org/10.4060/cb5670en  

acquisition. Biotechnol 

Biofuels, 

biomass 

dried 

to 

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3.2.  Forage fish dependency ratio (FFDR) 

3.2.1.  Understanding significance of the FFDR  

3.2.1.1.  Metrics 

for  assessing  marine 

ingredients 

for 

aquaculture 

Over the years, the aquaculture industry has developed several methodologies 
to assess the performance of marine ingredients in aquafeed. These tools allow 
the  demonstration  of  factors  such  as  impact,  effectiveness,  value  and 
sustainability (156). One of the most widely used indicators of production efficiency 
in aquaculture systems is the feed conversion rate (FCR), which is explained in 
Annex  III  Section  9.7  and  compared  for  several  feed  options  in  the  MCA  in 
Chapter 3.1 of this report.  

Another well-known metric is the Fish in: Fish out (FIFO) ratio, which indicates 
the  amount,  in  kilograms,  of  fish-based  ingredients  required  to  produce  one 
kilogram  of  farmed  fish.  Though  it  serves  as  a  very  simplified  environmental 
benchmark,  it  has  been  widely  criticised  for  its  limitations,  particularly  for  not 
distinguishing between wild-caught fish or by-products as input sources, which 
can lead to an inaccurate portrayal of environmental impact (157). To address the 
limitation  of  the  FIFO  method,  FFDR  was  developed.  While  its  formula  is  like 
FIFO, FFDR specifically accounts for fish-based ingredients from wild-caught fish 
used to produce one kilogram of farmed fish, excluding other sources such as 
fish-based by-products. 

In  contrast,  Life  Cycle  Assessment  (LCA)  takes  a  different  approach  and  is 
considered the most complex among the four methods described here. LCA was 
introduced  to  provide  a  more  holistic  approach  to  assess  environmental 
sustainability.  It  considers  factors  like  global  warming  potential  and  water use, 
amongst many other factors. 

For forage fish, the fuel consumption per tonne of catch is relatively low, primarily 
due to the efficient fishing methods that are employed (158). Some other aspects 
that are commonly considered in LCAs, such as the land  use, are also low for 
forage fish (159). Therefore, when conducting an LCA, the use of wild caught fish 
in feed can often be considered advantageous in an LCA calculation, especially 

(156) IFFO (2024). The Evolution of Sustainability metrics for marine ingredients. Available here. 
(157) IFFO (2024). The Evolution of Sustainability metrics for marine ingredients. Available here. 
(158) IFFO (2024). The Evolution of Sustainability metrics for marine ingredients. Available here. 
(159) Davis et al. (2021). Life cycle assessment of heterotrophic algae omega-3. Algal research, 
60. https://doi.org/10.1016/j.algal.2021.102494  

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when compared to other ingredients in feeds. As a result, the use of forage fish 
in some cases can (although depending on many factors) be considered more 
environmentally  friendly  in  terms  of  resource  efficiency  and  perform  better  in 
LCAs, in comparison to algae (160). However, in some LCAs, algae ingredients 
have shown to have a significantly lower climate change impact in comparison to 
fish-based ingredients (161;162). This demonstrates that algae have the potential 
to show better LCA results than forage fish, but it is strongly dependant on the 
specific production set-up as well as the scale of operations.  

It is also important to note that most of the currently available LCAs for aquafeed 
production were not conducted using standardised methodologies, an issue that 
is also highlighted in the MCA presented in Chapter 3.1.   

Furthermore,  LCAs  (specifically  those  that  were  analysed  for  the  MCA  in  this 
report) did not account for certain critical ecological aspects like biodiversity or 
ecosystem  preservation,  which 
in  most  LCAs. 
Unsustainable  exploitation  of  forage  fish  can  have  negative  impacts  on  the 
mentioned key components of marine ecosystems (163).  

is  often  a  shortcoming 

The FFDR is discussed in detail in the following sections. It  can be a valuable 
indicator  for  indirectly  assessing  potential  impacts  on  biodiversity,  overfishing, 
and ecosystem health in the context of aquaculture, but it assesses only a single 
dimension. While LCA and FFDR both have their limitations on their own, an 
efficient  strategy  to  provide  a  more  holistic  overview  could  involve  the 
combined use of FFDR and LCA. 

3.2.1.2.  Sustainability  considerations  regarding  the  FFDR 

and the use of forage fish 

FFDR  aims  to  provide  an  indication  of  environmental  impact.  However,  the 
Marine Ingredients Organisation (IFFO) argues that marine ingredients can also 
be sourced from well-managed fisheries  and therefore represent a sustainable 
resource for animal feeds. In this regard, they further assert that the assumptions 
regarding  the  environmental  impact  of  forage  fish  exploitation  are  often 
overstated or not universally valid (164).   

(160) However, it is often unclear whether fuel consumption is accounted for differently between 
bottom  trawling  and  gillnet  fishing  (which  differ  significantly),  and  whether  these  LCAs  include 
greenhouse  gas  emissions  from  manufacturing  fossil-based  plastic  fishing  gear  and  other 
materials, energy use onboard vessels, or the negative impacts on marine ecosystems. 
(161) Valenti et al. (2018). Indicators of sustainability to assess aquaculture systems. Ecological 
Indicators, 88. https://doi.org/10.1016/j.ecolind.2017.12.068  
(162) Davis et al. (2021). Life cycle assessment of heterotrophic algae omega-3. Algal Research 
(163) Marine Stewardship Council (n.d.). Overfishing. Available here.  
(164) IFFO (2024). The Evolution of Sustainability metrics for marine ingredients. Available here. 

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However, not all forage fish is obtained from well-managed fisheries. Aside from 
the factors commonly analysed in LCAs, exploiting forage fish can also lead to 
overfishing, which is a serious concern. It can cause major negative impacts on 
the wild marine environment and biodiversity, which play essential roles in terms 
of  climate,  clean  air,  water,  and  food.  According  to  the  Marine  Stewardship 
Council  (MSC),  as  of  2024,  more  than  37%  of  global  fish  stocks  are  already 
overfished (165). In 2021, such unsustainable stocks accounted for 23% of the 
total  wild  fish  catch  (166).  The  proportion  of  irresponsibly  sourced  forage  fish 
varies by region and species. Among the remaining fish stocks, most are already 
at  their  maximum  sustainable  limits  (see  Figure  4).  Additionally,  some  experts 
caution that certain fisheries may be ecologically overfished, even if they are not 
officially classified as such (167). 

Figure 4 – World’s marine fisheries stocks from 1975 to 2021 

Source: FAO estimates (168).  

While  the  use  of  wild  forage  fish  in  aquafeeds  can  be  sustainable  under 
responsible management, the current state of global fisheries highlights the need 
for  improved  practices  to  ensure  long-term  viability.  With  the  fed  aquaculture 
sector  expected  to  continue  growing  and  wild  fish  stocks  remaining  finite, 

(165) Marine Stewardship Council (n.d.). Overfishing. Available here. 
(166) FAO (2024). The State of World Fisheries and Aquaculture 2024 – Blue Transformation in 
action. Rome, https://doi.org/10.4060/cd0683en. 
(167) ASC (2023). ASC Salmon Standard Version 1.4. Available here. 
(168) FAO (2024). The State of World Fisheries and Aquaculture 2024 – Blue Transformation in 
action. Rome, https://doi.org/10.4060/cd0683en. 

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strategies  should  be  implemented  to  increase  the  use  of  sustainably  sourced 
alternative  ingredients.  This  approach  does  not  necessarily  require  total 
replacement,  but  rather  targeted  supplementation  in  aquafeeds  to  reduce  the 
reliance on unsustainably sourced fishmeal and fish oil. 

3.2.2.  Examples and FFDR calculation for a potential algal 

ingredient inclusion 

The formulas to calculate FFDR can be found in Annex II. It is important to note 
that  fishmeal  and  fish  oil  obtained  from  fishery  by-products  (e.g.  trimmings  or 
offal) are excluded from the FFDR equation. 

3.2.2.1.  The FFDR thresholds set by the ASC Standard 

The ASC Salmon Standard, designed for enhancing environmental sustainability 
and social responsibility, uses the FFDR to set thresholds for the use of wild fish 
in salmon aquaculture. Additionally, other requirements such as sourcing fish oil 
and meal from certified suppliers can help improve traceability and support the 
implementation of sustainable practices (169). 

Aside from calculating the combined FFDR for fishmeal and oil, it is possible to 
calculate them individually as FFDRm (Fishmeal forage fish dependency ratio) 
and  FFDRo  (Fish  oil  forage  fish  dependency  ratio),  providing  a  more  specific 
evaluation of the reliance on forage fish for each feed component (see Annex II). 
The threshold described in the ASC standard specifies that FFDRm must be less 
than 1.2, and FFDRo must be less than 2.52 or the feed must contain less than 
30g  of  EPA  and  DHA  combined  per  kg  feed,  specifically  derived  from  marine 
sources,  excluding  by-products.  With  this  requirement,  the  ASC  aims  to 
effectively  reduce  the  inclusion  of  fishmeal  and  fish  oil  in  salmon  feeds,  while 
encouraging  the  use  of  oil  and  meal  from  trimmings  and  offal  as  well  as  from 
alternative sources (170). However, average FFDRm and FFDRo levels of 0.5 and 
1.5 respectively in Norwegian salmon farming were calculated for 2020 by Aas et 
al. (171). Compared  to  these  average  values,  the  limits  set  by  ASC seem quite 
high. It is important to note that an ASC consultation report from 2022 stated that, 
“there  was  a  lot  of  concern  from  Environmental  NGOs  and  other stakeholders 
that  the  FFDR  values  have  not  been  revised,  particularly  for  salmon” (172).  In 

(169) ASC (2023). ASC Salmon Standard Version 1.4. Available here. 
(170) ASC (2023). ASC Salmon Standard Version 1.4. Available here. 
(171) Aas et al. (2022). Utilization of feed resources in the production of Atlantic salmon (Salmo 
Reports. 
Norway: 
salar) 
https://doi.org/10.1016/j.aqrep.2022.101316  
(172) Aas et al. (2022). Utilization of feed resources in the production of Atlantic salmon (Salmo 
salar) 
Reports. 
Norway: 
https://doi.org/10.1016/j.aqrep.2022.101316 

Aquaculture 

Aquaculture 

update 

update 

2020. 

2020. 

An 

An 

for 

for 

in 

in 

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correspondence  with  the  ASC,  it  was  communicated  that  the  feed  efficiency 
metrics, including FFDR, in the ASC programme are currently under review. New 
ASC feed efficiency metrics criteria and guidance are planned to be included in 
the new consolidated standard.  

Besides the ASC standard, the other reviewed certification standards currently 
do not specify explicit FFDR targets.  

3.2.2.2.  FFDR development and current values 

Figure 5 – FIFO and FFDR for salmonids and marine finfish from 2000 to 2020 

Salmonids

Marine Finfish

3

2.5

2

1.5

1

0.5

0

3

2.5

2

1.5

1

0.5

0

2000

2010

2020

2000

2010

2020

FIFO FFDR

FIFO FFDR

Source: Graphs constructed with the data points for 2000, 2010 and 2020 from IFFO (173). 

The two graphs above (Figure 5) illustrate the trends in FIFO and FFDR. From 
2000 to 2020, there was a large reduction in both FIFO and FFDR. 

The average FFDR in 2020 was as follows:  

•  Atlantic salmon: 0.68; 

•  Other salmonids (e.g. rainbow trout): 0.67;  

•  Marine finfish (e.g. European seabass and gilthead seabream): 

0.53 (174).  

In 2020, the eFCR, a key parameter in calculating FFDR, was 1.27 for salmonids 
and 0.86  for marine  finfish  (175). Using  these  values  in the  FFDR formula  (see 
Annex II), the average proportion of feed ingredients derived from forage fish in 

(173) IFFO (n.d.). FFDR Data. 
(174) IFFO (n.d.). FFDR Data. 
(175) IFFO (n.d.) eFCR Data. 

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2020 was estimated at approximately 14.5% for salmonids and 17% for marine 
finfish. 

3.2.2.3.  Calculation for a hypothetical inclusion of 5% algal 

ingredients 

A reduction of the FFDR to zero is technically possible by replacing fishmeal and 
fish  oil  with  alternative  ingredients  such  as  algae,  plant-based  sources,  and 
aquaculture by-products such as trimmings. Among these, algal ingredients offer 
a  promising  solution  due  to  their  rich  content  of  essential  fatty  acids  and  their 
potential to be sustainably produced. 

Industry experts and stakeholders estimate that the inclusion of algal ingredients 
in  aquafeeds  could  reach  approximately  5%  within  the  next  five  years.  The 
following calculation aims to estimate the impact on the FFDR of incorporating a 
total of 5% algal ingredients (including meal and oil) into the feed formulation. 

It  should  be  noted  that  algae-based  ingredients  are  already  being  used  to  a 
limited  extent  in  aquafeeds.  Estimating  the  average  current  inclusion  levels 
remains  challenging,  as  the  specific  feed  formulations  are  often  proprietary 
information. For this report, it is assumed that current aquafeeds contain on an 
average 1% algal ingredients.  

Furthermore, it should be noted that a direct comparison between algae oil and 
fish oil is not straightforward. An inclusion of 1% algae oil does not equate to 1% 
fish oil, primarily due to the higher concentration of EPA and DHA in algae oil. 
This makes algae oil a more efficient source of essential omega-3 fatty acids. The 
actual replacement potential depends on the concentration of these fatty acids, 
which can vary significantly between different algae oil products. In this report, it 
is assumed  that  the  inclusion of  an  additional 4%  algal ingredients  (a blend of 
algae  meal  and  oil  with  a  higher  proportion  of  algae  oil,  as  it  is  already  more 
commonly used, while algae meal is expected to take longer to be adopted) can 
lead to a reduction of 6% fish-based ingredients.  

Given that approximately 76% of marine ingredients currently come from forage 
fish (percentage based on  Figure  6 on inclusion rates, numbers for Norwegian 
salmon farming, 2020) a 6% reduction in marine ingredients would correspond to 
an estimated 4.6% decrease in forage fish use in feed. This reduction would result 
in  a  total  forage  fish  ingredient  inclusion  of  9.9%  for  salmonids  and  12.4%  for 
marine finfish.  

The changes in the FCR (eFCR) when compared to feed without algae, were not 
found to be significant (see MCA Table 7). Therefore, for the FFDR calculation, 
the same average eFCR values are used. 

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Taking the previously mentioned assumptions into consideration, the FFDR for a 
feed containing 5% algal ingredients would be  0.46 for salmonids and  0.39 for 
marine  finfish  (see  calculation  in  the  Annex  II). This  level  of  substitution  would 
correspond to a reduction in the current (2020) FFDR of about 32% for salmonids 
and 26% for marine finfish. 

It  is important  to  note that these  calculations  are  based  on  many assumptions 
and  are  dependent  on  many  factors.  While  individual  values  may  differ,  this 
example shows that a significant reduction in FFDR can be achieved through 
the inclusion of algal ingredients. 

3.2.3.  Recommendations for adjusting the current FFDR 

The FFDR does not distinguish between sustainably harvested forage fish, and 
forage  fish  from  overfished  fisheries,  and  currently  approximately  37%  of  the 
forage fish stocks are overfished (176). The FFDR reflects pressure on forage fish 
stocks and can be a valuable indirect indication for the impact on biodiversity loss 
or ecosystem changes resulting from fishing activities. 

Inclusion of even small amounts of algal ingredients can significantly reduce the 
FFDR. This applies to algae oil, which is usually more concentrated in EPA and 
DHA than fish oil. The use of by-products or other alternative ingredients could 
further reduce the FFDR. 

While  it  is  not  recommended  to  solely  focus  on  achieving  a  low  FFDR,  other 
aspects such as the conditions of the forage fish stocks, or the sustainability of 
the catching methods should be taken  into consideration. Though certifications 
can be a helpful tool in this regard, the sustainability of fish-ingredients as well as 
those  of  their  replacements  should  be  assessed  in  a  standardised  and holistic 
manner, to achieve a robust assessment of the ingredients in question.  

Thus, an FFDR around the current average values (Atlantic salmon: 0.68, other 
salmonids: 0.67, marine finfish: 0.53 in 2020 (177)) should be considered as the 
baseline.  Additionally,  a  significantly  lower  FFDR  could  be  rewarded  with 
incentives  to  promote  the  use  of  by-products  and  alternative  ingredients.  It  is 
recommended  to  simultaneously  integrate  these  targets  with  other  indicators 
such as LCAs and certifications, which can provide a more holistic approach. As 
the aquaculture sector grows, the average FFDR values will decrease further as 
forage fish is a finite resource. Therefore, the targets should not be static but re-
evaluated and potentially lowered within regular time frames, for example every 
five years. 

(176) Marine Stewardship Council (n.d.). Overfishing. Available here. 
(177) IFFO (n.d.). FFDR Data.  

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It should be noted that this approach has been considered as realistic by most 
stakeholders  during  the  validation  process.  However,  it  was  suggested  that  it 
might be more effective to set targets specifically for FFDRo and FFDRm, rather 
than for the combined FFDR. In this case, the same considerations outlined for 
the  FFDR  would  apply,  but  with  respect  to  the  current  average  FFDRo  and 
FFDRm (1.5 and 0.5 respectively in 2020 for Norwegian salmon (178)). 

3.3.  Contaminants in fish and algae oil and application 
of  the  ‘as  low  as  reasonably  achievable’  (ALARA) 
principle for contaminants 

3.3.1.  Contaminant content in fish oil and algae oil destined 

for aquafeeds 

3.3.1.1.  Contaminants in meals and oils derived from fish and 

algae 

Contaminants in feed can impact human health, as they can accumulate in fish 
intended for human consumption. Fish-based ingredients, primarily derived from 
forage  fish,  can  contain  significant  levels  of  contaminants  originating  from  the 
ocean and bioaccumulated through the food chain. As avoiding contaminants in 
ocean  water  is  challenging,  ingredients  derived  from  alternative  sources  and 
produced in controlled environments generally contain lower levels of the harmful 
substances.  Microalgae  used  in  aquafeeds  are  typically  cultivated  in  closed 
facilities, which helps limit the introduction of contaminants. 

While heavy metal contamination can be a problem especially in fishmeal, this 
could also be a problem in marine grown seaweeds. For microalgae in controlled 
systems, and ingredients derived thereof, it is not mentioned as a common issue.  
For fish oil and algae oil, heavy metals are generally not a significant concern, 
according to the stakeholders interviewed. 

Other substances that require close monitoring are dioxins and PCBs, which are 
toxic  and  considered  persistent  organic  pollutants  found  in  the  environment. 
These  compounds  can  accumulate  in  the  food  chain  over  time,  especially  in 
animal  fat.  Dioxins  are  unintended  by-products  of  thermal  and  industrial 
processes,  while  PCBs  were  widely  used  in  various  industries  until  they  were 

(178) Aas et al. (2022). Utilization of feed resources in the production of Atlantic salmon (Salmo 
salar) 
Reports. 
Norway: 
https://doi.org/10.1016/j.aqrep.2022.101316 

Aquaculture 

update 

2020. 

An 

for 

in 

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banned in most countries by the 1980s. Long-term exposure to these substances 
can  harm  the  nervous,  immune  and  endocrine  systems,  impair  reproductive 
functions, and increase the risk of cancer (179). 

This section  focuses  on  strategies to minimise  contaminant  levels in  fish  feed, 
thereby reducing their levels in the final fish product and contributing to improved 
human health. 

3.3.1.2.  Dioxins and PCBs in fish oil 

Fish  oil  in  aquafeed  is  considered  the  primary  source  of  dioxins  and  PCBs  in 
farmed  fish,  as  it  accumulates  these  contaminants  while  growing  at  sea (180). 
Table 17 in Annex I presents contaminant levels in fish oil used as an ingredient 
in Norwegian salmon feed, which are well below the legal limits. The maximum 
allowed levels for dioxins and PCBs in selected animal feed products, as set by 
Directive  2002/32/EC,  are  listed  in  the  Annex  I  in  Table  18  of  this  report. 
Additionally,  action  thresholds  have  been  established  for  these  contaminants, 
and  if  they  are  found  to  be  exceeded,  an  investigation  by  Member  States  is 
prompted. These thresholds are detailed in Annex II of the same Directive. 

When comparing the maximum allowed contaminant levels for fish oil with those 
for other feed ingredients, it is notable that the limits for fish oil are significantly 
higher than those for plant-based ingredients. For example, the permitted level of 
dioxins in fish oil is more than six times higher  than in plant materials used for 
feed (5 ppt for fish oil vs. 0.75 ppt in plant materials), and for non-dioxin-like PCBs 
the difference is even greater; more than 17 times higher (20 ppt in fish oil vs. 1.5 
ppt in plant material). It should be noted that compound feed for fish (which often 
includes fish oil) is the only kind of compound livestock feed that is allowed to 
have higher thresholds for these contaminants.  

3.3.1.3.  Dioxins and PCBs in algae oil 

As algae oil is produced in controlled environments,  it generally contains much 
lower levels of contaminants (181). From the interviews conducted for this report 
as well as from literature studies it is evident that replacing fish oil with algae oils 
in  aquafeeds  can  significantly  reduce  the  levels of PCBs  and dioxins  in  feeds; 
these  improvements  are  marked  by  the  lower  levels  of  these  undesirable 
compounds in fish fillet. To illustrate this: a study found, that with the inclusion of 

Gilthead 

(179) EFSA (2025). Dioxins and PCBs. 
(180) Santigosa et al. (2021). Microalgae Oil as an Effective Alternative Source of EPA and DHA 
for 
11(4). 
https://doi.org/10.3390/ani11040971  
(181) On some occasions, contaminants may originate from input sources in algae cultivation, e.g. 
from used water, nutrients or from the crops that are used as sugar source for algae cultivation. 

Aquaculture. 

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(Sparus 

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either 3.5 or 7% algae oil, a teenager could safely consume approximately three 
times more microalgae oil-fed seabream compared to the fish oil-fed seabream 
(i.e., 680g with 3.5% algae oil or 735 g with 7% algae oil; while only consuming 
218g of fish fed with fish oil), considering the tolerable weekly intake of dioxins or 
dioxin-like PCBs recommended by the European Food and Safety Authority (182). 

3.3.2.  Processing 

techniques  and 

ingredient  sourcing 

options for reducing contaminants 

There  are  several  strategies  to  reduce  the  levels  of  dioxins  and  PCBs  in 
aquafeeds, which are crucial for minimising the accumulation of contaminants in 
the final fish product.  

Processing techniques: 

•  PCBs:  techniques  such  as  deodorisation  and  simple  packed  column 

stripping were found to be effective in removing PCBs (183); 

•  Dioxins  and  dioxin-like  PCBs:  a  combination  of  different 
decontamination  methods  has  proven  to  be  more  effective  in  reducing 
both,  dioxins  and  dioxin-like  PCBs,  in  aquafeed  ingredients  than  single 
treatment options.  For  instance,  the  combined use  of  deodorisation  and 
activated  carbon 
reduce 
contaminant levels without compromising the nutritional quality of the oil 
(184).  Similarly,  another  study  demonstrated 
that  counter  current 
supercritical  CO2  extraction  effectively  removes  dioxin-like  PCBs  and 
confirms  that  activated  carbon  treatment  is  particularly  efficient  in 
removing  dioxins (185).  These  findings  support  the  use  of  integrated 
decontamination strategies to enhance feed and food safety. 

treatment  was 

to  significantly 

found 

Ingredient sourcing 

The  levels  of  contaminants  in  forage  fish  commonly  used  to  produce  fishmeal 
and  oil,  such  as  herring  and  sprat,  varies  greatly  depending  on  geographical 

aurata) 

(Sparus 

Gilthead 

Seabream 

(182) Santigosa et al. (2021). Microalgae Oil as an Effective Alternative Source of EPA and DHA 
11(4). 
for 
https://doi.org/10.3390/ani11040971  
(183) Maes et al. (2010). Process optimization for the removal of environmental contaminants from 
fish oils, OCL, 17(2). https://doi.org/10.1051/ocl.2010.0298  
(184) Maes et al. (2010). Process optimization for the removal of environmental contaminants from 
fish oils, OCL, 17(2). https://doi.org/10.1051/ocl.2010.0298 
(185)  Kawashima  et  al.  (2009).  Removal  of  dioxins  and  dioxin-like  PCBs  from  fish  oil  by 
countercurrent supercritical CO2 extraction and activated carbon treatment. Chemosphere. 75(6). 
http://dx.doi.org/10.1016/j.chemosphere.2008.12.057  

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origin. In some regions, contaminant levels even exceed the established limits, 
with  notable  variations  occurring  even  within  sub-basins (186).  These  regional 
differences should be carefully considered when sourcing fish-based ingredients 
to avoid high contamination levels in aquafeeds.  

from 

Beyond reducing contaminants in fish oil through decontamination techniques or 
less  contaminated  regions,  partial  or  complete 
through  sourcing 
replacement  of  fish  oil  with  alternative  sources  is  also  a  viable  strategy.  For 
instance, in one study, salmon was initially fed a vegetable-oil-based diet for 55 
weeks,  followed  by  24  weeks  on  a  decontaminated  fish  oil-containing  diet  to 
restore omega-3 fatty acid levels. This approach resulted in a 52% reduction of 
dioxins and  furans,  as  well as  a  79%  reduction  in  the  dioxin-like  PCB  content, 
compared to fish fed a standard fish-oil-based diet (187). It should be noted that 
this  paper  did  not  focus  on  growth  and  health  performance  of  the  fish  and 
therefore further studies would be needed to validate this as a feeding strategy in 
salmon farming and identify bottlenecks to the methodology. One such bottleneck 
could be that gut health performance of carnivorous fish fed on vegetable-based 
diets may be worse than those fed on fish oil and meal-based diets which can 
have  a  negative  impact  on  growth  and  feed  conversion,  as  mentioned  in 
interviews with industry experts. This was not mentioned regarding algae-based 
diets. 

Evidence from interviews and reported literature indicate that replacing fish oil 
with  algae  oil,  or  a  combination  of  algae  and  plant  oils,  leads  to  a  significant 
reduction in PCBs and dioxins (188;189). As previously explored in this report, large 
portions of fish oil can be replaced with algae oil, which provides the essential 
omega-3 fatty acids while helping to lower contaminant levels in the feed. In a 
study where the total amount of fish oil was replaced with algae oil, a reduction 
of up to 70% in dioxins and furans and 79% in dioxin-like PCBs was noted (190), 
further confirming algae oil as a safer option in aquafeeds.  

Gilthead 

(186) HELCOM (2018). Polychlorinated biphenyls (PCBs), dioxins and furans. Available here. 
(187)  Bell  et  al.  (2012).  Complete  replacement  of  fish  oil  with  a  blend  of  vegetable  oils  affects 
dioxin, dioxin-like polychlorinated biphenyls (PCBs) and polybrominated diphenyl ethers (PBDEs) 
in  3  Atlantic  salmon  (Salmo  salar)  families  differing  in  flesh  adiposity,  Aquaculture  324-325. 
https://doi.org/10.1016/j.aquaculture.2011.11.004  
(188) Santigosa et al. (2021). Microalgae Oil as an Effective Alternative Source of EPA and DHA 
for 
11(4). 
https://doi.org/10.3390/ani11040971 
(189) Belanger-Lamonde et al. (2018). Algal and Vegetable Oils as Sustainable Fish Oil Substitutes 
in Rainbow Trout Diets: An Approach to Reduce Contaminant Exposure. Journal of Food Quality 
(1). https://doi.org/10.1155/2018/7949782  
(190) Zatti et al. (2023). Full replacement of fish oil with algae oil in farmed Atlantic salmon 
(Salmo salar) – Debottlenecking omega 3. Aquaculture. 574. 
https://doi.org/10.1016/j.aquaculture.2023.739653  

Aquaculture. 

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Animals, 

(Sparus 

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Together, these findings show that several practical and effective strategies exist 
for  reducing  or  avoiding  contaminants  in  aquafeeds,  while  still  maintaining  the 
nutritional value of the final product.  

3.3.3.  Recommendations  for  the  application  of  the  ALARA 

principle for contaminants 

ALARA in food and feed 

When  Regulation  2023/915  on  food  contaminants  was  first  established,  it 
emphasised  that  “In  the  case  of  a  possible  health  risk,  maximum  levels  for 
contaminants should be set at a level, which is as low as reasonably achievable 
(ALARA).  Such  an  approach  ensures  that  food  business  operators  apply 
measures  to  prevent  and  reduce  the  contamination  as  much  as  possible  to 
protect public health. This ALARA principle served as a key rationale for adopting 
the new regulation.  

While this Regulation specifically targets food contaminants, a similar paragraph 
relating to the ALARA-principle can be found in the Regulation (EC) No 183/2005 
Article 4 (2), which outlines requirements for feed hygiene: “When feeding food-
producing animals, farmers shall take measures and adopt procedures to keep 
the risk of biological, chemical and physical contamination of feed, animals and 
animal products as low as reasonably achievable.” 

However, the Hygiene Regulation applies the ALARA principle specifically to the 
feeding of food-producing animals and does not directly address the production 
of feed. 

Application of the ALARA-principle for feed contaminants 

It should be noted, that it was highlighted during consultations, that although the 
ALARA  principle  is  not  explicitly  mentioned  in  Directive  2002/32/EC  on 
undesirable  substances,  it  is  already  applied  in  practice  when  establishing 
maximum levels. 

However, in the examples in Table 17 in Annex I, the contamination levels in fish 
oil are significantly lower than the maximum limits  for dioxins, dioxin-like PCBs 
and non-dioxin-like PCBs listed in Table 18. Additionally, as outlined in Section 
3.3.2,  there  are  many  effective  techniques  and  sourcing  strategies  to  further 
reduce  contamination  levels  in  aquafeed.  Considering  this,  it  seems  that  the 
currently  existing maximum  levels  are  set  higher than  necessary and  primarily 
exclude only the most contaminated fish oil from the market. This approach does 
not align with the ALARA principle. 

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It  is  therefore  recommended  that  the  ALARA  principle  be  explicitly 
integrated  into  the  Directive  2002/32/EC,  particularly  in  relation  to  feed 
production, during its next evaluation. Doing so would strengthen efforts 
to  reduce  levels  of  PCBs,  dioxins  and  other  contaminants  in  feed,  and 
subsequently in food products derived from animals. 

Nearly all the stakeholders participating in the validation have confirmed that this 
recommendation seems realistic. 

Revision of contaminant limits for dioxins and PCBs in feed 

Furthermore,  a  re-evaluation  of  the  current  maximum  and  action  levels  for 
dioxins, dioxin-like PCBs and PCBs is strongly advised.  

Since  April  2012,  the  maximum  levels  for  these  contaminants  in  fish  oil  and 
aquafeeds  under  Directive  2002/32/EC  have  not  been  revised.  Over  the  past 
13 years, however, the composition of aquafeeds has changed drastically. The 
inclusion levels of fish oil in modern formulations are significantly lower than they 
were in 2012 (comparison Figure 2 in Chapter 2.1.1). Given that fish oil remains 
the  main  source  of  dioxins  and  PCBs,  the  permitted  limit  values  in  aquafeeds 
should have been lowered accordingly. 

It should be noted that during consultations it was mentioned that an amendment 
to Directive 2002/32/EC is close to finalisation, in which the maximum limits for 
dioxins  and  dioxin-like  PCBs 
lowered.  Furthermore,  a 
comprehensive review of the legislation on dioxins and PCBs in feed and food is 
foreseen in 2026, in which it is envisaged to further lower these limit values in 
feed and food. 

fish  oil  are 

in 

In recognition of the ongoing advancements in feed formulation and contaminant 
mitigation,  in  2023,  the  European  Commission  (EC)  notified    the  World  Trade 
Organisation (WTO) of its intention to lower certain limit values for dioxins and 
the sum of dioxins and dioxin-like PCBs. 

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Table 8 – Suggestions for the lowering of legal upper limits for dioxins and PCBs 
in fish oil and selected compound feed (Current value → suggestion) 

Feed or feed 
materials 

Dioxins (*1) 

Sum of dioxins and 
dioxin-like PCBs (*2) 

Maximum content  
in ng WHO-PCDD/F-
TEQ/kg (ppt) (*4) 
relative to a feed 
with a moisture 
content of 12% 

Maximum content  
in ng WHO PCDD/F-
PCB-TEQ/kg (ppt) 
(*4) relative to a feed 
with a moisture 
content of 12% 

Non-dioxin-like PCBs 
(*3) 

Maximum content   
in μg/kg (ppb) relative 
to a feed with a 
moisture content of 
12% (*5) 

Fish oil 

5.0 → 3.5 (notified by 
EC to the WTO) 

20.0 → 12.0 (notified by 
EC to the WTO) 

175 → lowering possible, 
not specified 

Compound feed  
for fish 

1.75 → 1.0 (notified by EC 
to the WTO) 

5.5 → 2.0 (notified by 
EC to the WTO) 

40 → lowering possible, 
not specified 

Details *1, *2, *3, *4, *5: see Table 18 (Annex I) 

Source: Current maximum values: Directive 2002/32EC (191); Suggested values: Notification of the EC to 
the WTO (192).  

Aside from this, the EC notified the WTO its intention to lower maximum levels 
for  other  high-fat  marine-derived  ingredients,  including  hydrolysed  fish  protein 
containing more than 20% fat and for crustacean meal (193). 

Additionally, the EC notified the lowering of the action threshold for dioxins from 
4.0  to  2.5ng  WHO-PCDD/F-TEQ/kg  in  fish  oil  and  from  1.25  to  0.75ng  WHO-
PCDD/F-TEQ/kg in compound feed for fish. For dioxin-like PCBs, the proposed 
reductions are from 11.0 to 8.0 ng WHO PCDD/F-PCB-TEQ/kg in fish oil and from 
2.5 to 1.25 ng WHO PCDD/F-PCB-TEQ/kg in compound fish feed (194). 

It should be noted that the proposal of specific values is not part of this work and 
should follow a comprehensive evaluation. However, the EC’s proposed limits for 
dioxins  and  the  combined  sum  of  dioxins  and  dioxin-like  PCBs  in  fish  oil  and 
compound fish feed (see Table 8) appear justified, given the substantial reduction 
in  fish  oil  inclusion  levels  in  modern  aquafeeds,  along  with  the  availability  of 
effective decontamination technologies and sourcing strategies. 

(191) “DIRECTIVE 2002/32/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 7 
May  2002  on  Undesirable  Substances  in  Animal  Feed,”  November  28,  2019,  https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:02002L0032-20191128. 
(192)  World  Trade  Organisation  Committee  on  Sanitary  and  Phytosanitary  Measures  (2023). 
Notification.  
(193)  World  Trade  Organisation  Committee  on  Sanitary  and  Phytosanitary  Measures  (2023). 
Notification. 
(194)  World  Trade  Organisation  Committee  on  Sanitary  and  Phytosanitary  Measures  (2023). 
Notification 

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Although the EC does not currently propose a recommendation for lowering the 
limits for non-dioxin-like PCBs, a reduction in these values, particularly in fish oil 
and compound fish feed also seems feasible for the mentioned reasons and could 
be considered. 

It  is  recommended  to  lower  the  current  legal  values  for  dioxins  and  the 
combined sum of dioxins and dioxin-like PCBs. In addition, the lowering of 
the values for non-dioxin-like PCBs in fish oil and in compound feed for fish 
could also be considered.  

Along with these proposed values, the current action thresholds for dioxins 
and  the  combined  sum  of  dioxins  and  dioxin-like  PCBs  should  also  be 
lowered as well. 

While the determination of the specific lower values lies under the responsibility 
of  the  relevant authorities,  it  was  confirmed during  the  validation  that  a  further 
lowering of the current maximum levels and action thresholds seems generally 
reasonable. 

3.3.4. 

Inclusion levels of algae 

3.3.4.1.  Optimal inclusion levels of algae 

A variety of inclusion levels for algae-based ingredients has been tested in the 
reviewed sources. Articles investigating very small amounts of algal ingredients, 
such as those used as additives, were excluded from the analysis as this report 
focuses  on  replacing  fish-based  ingredients.  Only  articles  investigating  a 
minimum of 3% algal inclusion were considered. 

Based on the interviews and after evaluating the literature sources, the overall 
results indicated that inclusion of 3% or more algal ingredients would maintain 
comparable  performance  in  terms  of  FCR  and  SGR.  While  algae-containing 
feeds  can  present  economic  challenges  and  certain  environmental  impacts, 
depending  on  the  production  setup,  they  also  offer  significant  advantages, 
including contaminant reduction, price stability and reduced pressure on wild fish 
stocks. The optimal inclusion level of algae in aquafeeds depends on balancing 
these factors against specific goals such as sustainability, fish quality, and market 
demands. Nonetheless, the performed MCA showed that the inclusion of at least 
3% of algal ingredients in feeds for salmonids (salmon and rainbow trout) as well 
as for seabass and seabream, has proven to be beneficial overall compared to 

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feeds without algae. Even a replacement of all fish oil (195) or fishmeal (196) (197) 
would be possible. This suggests that the current use of fish oil or fishmeal from 
forage  fish  could  be  eliminated,  considering  that  a  portion  of  the  fish  oil  and 
fishmeal already comes from more sustainable, circular approaches including the 
use of by-products, such as cut-offs (198). Therefore, the emphasis should be on 
incorporating  aquaculture  processing  by-products  along  with  algae-derived 
bioavailable ingredients.  

While  fish-based  ingredients  derived  from  by-products  are  generally  more 
sustainable than those sourced from forage fish, it is important to note that using 
forage  fish  for  feed  is  not  inherently  unsustainable.  The  sustainability  of  by-
products  also  depends  on  various  factors,  including  sourcing,  processing 
methods, and overall management practices. 

In 2020, Norwegian Atlantic salmon feed contained an average of 12.1% marine 
protein  and  10.3%  marine  oils.  Of  those,  8.8%  and  8.3%,  respectively,  were 
derived from forage fish (199). 

the 

World 

Journal 

Society, 

Aquaculture 

(195)  Santigosa  et  al.  (2023).  Algal  oil  gives  control  of  long-chain  omega-3  levels  in  full-cycle 
production  of  Atlantic  salmon,  without  detriment  to  zootechnical  performance  and  sensory 
54(4). 
of 
characteristics. 
https://doi.org/10.1111/jwas.12947 
(196)  Nagappan  et  al.  (2021).  Potential  of  microalgae  as  a  sustainable  feed  ingredient  for 
aquaculture. Journal of Biotechnology, 342. https://doi.org/10.1016/j.jbiotec.2021.09.003 
(197) Scholz, B. (2021). Northern Icelandic marine microalgae as health promoting multi-functional 
feed  protein  and  lipid  source  for  Atlantic  salmon  (Salmo  salar)  -  A  whole  algae  concept. 
http://dx.doi.org/10.13140/RG.2.2.25481.98405 
(198) Kreiss et al. (2020). Future Socio-Political Scenarios for Aquatic Resources in Europe: An 
7. 
Operationalized  Framework 
https://doi.org/10.3389/fmars.2020.568159  
(199) Aas et al. (2022). Utilization of feed resources in the production of Atlantic salmon (Salmo 
salar) 
Reports. 
Norway: 
https://doi.org/10.1016/j.aqrep.2022.101316 

for  Aquaculture  Projections.  Front.  Mar.  Sci., 

Aquaculture 

update 

2020. 

An 

for 

in 

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Figure 6 – Sources of marine ingredients in Norwegian salmon feed in 2020 

SOURCES OF MARINE INGREDIENTS IN 
SALMON FEED [%]

8.3

2.0

8.8

3.3

77.6

Fish oil from
forage fish

Fish oil from cut-
offs

Fish meal from
forage fish

Fish meal from
cut-offs

Other
ingredients

FISH OIL 
SOURCES [%]

FISH MEAL 
SOURCES [%]

19

81

Forage fish

Cut-offs

27

73

Forage fish

Cut-offs

Source: The charts are based on figures from Aas, Åsgård et al. (200). 
The two pie-charts on the right side indicate the proportions of cut-offs in the marine oil and marine protein 
sources employed in salmon feeds. 

If these 8.8% of fishmeal and 8.3% of fish oil obtained from forage fish could be 
replaced  by algae  meal and  oil,  the  remaining  parts could  be  covered  by  fish-
based  ingredients  obtained  from  cut-offs,  based  on  the  figures  from  2020  for 
Norwegian  salmon  feed.  Rainbow  trout  feeds  have  a  nutrient  composition 
comparable to that of salmon, specifically containing 13.4% fishmeal and 10.8% 
fish oil, with 9.5% and 8.4%, respectively from forage fish (201).  

As  shown  in  Figure  1  from  Chapter 2.1,  seabass  and  seabream  feeds  contain 
similar amounts of fish oil. Notably, the inclusion level of fishmeal is almost double 
that  of  the  salmonid  feeds,  which  have  evolved  over  the  years  by  upholding 
sustainability. It can be assumed that the aquafeed industry will gradually replace 
ingredients  from  forage  fish  with  cut-offs  and  alternative  ingredients.  The  fish-
based ingredients in the feed for these species would be replaced in proportional 
amounts.  That  would  result  in  a  replacement  of  approximately  8%  fish  oil  and 
18% fishmeal in the total feed formulation. 

It  is  important  to  note  that  during  interviews,  fish  and  feed  producers  have 
predicted that the use of algal oil could rise to as high as 5% within the next five 
years, while algal meal could reach an inclusion level of up to 3% in the same 
time frame.  

in 

(200) Aas et al. (2022). Utilization of feed resources in the production of Atlantic salmon (Salmo 
Reports. 
Norway: 
salar) 
https://doi.org/10.1016/j.aqrep.2022.101316  
(201) Aas et al. (2022). Utilization of feed resources in the production of Atlantic salmon (Salmo 
salar) 
Reports. 
Norway: 
https://doi.org/10.1016/j.aqrep.2022.101316  

Aquaculture 

Aquaculture 

update 

update 

2020. 

2020. 

An 

An 

for 

for 

in 

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In  the  long  run,  incorporating  corresponding  amounts  of  algal  ingredients  – 
estimated at 10-15% for salmon and trout and approximately 20-25% for seabass 
and  seabream  –  appears  both  feasible  and  promising  for  enhancing  the 
sustainability of future aquafeeds.  

Regarding  algae  oil,  it  is primarily valued  for its  EPA and  DHA. Given  that  the 
concentrations of these fatty acids can vary significantly among different algae 
oils,  EPA  and  DHA  levels  often  determine  the  appropriate  inclusion  levels  of 
algae oils in aquafeeds. Interviews with experts have revealed that replacing fish 
oil with algae oil is usually not done on a 1:1 basis, as the algae oil is often more 
concentrated in EPA and DHA. As a result, only small amounts of algae oil are 
needed  to  achieve  the  desired  nutritional  effect.  Specific  minimum  blend-in 
targets  for  non-fish-derived  EPA  and  DHA  will  be  discussed  in  the  following 
Chapter. 

3.3.5.  Recommendations  for  minimum  levels  of  EPA  and 

DHA from non-fish-sources in aquafeeds 

Commercially  available  EPA  and  DHA  are  primarily  derived  from  marine 
organisms. The aquafeed industry continues to rely heavily on these ingredients 
especially  in  feeds  formulated  for  farmed  marine  carnivorous  fish  and  shrimp.  
Although  ongoing  efforts  aim  to  identify  sustainable  alternatives  rich  in 
polyunsaturated  fatty  acids,  the  current  supply  remains  dominated  by  marine 
sources.  As  illustrated  in  the  figure  below,  whole  forage  fish  are  the  primary 
source of fish oil and fishmeal, accounting for approximately 85% (295 kilotonnes) 
of  the  EPA  and  DHA supply. In  contrast,  only 14%  (48  kilotonnes)  is obtained 
from by-products originating from seafood and aquaculture processing industries. 

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Figure 7 – Modelled global flows of EPA and DHA for fish oil and fishmeal 
production [kilotonnes] 

Source: Modified graphic from Brett D. Glencross et al. (2024) (202), which was based on Hamilton et al. 
(2020). 

FM = fishmeal; FO = fish oil. 

Establishing minimum levels for the inclusion of non-fish-derived EPA and DHA 
sources  in  aquafeeds  represents  a  crucial  first  step  towards  reducing 
dependency on wild fish for these essential nutrients. Over time, the contribution 
of  EPA  and  DHA  from  alternative  sources  in  aquafeeds  should  increase, 
potentially replacing, if not the entire amount, at least a significant share of what 
is currently supplied through wild-caught fish.  

A minimum blend-in target of 25% EPA and DHA from non-fish derived sources 
is recommended. During the validation process, all stakeholders confirmed 
that this appears to be realistic. As shown in Figure 2 from Chapter 2.1, oils 
from alternative sources already account for a significant share of the total 
oil  content  in  aquafeed.  During  the  validation  process,  stakeholders 
confirmed  that,  in  certain  cases,  such  inclusion  levels  are  already  being 
implemented.  In  fact,  some  leading  companies  in  the  salmon  farming 
industry  are  already  applying  a  minimum  of  30%  EPA  and  DHA  from 
alternative sources. While the recommended minimum target of 25% may 

(202) Brett et al. (2024). “Omega-3 Futures in Aquaculture: Exploring the Supply and Demands 
for Long-Chain Omega-3  Essential Fatty Acids by  Aquaculture  Species,”  Reviews in Fisheries 
Science 
1–50,  
https://doi.org/10.1080/23308249.2024.2388563.  

Aquaculture, 

September 

2024, 

& 

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seem like a modest target for companies that already incorporate algae into 
aquafeeds,  it  may  not  appear  like  this  for  those  who  are  yet  to  adopt 
alternative  sources.  A  balanced  consideration  of  all  parties  is  needed. 
Although  a  full  replacement  of  fish-derived  EPA  and  DHA  may  be 
technically  possible  with  algal  sources,  it  may  not  be  necessary,  as  by-
products  from  seafood  and  aquaculture  processing  remain  a  valuable 
supplementary source for these important fatty acids.  

The  current  limitations  associated  with  the  algae  sector  are  lower  production 
capacity and higher prices compared to traditional ingredients, thereby prohibiting 
a large-scale demand in the short term. However, from a nutritional perspective, 
algae rich in EPA and DHA are ideal replacements for fishmeal and fish oil. As 
demonstrated  in  the  MCA  presented  in  Section  3.1,  feeds  containing  algae 
perform comparable to, and in several respects even superior to traditional feeds. 
Benefits 
levels,  and  reduced 
include  price  stability, 
dependency on wild fish resources. 

lower  contaminant 

The content of EPA and DHA varies significantly between the different forage fish 
species, and even more markedly between algae species and strains, as shown 
in Table 4 of Chapter 2.1.2. Notably, the EPA and DHA content in specific algal 
strains  is  much  higher  than  in  fish.  Consequently,  the  amount  of  algae  oil 
required to achieve the same EPA and DHA levels as those observed in fish 
oil is comparatively lower. Based on the interviews conducted, it was estimated 
that  only two-thirds  of  the  amount  of  algae  oil  is  required  to  achieve  EPA  and 
DHA  levels  in  feeds  equivalent  to  those  obtained  from  fish  oil.  Upon  targeting 
25% of the required EPA and DHA from non-fish-derived sources such as algae 
oil,  a  feed  that  typically contains  12%  fish  oil could  be  reformulated  to  contain 
only 9% fish oil, supplemented with approximately 2% algae oil. However, more 
concentrated algae oil options are also available, allowing inclusion levels of 1.5% 
or lower to meet the requirements of farmed fish. 

Table 9 outlines the EPA and DHA requirements in gram per kilogram feed for 
key European farmed fish species at various development stages, along with the 
implications of a 25% inclusion from non-fish derived EPA and DHA. 

Although the initial minimum target of obtaining 25% of EPA and DHA in grower 
feeds from non-fish-derived sources appears achievable, it is important to note 
that  this  remains  only as  a  recommended  minimum  threshold.  This  minimum 
threshold should be re-evaluated as the market evolves. As evaluated in the 
MCA,  the  price  for  algae  oils  is  still  relatively  high,  which  can  be  a  hurdle  for 
increasing the threshold. Therefore, the recommendations in Chapter 4 regarding 
financial  incentives  should  be  considered  in  combination  with  these  targets. 
Moreover,  not  only  the  aquaculture  sector,  but  also  the  algae  oil  market  is 
projected  to  continue  growing,  thereby  enabling  higher  inclusion  rates  in  the 
future as availability increases and prices decline.  

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Table 9 – Indicative requirements for EPA, DHA, and EPA + DHA for selected 
species and suggested minimum target for replacement with non-fish derived 
EPA and DHA [g/kg diet] 

Species 

Fish weight 
(g)* 

EPA 

DHA 

EPA + 
DHA** 

Minimum target for 
non-fish derived 
EPA+DHA targets  
(25% replacement) 

Atlantic salmon  
(Salmo salar) 

European seabass 
(Dicentrarchus  
labrax) 

Gilthead seabream  
(Sparus aurata) 

< 0.5 

0.5-2 

2-5 

5-15 

15-50 

50-200 

200-500 

500-1000 

1000-2000 

2000-4000 

< 0.5 

0.5—2 

2-10 

10-50 

50-200 

200-500 

500-1000 

< 0.5 

0.5-2 

2-10 

10-50 

50-200 

200-500 

500-1000 

6 

7 

8 

9 

9 

9 

9 

9 

8 

7 

9 

8 

7 

6 

6 

5 

5 

7 

8 

9 

10 

10 

10 

10 

18 

15 

14 

12 

11 

9 

9 

9 

8 

7 

9 

8 

7 

6 

6 

5 

5 

14 

12 

10 

7 

5 

5 

5 

24 

22 

21 

20 

20 

18 

17 

17 

17 

15 

17 

16 

14 

12 

11 

10 

9 

20 

20 

19 

16 

15 

15 

15 

6.0 

5.5 

5.3 

5.0 

5.0 

4.5 

4.3 

4.3 

4.3 

3.8 

4.3 

4.0 

3.5 

3.0 

2.8 

2.5 

2.3 

5.0 

5.0 

4.8 

4.0 

3.8 

3.8 

3.8 

Rainbow trout 
(Oncorhynchus 
mykiss) 

The values for rainbow trout (also a salmonid) are expected to be similar to 
those listed for Atlantic salmon. 

*   Although individual categorisation may vary, the bold highlighted sizes in this list are typically considered the  
    grower stage by industry for these species.  
    (the bold highlighting was based on feed specifications from AllerAqua for grower stage feed) 
** EPA + DHA assumed to be at a ratio of 1:1 unless contrasting evidence was available the EPA and DHA  
    requirements were assumed to be equal to 50% each of the total EPA + DHA requirements. 

Source: Glencross et al. (2024) (203). 

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3.4.  Conclusion 

In  summary,  algae-containing  feeds  represent  a  compelling  alternative  to 
conventional aquafeeds. They offer several advantages, including enhanced fish 
quality  and  improved  price  stability.  Notably,  they  contribute  to  greater 
environmental  sustainability  by  reducing  reliance  on  forage  fish.  Even  minimal 
inclusion of algae can significantly lower the forage fish dependency ratio (FFDR), 
alleviating pressure on wild fish stocks, many of which are already overexploited 
or  at  capacity.  In  a  hypothetical  example  calculation,  5%  algal  inclusion  could 
reduce the FFDR by 32% (salmonids) and 26% (marine finfish) (see Annex II). 
Furthermore,  substituting  fish-based  ingredients  with  algae  can  lead  to  a 
meaningful reduction in harmful contaminants such as PCBs and dioxins. A full 
replacement of fish oil with algae has resulted in a 70% reduction in dioxins and 
furans and a 79% in dioxin-like PCBs (204). 

Currently,  the  elevated  cost  of  algae-based  feed  ingredients  remains  a  major 
barrier to widespread adoption. While prices of fish-based ingredients can vary 
greatly and prices for algae oil vary depending on their concentration, the total 
price of algae-containing feed is estimated to be approximately 10% higher  on 
average  in  comparison  to  feed  without  alternative  ingredients.  Additionally, 
ensuring  sustainable  production  of  algae  requires  further  advancement  in 
cultivation  and  processing  technologies.  The  MCA  included  in  this  report 
demonstrates that complete replacement of fish oil or fishmeal with substantial 
proportions  of  algal  components  is  both  technically  viable  and  beneficial. 
However, a more pragmatic and immediately implementable strategy may involve 
combining  algae-based  ingredients  with  sustainably  sourced  fishmeal  and  fish 
oil, particularly those derived from aquaculture by-products. 

Although  insect-based  feeds  also  present  advantages,  they  continue  to  face 
challenges  related  to  scalability,  cost  of  production,  and  price  volatility. 
Nonetheless,  supporting  the  development  of  insect-based  ingredients  –  as  a 
complement to algae – could broaden the range of sustainable feed options for 
the aquaculture sector. 

Encouraging  lower  FFDR  values  and  reviewing  current  maximum  limits  for 
contaminants such as PCBs and dioxins are important steps towards ensuring 
the  use  of  high-quality  ingredients  in  feeds.  Simultaneously,  setting  minimum 
targets for non-fish-derived EPA and DHA in aquafeeds could accelerate the shift 

(203) Glencross, B. D., Bachis, E., Betancor, M. B., Calder, P., Liland, N., Newton, R., & Ruyter, 
B. (2024). Omega-3 Futures in Aquaculture: Exploring the Supply and Demands for Long-Chain 
Omega-3  Essential  Fatty  Acids  by  Aquaculture  Species. Reviews  in  Fisheries  Science  & 
Aquaculture, 33(2), 167–216. https://doi.org/10.1080/23308249.2024.2388563  
(204) Zatti et al. (2023). “Full Replacement of Fish Oil with Algae Oil in Farmed Atlantic Salmon 
(Salmo 
574, 
– 
https://doi.org/10.1016/j.aquaculture.2023.739653  

Debottlenecking 

Aquaculture, 

Omega 

Salar) 

3.” 

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toward alternative  sources.  Algal ingredients  are  well-positioned  to  meet  these 
targets. The gradual integration of algae into aquafeeds will not only strengthen 
the algae market but also contribute to bridging the anticipated supply gap arising 
from continued growth in global aquaculture. 

The industry remains optimistic about reaching an inclusion rate of approximately 
5% for algae oil in aquafeeds within the next five years. While algal meal is not 
widely used in aquaculture yet, an inclusion of up to 3% could still be possible 
within  the  same  timeframe.  Given  their  potential  to  substitute  both  fish  oil  and 
fishmeal,  it  is  reasonable  to  anticipate  that  significantly  higher  inclusion  levels 
could be achieved over the longer term. If all currently utilised forage fish-based 
ingredients  were  to  be  replaced,  theoretical  inclusion  levels  could  reach 
approximately  10–15%  in  salmon  and  trout  feeds,  and  20–25%  in  feeds  for 
seabass  and  seabream.  The higher proportion  in  the  latter reflects  the  greater 
reliance on fish-based ingredients in their diets (see Figure 1 from Chapter 2.1). 
However, economic constraints are expected to considerably delay the timeline 
required to attain such high inclusion levels, particularly in the case of seabass 
and seabream. 

With  respect  to  essential  fatty  acids  –  particularly  EPA  and  DHA  –  it  appears 
feasible  to  supply  at  least  25%  of  the  total  dietary  requirement  from  non-fish-
derived sources. Depending on the species and production stage, this equates 
to approximately 2.3 to 4.5 grams of EPA+DHA per kilogram of grower feed for 
the  fish  species  considered.  It  should  also  be  noted  that  the  concentration  of 
omega-3 fatty acids in algae oil is typically much higher than that found in fish oil. 
This allows for the inclusion of small quantities of algae oil in feed formulations 
while still achieving the same nutritional benefits, resulting in more efficient use 
of space within the feed. It was estimated that fish oil can be replaced with algae 
oil in a ration of 3:2, but even higher concentrations are possible, according to 
the interviewed stakeholders. 

In conclusion, algal ingredients present substantial potential as alternatives to fish 
oil  and  fishmeal  in  aquafeeds,  offering  a  pathway  towards  more  sustainable 
aquaculture.  To  support  their  wider  adoption,  it  is  recommended  to  introduce 
measures  such  as  setting  minimum  targets  for  non-fish-derived  EPA+DHA, 
promoting  a  lower  Forage  Fish  Dependency  Ratio  (FFDR),  and  tightening  the 
permissible levels of contaminants in aquafeeds. These actions are both practical 
and essential to accelerating the integration of algal ingredients into aquaculture 
practices. 

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4.  Economic viability 

The economic viability of algae-containing feed is a critical factor influencing its 
adoption  in  the  aquaculture  sector.  The  economic  performance  of  algae-
containing  feed  compared  to  other  feed  options  was  analysed  in  the  MCA, 
particularly in Section 3.1.4.2. At present, the production of algae-containing feed 
is generally more costly than standard feed, typically leading to an increase of 
around 10% in overall production costs and price. As such, financial support is 
essential to enable the industry to scale up and improve competitiveness. Despite 
the higher upfront costs, algae-based feeds offer greater price stability compared 
to conventional feeds, which are subject to fluctuations in the fishmeal and fish 
oil  markets.  This  stability  reduces  exposure  to  supply  chain  disruptions  and 
sudden price spikes. Targeted financial support can help to close the cost gap, 
stimulate  innovation,  and  foster  a  more  sustainable  and  resilient  aquaculture 
sector by reducing reliance on marine-derived ingredients. 

Assessing the financial sustainability of this alternative feed source necessitates 
a comprehensive analysis of cost structures, financial incentives, and prevailing 
market conditions. This section evaluates the economic viability of algae-based 
feeds through the lens of financial incentives, acknowledging that the transition 
to  such  feeds  hinges  not  only  on  direct  cost-effectiveness  but  also  on  the 
availability of supportive funding mechanisms. 

The analysis begins by examining financial incentives employed in other primary 
production sectors, with a particular emphasis on agriculture. This offers valuable 
insights  into  established  policy  instruments  that  have  successfully  facilitated 
sustainability transitions, potentially providing useful lessons for the aquaculture 
sector.  The  section  then  proceeds  to  explore  financial  incentives  tailored 
specifically  to  aquaculture.  The  approach  first  considers  policy  commitments 
under the European Green Deal to determine what financial support frameworks 
align  with  sustainability  goals  in  the  aquaculture  sector.  The  analysis  then 
extends to financial mechanisms that have been implemented or proposed within 
the aquaculture sector, assessing their effectiveness and suitability in promoting 
the adoption of algae-containing feed. 

4.1.  Financial incentives for algae-based fish feed 

4.1.1.  Strategies and financial incentive systems used in the 

agriculture sector 

Financial incentives have long been a cornerstone of policy interventions aimed 
at promoting sustainable practices in primary production sectors, particularly in 

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agriculture.  These  mechanisms  aim  to  align  economic  and  environmental 
objectives, ensuring that producers can transition to more sustainable methods 
without bearing undue financial burdens. The EU has implemented a variety of 
financial  incentives  to  encourage  sustainable  agriculture  under  the  Common 
Agricultural Policy (CAP) and the European Green Deal. These incentives fall into 
five  key  categories:  direct  financial  support,  market-based  instruments,  trade 
policy tools, risk-sharing instruments, and support mechanisms. A more detailed 
analysis of these financial incentives can be found in Annex IV. Section 9.9 of the 
Annex provides an overview and explanation of each instrument, while Section 
9.10 outlines  how these  strategies  and  financial  incentive  systems  are  applied 
within the primary production sector.  

4.1.2.  Exploring  options  for  financial  incentives  for  algae-

based fish feed 

To  assess  financial  incentives  relevant  to  the  aquaculture  sector,  this  section 
begins by identifying the policy commitments and funding mechanisms outlined 
in the European Green Deal. These commitments highlight key priority areas for 
financial support and reflect the EU’s broader sustainability objectives concerning 
food  systems.  The  section  then  examines  financial  incentives  that  have  been 
implemented or proposed specifically for aquaculture, drawing on both existing 
mechanisms  and  potential  new  instruments  that  could  improve  the  economic 
viability of algae-containing feed. 

4.1.2.1.  Financial instruments and incentives in the EU Green 

Deal 

The European Green Deal is an ambitious and transformative strategy aimed at 
making the EU economy sustainable across all sectors. To realise its objectives, 
the  European  Commission  has  committed  to  mobilising  at  least  €1  trillion  in 
sustainable investments over the next decade. In support of this goal, the Green 
Deal  and  its  associated  regulations  have  introduced  a  range  of  financial 
instruments and incentives designed to direct public and private capital towards 
sustainable  activities  across  multiple  sectors.  Several  of  these  instruments 
specifically  target  sustainable  food  systems  and  hold  promise  for  promoting 
environmental  sustainability  within 
including  by 
encouraging the increased production and uptake of algae-containing feed. 

the  aquaculture  sector, 

A  significant  portion  of  the  EU’s  budget  has  been  allocated  to  supporting  the 
Green  Deal’s  objectives.  Specifically,  30%  of  the  EU’s  multiannual  budget 
(2021-2027) and the EU’s NextGenerationEU (NGEU) recovery instrument have 
been earmarked for sustainable investments in key sectors. In addition, within the 
Recovery and Resilience Facility (RRF), Member States are required to allocate 
at least 37% of the €672.5 billion to climate-related objectives.  

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Complementing  public  funding,  the  Green  Deal  places  a  strong  emphasis  on 
mobilising  private  finance  to  achieve  its  sustainability  goals.  The  InvestEU 
Programme plays a pivotal role in this effort by providing guarantees and loans 
to  reduce  investment  risks,  with  at  least  30%  of  its  funding  targeted  towards 
climate-related projects. As such, InvestEU can be a key instrument for financing 
sustainable  aquaculture,  particularly  for  small  and  medium-sized  enterprises 
(SMEs) that may face  challenges  in accessing  traditional funding. A  dedicated 
Just Transition Scheme under InvestEU further supports regions transitioning to 
sustainable practices, ensuring inclusivity in the green transition. 

is 

the  cornerstone  of 

The  EU  Sustainable  Finance  framework 
the 
Commission’s  strategy  to  channel  private  capital  toward  environmentally 
sustainable  projects.  At  its  core,  the  EU  Taxonomy  for  Sustainable  Activities 
provides  a  clear  classification  system  for  green  investments,  helping  investors 
identify opportunities that align with the Green Deal’s objectives. The Taxonomy 
defines  criteria  for  economic  activities  that  contribute  to  climate  change 
mitigation,  adaptation,  and  other  environmental  goals.  While  the  Taxonomy 
currently  does  not  explicitly  include  sustainable  aquaculture  activities,  future 
delegated  acts  could  expand  its  scope  to  incorporate  such  measures,  thereby 
unlocking additional green financing opportunities for the sector.  

Individual regulations and initiatives relevant to aquaculture that arose from the 
Green  Deal  have  introduced  a  range  of  financial  instruments  and  incentives 
specifically  designed  to  support  sustainable  practices  and  the  adoption  of 
innovative solutions. One of the most direct ways the EU supports sustainable 
aquaculture  is  through  dedicated  funding  programmes.  The  European 
Maritime,  Fisheries  and  Aquaculture  Fund  (EMFAF)  provides  financial  support 
for  sustainable  aquaculture  as  part  of  its  broader  objectives  to  promote  the 
sustainable  development  of  fisheries,  aquaculture,  and  maritime  economies. 
EMFAF  contributes  to  the  European  Green  Deal’s  objectives,  by  supporting 
initiatives  that  enhance  environmental  sustainability,  resource-efficiency,  and 
innovation in aquaculture.  

through 

Beyond  direct  payments,  fiscal  tools  also  have  a  crucial  role  to  play  in 
encouraging  sustainable  practices.  The  European  Green  Deal  specifically 
emphasises  the  importance  of  greening  national  budgets  and  aligning  price 
for 
signals 
environmentally harmful activities – such as those supporting fossil fuels – and 
introducing tax incentives that promote the adoption of sustainable products and 
practices.  The  revised  VAT  Directive  (EU  2022/542)  allows  Member  States  to 
apply reduced VAT rates on environmentally friendly products, including organic 
and sustainably produced food. 

includes  phasing  out  subsidies 

reform.  This 

tax 

in  promoting 
Certification  and 
sustainability by creating market incentives for environmentally friendly products. 
The Farm to Fork Strategy and the Circular Economy Action Plan (CEAP) both 

labelling  schemes  play  a  crucial  role 

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the 

labels 

to  highlight 

importance  of  certifications  and 

emphasise 
the 
sustainability  performance  of  (food)  products.  The  EU  is  further  exploring  the 
potential of blue carbon credits to incentivise carbon-capture services provided 
by  aquaculture,  such  as  seaweed  farming.  The  Farm  to  Fork  Strategy  also 
includes  provisions  for  promotion  activities  aimed  at  raising  consumer 
awareness  and  increasing  the  demand  for  sustainable  food  products,  creating 
additional  market  incentives  for  producers  to  adopt  environmentally  friendly 
practices.  Lastly,  research  and  innovation  play  a  key  role  in  the  Green  Deal. 
Horizon Europe, the EU’s flagship research and innovation programme, offers 
grants  for  projects  focused  on  sustainable  food  systems,  including  the 
development of alternative feeds. 

4.1.2.2.  Types  of  incentives  for  the  use  of  algae-based  fish 

feed in sustainable aquaculture 

Financial  and  regulatory  incentives  have  shown  strong  potential  in  guiding 
aquaculture practices toward greater sustainability across Europe, with several 
initiatives already delivering measurable results. Among these, flexible licensing 
systems  have  proven  particularly  effective,  blending  environmental  safeguards 
with  market-responsive  mechanisms  to  foster  the  uptake  of  sustainable 
technologies.  One  notable  example  is  Norway’s  eco-technology  licensing 
scheme, which leverages performance-based criteria and innovation incentives 
to reduce environmental impacts while enabling continued industry growth. The 
text box below illustrates how this model has been implemented in practice.  

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Case study: Norway’s Eco-Technology Licences 

Norway’s  approach  to  aquaculture  licensing  has  demonstrated  how  carefully 
designed  regulatory  incentives  can  drive  meaningful  environmental  improvements 
while  maintaining  industry  competitiveness.  Since  their  introduction  in  2021,  the 
country’s  eco-technology  licences  have  created  a  market  mechanism  that  rewards 
technological  innovation  and  environmental  performance (205).  These  specialised 
permits  function  as  a  bridge  between  experimental  research  and  full  commercial 
operation,  requiring  licence  holders  to  implement  innovative  solutions  that  address 
critical sustainability challenges (206). 

The  Norwegian  system  operates  through  a  competitive  allocation  process  where 
licences  are  awarded  to  applications  that  involve  significant  innovation  and 
investments  in  technology  that  can  contribute  to  solving  one  or  more  of  the 
environmental and area challenges that the aquaculture industry faces. What makes 
this system particularly innovative is its scoring methodology, where operators earn 
‘innovation points’ for implementing specific environmental safeguards (207).  

Implementation results after three years reveal significant environmental benefits, with 
licensed  farms  showing  40-60%  reductions  in  seabed  pollution  compared  to 
conventional  operations (208).  The  scheme  has  successfully  stimulated  market 
transformation, creating a premium segment for eco-certified salmon that commands 
15-20%  higher  prices (209). It  has  also  accelerated  the  adoption  of  recirculating 
aquaculture systems (RAS), with twelve new RAS facilities established specifically to 
meet the licence requirements (210). The decision to offer these licences free of charge 
for RAS operations has been particularly effective in removing cost barriers for smaller 
operators and start-ups. 

the  Norwegian  experience  also  highlights  several 

implementation 
However, 
challenges.  The  complex  application  process  created  significant  administrative 
burdens that delayed licence awards by 12-18 months in initial rounds (211). Concerns 
have  also  been  expressed  about  the  sector’s  rapid  technological  transformation, 
which risks undermining Norway’s competitive position by marginalising actors lacking 
the resources to invest in R&D or adopt complex new systems (212). 

(2024). 

(205)  European  Commission 
“COMMISSION  STAFF  WORKING  DOCUMENT 
Implementing  the  Strategic  Guidelines  for  EU  Aquaculture  Regulatory  and  Administrative 
Framework for Aquaculture”. Available here.  
(206) Afewerki et al. (2023). “Innovation Policy in the Norwegian Aquaculture Industry: Reshaping 
Aquaculture 
152.  
Innovation 
Production 
https://doi.org/10.1016/j.marpol.2023.105624  
(207)  Osmundsen  et  al.  (2022).  “Aquaculture  Policy:  Designing  Licenses  for  Environmental 
Regulation,” Marine Policy 138.  https://doi.org/10.1016/j.marpol.2022.104978  
(208) Afewerki et al. (2023). “Innovation Policy in the Norwegian Aquaculture Industry: Reshaping 
Aquaculture 
152.  
Innovation 
Production 
https://doi.org/10.1016/j.marpol.2023.105624 
(209)  Osmundsen  et  al.  (2022).  “Aquaculture  Policy:  Designing  Licenses  for  Environmental 
Regulation,” Marine Policy 138.  https://doi.org/10.1016/j.marpol.2022.104978  

Networks,” 

Networks,” 

Marine 

Marine 

Policy 

Policy 

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In addition to preferential licensing, multiple financial instruments can incentivise 
sustainable  aquaculture  practices,  including  the  adoption  of  algae-containing 
feeds. The instruments outlined below, drawn from academic literature and EU 
policy,  represent  the  most  promising  approaches  currently  available.  These 
incentives  aim  to  reduce  the  financial  risks  of  adopting  sustainable  practices, 
encourage  innovation,  and  create  market  demand  for  environmentally  friendly 
products.  They  are  categorised  according  to  the  same  typology  applied  to 
agricultural incentives (see Section 4.1.1 and Annex IV). 

Direct financial support 

Subsidies and direct funding are among the most widely discussed financial 
incentives  in  the  literature.  Governments  and  international  organisations  often 
provide  grants  or  subsidies  to  offset  the  high  initial  costs  of  transitioning  to 
sustainable  practices,  making  them  more  accessible  to  producers,  especially 
small  and  medium-sized  enterprises  (SMEs),  and  more  competitive  with 
conventional alternatives. As shown in Annex IV, the CAP supports the adoption 
of  sustainable  practices  through  Agri-Environment-Climate  Measures,  Eco-
schemes,  and  Rural  Development  Programmes  through  subsidies  and  direct 
payments, while the EMFAF provides targeted subsidies to foster innovation and 
facilitate  the  uptake of  sustainable  aquaculture  practices.  By  reducing  the  cost 
differential,  subsidies  can  accelerate  adoption  rates  and  support  producers 
during the transition phase. 

The  primary  effect  mechanism  of  direct  subsidies  is  cost  reduction,  enabling 
producers to invest in sustainable feed without incurring financial disadvantages. 
Subsidies have been successfully used in agriculture to promote environmentally 
friendly practices, demonstrating their potential for aquaculture.  

One  of  the  key  merits  of  direct  subsidies  is  their  ability  to  provide  immediate 
financial relief, ensuring that sustainability goals do not come at the expense of 
economic  viability.  Furthermore,  subsidies  can  be  designed  with  conditional 
requirements, ensuring that recipients meet sustainability benchmarks. However, 
a  major  drawback  is the  fiscal burden  on  public  budgets, and poorly  designed 
subsidies can lead to market distortions, creating dependencies that may not be 
sustainable in the long term. 

(210)  SUBMARINER  Network  For  Blue  Growth  EEIG,  “Policy  Recommendations  for  Innovation 
and Market Access Barriers in the RAS Sector within the Baltic Sea Region”. Available here. 
(211)  Osmundsen  et  al.  (2022).  “Aquaculture  Policy:  Designing  Licenses  for  Environmental 
Regulation,” Marine Policy 138.  https://doi.org/10.1016/j.marpol.2022.104978 
(212) Afewerki et al. (2023). “Innovation Policy in the Norwegian Aquaculture Industry: Reshaping 
Aquaculture 
152.  
Innovation 
Production 
https://doi.org/10.1016/j.marpol.2023.105624 

Networks,” 

Marine 

Policy 

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Investment in R&D is critical to improving the cost-effectiveness and nutritional 
value  of  algae-based  fish  feed.  R&D  grants  targeted  at  feed  producers, 
universities,  and  research  institutions  can  drive  innovation  and  scale-up 
production  techniques.  The  effect  mechanism  of  R&D  grants  lies  in  fostering 
technological advancements, reducing production costs over time, and improving 
the feed’s commercial viability. 

One  of  the  key  merits  of  R&D  funding  is  its  potential  to  generate  long-term 
benefits  by  addressing  existing  barriers  to  adoption.  Innovations  in  algae 
cultivation,  algae  processing  efficiency,  and  feed  formulation  can  make  algae-
containing sustainable feed a viable alternative to traditional fishmeal and fish oil 
incorporated  feed.  However,  the  primary  drawback  is  the  time  lag  between 
investment  and  market  impact,  as  research  breakthroughs  require  years  to 
translate into commercially viable products. 

Market-based instruments 

in 

the 

incentives 

literature  as  market-based 

Certification  schemes  and  eco-labels,  such  as  the  Aquaculture  Stewardship 
Council  (ASC)  and  the  Marine  Stewardship  Council  (MSC),  are  frequently 
discussed 
for  sustainable 
aquaculture.  These  certifications  allow  producers  to  access  premium  markets 
and charge higher prices for their products, creating a financial incentive to adopt 
sustainable  practices.  Producers  who  meet  the  stringent  environmental  and 
social standards required by certifications can differentiate their products in the 
market,  attract  environmentally  conscious  consumers,  and  command  higher 
prices (213). Larger producers are willing to invest in certification and eco-labels 
to gain a competitive advantage relative to other fish farmers and to avoid future 
non-compliance with stricter market requirements (214). However, for small-scale 
producers, certification may not be a viable option, even in the presence of strong 
market demand, as complexities and costs associated with certification limit the 
ability of small-scale producers to benefit from premium pricing (215). Processors 
and retailers of farmed fish also play a critical role in driving certification and eco-
label  adoption,  since  they  often  demand  certification  from  their  suppliers 
motivated by the potential to obtain a competitive advantage and gain or maintain 
access to certain markets (216). However, certification and eco-label requirements 

(213) Jonell  et al. (2016). “Eco-Labeled  Seafood: Determinants for (Blue) Green Consumption,” 
Sustainability, 8(9). https://doi.org/10.3390/su8090884  
(214) Chikudza et al. (2020). “Producer Perceptions of the Incentives and Challenges of Adopting 
Ecolabels  in  the  European  Finfish  Aquaculture  Industry:  A  Q-Methodology  Approach,”  Marine 
Policy 121, 104176. https://doi.org/10.1016/j.marpol.2020.104176  
(215) Chikudza et al. (2020). “Producer Perceptions of the Incentives and Challenges of Adopting 
Ecolabels  in  the  European  Finfish  Aquaculture  Industry:  A  Q-Methodology  Approach,”  Marine 
Policy 121, 104176. https://doi.org/10.1016/j.marpol.2020.104176 
(216)  Olsen  et  al.  (2021).  “Certifying  the  Public  Image?  Reputational  Gains  of  Certification  in 
Norwegian 
736900. 
https://doi.org/10.1016/j.aquaculture.2021.736900  

Aquaculture,” 

Aquaculture, 

Salmon 

542. 

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are sometimes perceived as inadequate or irrelevant for addressing the negative 
impacts of aquaculture in the local context (217). 

tool 

incentives  are  another 

for  promoting  sustainable 
important 
Tax 
aquaculture (218).  Tax  incentives,  such  as  reduced VAT rates  (e.g.  through  the 
revised VAT Directive EU 2022/542) or tax credits for feed manufacturers using 
algae-based ingredients, can lower production costs and encourage investment 
in  sustainable  alternatives.  The  effect  mechanism  of  tax  incentives  operates 
through  cost  reduction,  stimulating  supply  and  demand  for  sustainable  feed 
options. The literature suggests that reducing taxes on environmentally friendly 
practices  or  products  can  incentivise  producers  to  adopt  sustainable  methods. 
Additionally,  environmental  taxes  or  pollution 
levies  can  discourage 
unsustainable  practices,  such  as  excessive  nutrient  discharge  or  the  use  of 
harmful chemicals. By internalising the environmental costs of aquaculture, these 
fiscal  policies  create  economic  incentives  for  producers  to  adopt  cleaner  and 
more efficient practices. For example, since 2013, Denmark applies a pesticide 
load  tax  according  to  which  the  most  harmful  pesticides  carry  higher  taxes, 
incentivising farmers to switch to less toxic alternatives. The main advantage of 
tax incentives is their ability to encourage private-sector investment without direct 
government spending. They provide long-term support without requiring constant 
financial outflows, making them fiscally sustainable. However, tax incentives may 
be less effective in markets where upfront investment costs are prohibitively high, 
and  their  impact  depends  on  how  businesses  and  producers  respond  to  the 
financial incentives. 

The concept of Payment for Ecosystem Services (PES) has gained traction in 
the literature as a financial incentive for sustainable aquaculture. PES schemes 
compensate  producers  for  the  environmental  benefits  they  generate,  such  as 
carbon  sequestration,  water  purification,  or  biodiversity  conservation.  For 
example, microalgae cultivation can deliver ecosystem services such as carbon 
sequestration  and  nutrient  removal  from  wastewater,  and  PES  schemes  could 
potentially reward producers for providing these environmental benefits (219). PES 
schemes  can  be  funded  by  governments,  non-governmental  organisations 
(NGOs), or private entities, and provide a direct financial incentive for producers 
to adopt practices that enhance ecosystem health. PES can improve ecological 
outcomes while generating additional revenue streams for fish farmers. However, 

(2020). 

(217)  Amundsen  &  Osmundsen 
“Becoming  Certified,  Becoming  Sustainable? 
Improvements  from  Aquaculture  Certification  Schemes  as  Experienced  by  Those  Certified,” 
Marine Policy 119, 104097. https://doi.org/10.1016/j.marpol.2020.104097  
(218)  Hishamunda  et  al.  (2014).  “Policy  and  Governance  in  Aquaculture  Lessons  Learned  and 
Way Forward” (FAO). Available here. 
(219) Linus Hasselström and Fredrik Gröndahl (2021). “Payments for Nutrient Uptake in the Blue 
Bioeconomy – When to Be Careful and When to Go for It,” Marine Pollution Bulletin 167, 112321, 
https://doi.org/10.1016/j.marpolbul.2021.112321 

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establishing  measurable  criteria  and  ensuring  effective  monitoring  can  be 
challenging. 

Risk-sharing instruments 

Green/Blue bonds and other sustainable finance instruments are increasingly 
being  explored  as  tools  to  fund  sustainable  aquaculture  projects.  Green/Blue 
bonds allow investors to support environmentally friendly initiatives, such as the 
development  of  sustainable  aquaculture  systems  or  the  production  of  algae-
containing feeds. The proceeds from these bonds can be used to finance projects 
that  reduce  environmental  impacts  and  promote  resource  efficiency (220).  For 
example, on 2 April 2025, the European Investment Bank (EIB) issued €3 billion 
in  green  bonds  aligned  with  the  new  European  Green  Bond  Standard,  with 
proceeds earmarked for projects that contribute substantially to EU climate and 
environmental objectives, such as clean energy, sustainable transport, and water 
infrastructure. 

Beyond  bonds,  impact  investing  and  blended  finance  models  present 
significant  opportunities  to  attract  private  capital  into  sustainable  aquaculture. 
While these instruments have historically received limited attention in the context 
of sustainable fishing and aquaculture (221), their potential to reduce investment 
risks  and  support  innovative  projects  is  substantial.  Impact  investing  seeks  to 
generate positive social and environmental benefits alongside financial returns, 
making it well-suited to funding sustainable aquaculture initiatives. According to 
the  FAO,  there  is  a  significant  opportunity  to  leverage  $500  billion  of  impact 
including  sustainable 
investment  capital 
aquaculture (222).  Blended 
finance,  which  combines  public  and  private 
investment,  can  further  mitigate  risks  and  enhance  the  attractiveness  of 
sustainable  aquaculture  projects  to  private  investors (223).  Such  instruments, 
including bonds,  impact  investing,  and  blended  finance,  can  support long-term 
funding and sector growth, but require strong governance frameworks to ensure 
funds are allocated effectively. 

the  blue  economy, 

to  support 

(220)  FAO  (2020).  “FAO’s  Blue  Growth  Initiative:  Blue  Finance  Guidance  Notes  Impact 
Investment,” Available here. 
(221) Sumaila et al. (2021). “Financing a Sustainable Ocean Economy,” Nature Communications 
12, no. 1: 3259. https://doi.org/10.1038/s41467-021-23168-y 
(222)  FAO  (2020).  “FAO’s  Blue  Growth  Initiative:  Blue  Finance  Guidance  Notes  Impact 
Investment,” Available here. 
(223)  FAO  (2020).  “FAO’s  Blue  Growth  Initiative:  Blue  Finance  Guidance  Notes  Impact 
Investment,” Available here. 

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Support mechanisms 

Consumer demand for sustainable seafood is a powerful financial incentive for 
aquaculture  producers.  The  literature  emphasises  the  role  of  eco-labels  and 
consumer  awareness  campaigns  in  driving  demand  for  sustainably  produced 
seafood. By choosing certified products, consumers can create market incentives 
for producers to adopt environmentally friendly practices (224). 

4.1.3.  Feasibility  and 
incentives 

recommendations 

for 

financial 

Financing  sustainable  ocean  economies  –  including  aquaculture  –  faces 
persistent  challenges  stemming  from  inadequate  policy  frameworks,  limited 
investable  projects,  and  heightened  risk  perceptions (225).  To  overcome  these 
barriers  and  specifically  promote  algae-containing  feed  adoption,  a  structured 
incentive system is required. Such a system must begin with  a comprehensive 
policy  framework  to  create  stable  investment  environments,  complemented  by 
innovative financing mechanisms and enhanced risk mitigation (226). 

The  economic  viability  of  algae-based  fish  feed  in  European  aquaculture 
demands  a  holistic  approach 
that  simultaneously  addresses  regulatory, 
production, adoption, and market dimensions. This requires coordinated action 
across  four  critical  angles:  first,  the  establishment  of  a  comprehensive  policy 
framework  setting  clear  sustainability  standards  and  adoption  pathways  for 
alternative  feeds;  second,  targeted  support  for  feed  producers  to  overcome 
technical  and  financial  barriers;  third,  tailored  incentives  for  fish  farmers  to 
mitigate  transition  costs  and  operational  risks  to  adopt  algae-containing  feeds; 
and fourth, robust consumer information campaigns to build market recognition 
and  demand  for  seafood  raised  on  sustainable  feed.  Through  this  mutually 
reinforcing combination of measures – where policy certainty enables investment, 
producer support ensures supply, farmer incentives drive uptake, and consumer 
awareness sustains demand – algae-containing feeds can achieve the necessary 
scale to compete with conventional alternatives. The specific recommendations 
that follow detail how each of these angles can be operationalised. 

(224) Hallstein & Villas-Boas (2013). “Can Household Consumers Save the Wild Fish? Lessons 
from a Sustainable Seafood Advisory,”  Journal of Environmental Economics and Management 
66, no. 1: 52–71. https://doi.org/10.1016/j.jeem.2013.01.003  
(225) Sumaila et al. (2021). “Financing a Sustainable Ocean Economy,” Nature Communications 
12, no. 1: 3259. https://doi.org/10.1038/s41467-021-23168-y  
(226) Sumaila et al. (2021). “Financing a Sustainable Ocean Economy,” Nature Communications 
12, no. 1: 3259. https://doi.org/10.1038/s41467-021-23168-y  

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Establish an enabling regulatory and policy environment 

A stable and effective regulatory environment is essential to attract investment 
and foster innovation in algae-based fish feed, which is already progressing as 
part of the EU Green Deal package. 

Key actions include introducing policies that secure tenure and access rights for 
fish farmers who adopt algae-containing feeds. For example, preferential access 
to aquaculture zones or reduced or eliminated licensing fees could be offered to 
those  who  demonstrate  compliance  with  sustainability  standards.  Additionally, 
the EU should encourage existing certification schemes, such as the ASC and 
the  EU  Organic  Logo,  to  include  specific  criteria  for  algae-containing  feeds. 
Certification  can  enhance  market  access  and  create  price  premiums  for 
sustainably  farmed  fish,  providing  a  financial  incentive  for  fish  farmers  to 
transition to algae-containing feeds. Furthermore, technical support should be 
provided  to  feed  producers  and  fish  farmers  through  training  programmes, 
knowledge-sharing  platforms,  and  access  to  R&D  resources  that  enables  the 
adoption  of  algae  as  a  sustainable  feed  ingredient.  This  will  help  overcome 
barriers to adoption and ensure that stakeholders have the necessary skills and 
knowledge to implement sustainable practices. 

Correct market distortions through fiscal measures 

Fiscal  measures  can  play  a  pivotal  role  in  aligning  economic  incentives  with 
environmental goals. Reforming fiscal policies has great potential to discourage 
unsustainable practices and promote the use of algae-containing feeds. 

One key action is to phase out subsidies for conventional fish feeds that rely on 
fishmeal and fish oil above a certain level of FFDR (see Section 3.2) and redirect 
these  funds  to  support  the  production  and  adoption  of  algae-containing  feeds. 
Gradually reducing subsidies for high-FFDR fish-containing feeds can level the 
playing  field  for  alternative  feed  options,  encouraging  producers  to  seek  more 
sustainable feeds such as those containing algae. One of the key benefits of this 
approach  is  that  it  does  not  require  additional  public  spending;  rather,  it 
reallocates  resources  towards  sustainable  solutions.  However,  a  potential 
drawback  is  resistance  from  stakeholders  currently  benefiting  from  existing 
subsidies, which could slow implementation. 

Additionally,  the  EU  should  introduce  taxes  on  conventional  feeds  that  have  a 
higher environmental impact, such as those contributing to overfishing or those 
leading  to  nutrient  loading.  The  revenue  generated  from  these  taxes  could  be 
used  to  fund  R&D  for  algae-containing  feeds  or  provide  subsidies  for  their 
adoption. Tax incentives, such as reduced VAT rates on sustainable aquaculture 
products, as allowed under the revised VAT Directive (EU 2022/542), should also 
be offered to fish farmers who adopt algae-containing feeds. 

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Integrate sustainable aquaculture into the EU Taxonomy  

To guide investment decisions and development policy, the EU should consider 
integrating  sustainable  aquaculture,  including  algae-containing  feeds,  into  the 
existing  EU  Taxonomy  for  Sustainable  Activities.  This  would  have  positive 
implications for investments in the aquaculture industry, as activities assessed as 
environmentally sustainable would become more attractive to investors. 

The inclusion of sustainable aquaculture in the EU Taxonomy would provide a 
clear framework for defining environmentally sustainable practices, such as the 
use of algae-containing feeds, and ensure that investments align with the EU’s 
sustainability goals. This would also create a strong incentive for fish farmers and 
feed  producers  to  adopt  sustainable  practices,  as  they  would  gain  access  to 
green  financing  opportunities.  The  EU  should  collaborate  with  stakeholders  to 
develop  specific  criteria  for  sustainable  aquaculture  within  the  Taxonomy, 
ensuring  that  algae-containing  feeds  are  recognised  as  a  key  component  of 
environmentally sustainable practices. 

Introduce innovative financing mechanisms 

New  financing  tools  and  access  to  capital  markets  are  needed  to  incentivise 
sustainable, inclusive, and climate-resilient aquaculture activities. The EU should 
explore  innovative  financial  instruments  to  support  the  adoption  of  algae-
containing feeds. 

One  approach  is  to  encourage  the  issuance  of  green  and  blue  bonds  to  fund 
sustainable  aquaculture  projects,  including  the  development  and  adoption  of 
algae-containing feeds. These bonds can attract private capital and support the 
growth of the algae feed sector. Additionally, blended finance models should be 
used  to  combine  public  and  private  funding  for  algae-containing  feed  projects. 
This approach  can  reduce  investment  risks  and make  sustainable  aquaculture 
more attractive to private investors. 

Strengthen data infrastructure and transparency  

Improved  data  infrastructure  and  transparency  are  critical  for  attracting 
investment  and  ensuring  the  effective  allocation  of  resources.  The  EU  should 
prioritise  the  development  of  robust  monitoring  and  reporting  systems  for 
sustainable  aquaculture.  This  will  help  investors  make  informed  decisions  and 
support  the  development  of  robust  business  plans.  Additionally,  transparent 
monitoring  systems  should  be  implemented  to  track  the  environmental 
performance of aquaculture operations. This will increase consumer confidence 
in  sustainably  farmed  fish  and  create  market  incentives  for  algae-containing 
feeds. 

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The  feasibility  of  these  measures  was  assessed  in  the  validation  process  with 
stakeholders across the value chain. The establishment of an enabling regulatory 
and policy environment for algae-based fish feed, the integration of sustainable 
aquaculture into the EU Taxonomy, and the introduction of innovative financing 
mechanisms  were  found  to  be  realistic  by  each  of  the  participants.  Almost  all 
participants agreed to the development of a comprehensive framework for algae-
based fish feed, the correction of market distortions through fiscal measures, the 
phasing  out  of  subsidies  for  unsustainable  fish  feeds,  and  the  provision  of  tax 
incentives  for  more  sustainable  options,  as  well  as  to  strengthening  data 
infrastructure and transparency. 

4.2.  Conclusion  

The  financial  sustainability  of  algae-containing  feed  depends  on  both  cost 
competitiveness (as highlighted in the MCA conducted under this project) and the 
availability  of  targeted  financial  incentives.  The  analysis  in  this  section 
demonstrates  that  financial  incentives  play  a  crucial  role  in  supporting  the 
transition to sustainable feed alternatives, both by mitigating cost barriers and by 
providing  direct  economic  incentives  for  adoption.  Lessons  from  agriculture 
illustrate  how  structured  financial  support,  including  subsidies,  market-based 
instruments,  and  risk-sharing  mechanisms,  can  facilitate  the  widespread 
adoption of sustainable practices. Translating these insights into aquaculture will 
require careful consideration of sector-specific constraints and opportunities. 

A  key  takeaway  from  the  assessment  is  that  while  the  European  Green  Deal 
provides  a  strong  policy  foundation  for  sustainability  in  aquaculture,  existing 
financial  support  mechanisms  may  not  yet  be  fully  aligned  with  the  specific 
objective  of  increasing  the  adoption  of  algae-containing  feed.  Direct  financial 
support and risk-sharing instruments could be instrumental in addressing initial 
investment costs and market uncertainties, while market-based instruments such 
as PES and certification schemes could enhance long-term economic feasibility. 

Moving  forward,  a  more  coordinated  approach  is  needed  to  integrate  financial 
incentives  across  policy  frameworks,  ensuring  that  funding  mechanisms  are 
effectively tailored to drive innovation and sustainability in aquaculture. Aligning 
financial  support  with  clear  sustainability  targets,  fostering  public-private 
partnerships, and leveraging research and development funding will be critical in 
accelerating  the  adoption  of  algae-containing  feed.  By  building  on  the  lessons 
learned  from  other  primary  production  sectors  and  refining  financial  incentive 
structures, the EU can create a more resilient and sustainable aquaculture sector. 

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5.  Regulatory framework and compliance 

5.1.  Regulations  relevant to algae as  a feed ingredient 

in the EU 

What is “feed” from a legal point of view? 

Regulation  (EC)  No  178/2002  “lays  down 
the  general  principles  and 
requirements of food law, establishing the European Food Safety Authority and 
lays  down  procedures  in  matters  of  food  safety”.  While  this  Regulation  is  also 
often called the “General food law”, it also defines the term “feed” in “Article 4: 
“Feed” (or “Feedingstuff”) means any substance or product, including additives, 
whether processed, partially processed or unprocessed, intended to be used for 
oral feeding to animals”. 

While the Regulation (EC) No 178/2002 has defined that feed is intended to be 
orally fed to animals, Regulation (EC) No 767/2009 specifies that “oral feeding 
of animals means the introduction of feed into an animal’s gastrointestinal tract 
through the mouth with the aim of meeting the animal’s nutritional needs and/or 
maintaining the productivity of normally healthy animals”. These two definitions 
explain  the  fundamental  characteristics  that  a  feed  must  possess  to  be 
considered as such.  

The  following  sections  map  the  most  relevant  EU  regulations  for  (algae)  feed 
production and algae cultivation. 

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Table 10 – Overview of relevant EU regulations 

Regulations relevant to algae feed production 

Regulation (EC) No 767/2009  

Regulation on the placing on the market and use of feed  
(“Animal Feed Regulation”) 

Regulation (EC) No 178/2002 

Regulation laying down the general principles and requirements of 
food law, establishing the European Food Safety Authority and 
laying down procedures in matters of food safety  
(“General Food Law”) 

Regulation (EC) No 1831/2003 

Regulation on additives for use in animal nutrition 
(“Feed Additives Regulation”) 

Regulation (EU) No 68/2013  

Regulation on the Catalogue of feed materials 
(“The Catalogue of Feed Materials”) 

(Feed Materials Register) 

The Register is not a separate regulation, but introduced by Article 
25 (6) (EC) No 767/2009 

Regulation (EC) No 183/2005 

Regulation laying down requirements for feed hygiene  
(“Feed Hygiene Regulation”) 

Directive 2002/32/EC 

Directive on undesirable substances in animal feed 

Regulation (EC) No 1829/2003 

Regulation on genetically modified food and feed  
(“GMO Regulation”) 

Regulation (EU) 2015/2283 

Regulation on novel foods (“Novel Food Regulation”) 

Regulation (EU) No 2017/625 

Regulation on official controls and other official activities performed 
to ensure the application of food and feed law, rules on animal 
health and welfare, plant health and plant protection products 
(“Official Controls Regulation”) 

Regulations relevant to algae production 

Regulation (EU) No 1379/2013 

Regulation on the common organisation of the markets in fishery 
and aquaculture products (“CMO”) 

Regulation (EU) No 1380/2013 

The Common Fisheries Policy (“CFP”) 

Regulation (EC) No 708/2007 

Regulation concerning use of alien and locally absent species in 
aquaculture (“Alien Species Legislation”) 

Regulation (EU) 2018/848  

Regulation on organic production and labelling of organic products  
(“Organic Regulation”) 

Directive 2011/92/EU 

Regulation on the assessment of the effects of certain public and 
private projects on the environment (“EIA Directive”) 

Regulation (EC) No 1069/2009 

Regulation laying down health rules as regards animal by-products 
and derived products not intended for human consumption  
(“Animal By-Products Regulation,” “ABP Regulation”) 

Note that this list is non-exhaustive; additional regulations may be relevant, if applicable. 

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5.1.1.  EU Regulations relevant to algae as a feed ingredient 

Historically, Directive 82/471/EEC (from 1982) governed certain products used in 
animal  nutrition.  It  aimed  to  improve  the  supply  of  feed  used  as  a  direct  and 
indirect  source  of  protein  in  the  Community.  This  Directive  required  that  the 
placing  of  any  bioprotein  on  the  market  is  preceded  by  an  authorisation 
procedure.  In  its  Annex,  it  already  explicitly  listed  "algae"  among  the  "protein 
products obtained from microorganisms".  

This  Directive  was  replaced  by  Regulation  (EC)  No  767/2009,  also  called  the 
“Animal Feed Regulation”, that aimed to simplify and harmonise the legislation 
regarding the placing on the market and the use of feed. It is important to note 
that  novel  foods  must  undergo  an  authorisation  process  prior  to  market  entry, 
whereas  for  novel  feed  materials  it  is  suggested  that  safety  risks  could  be 
managed by prohibiting the sale of risky substances through market surveillance 
measures.  Annex  III  of  Regulation  (EC)  767/2009  also  contains  a  short  list  of 
materials that are strictly prohibited in animal feed.  

Additionally,  Chapter  4  of  this  regulation  establishes  the  principles  for  feed 
labelling and presentation, including the use of claims. In Article 13 it is stated 
that claims regarding nutritional characteristic or process or to a specific function 
related to any of these can be made under the conditions described therein. 

The Catalogue of Feed Materials was established to improve labelling of feed 
materials and compound feed. This catalogue is non-exhaustive, and its use is 
optional. It promotes the exchange of information about the characteristics of feed 
materials and is updated on a regular basis. Amongst other feed materials, algae 
are listed in Annex C No 7, "Other plants, algae and plant products". Currently, 
algae  (live  or  processed),  dried,  algae  meal,  algae  oil,  and  seaweed  meal 
(specific  mention  of  meal  from  macroalgae  Asparagopsis)  are  listed  in  the 
catalogue.  

A business operator who uses a feed material listed in the catalogue needs to 
ensure that all relevant provisions of the catalogue are complied with, including 
the  compulsory  declaration  about  the  feed  material  on  the  label.  Furthermore, 
they  need  to  ensure  compliance  with  Article  4  (on  safety  and  marketing 
requirements) of Regulation (EC) No. 767/2009. According to Article 24 (6) of this 
Regulation, the person who, for the first time, places on the EU market a feed 
material that is not listed in the catalogue must immediately notify this matter via 
the internet-based Feed Materials Register. Numerous micro- and macroalgae 
species have been registered, often in several different processing forms such as 
extracts or dried ingredients.  

If a product is listed in the register, it does not automatically imply that it is safe 
or suitable for all applications. The responsibility for ensuring the safety of feed 
lies with the individual operator in the feed sector. Requirements such as those 

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described in Article 4 of Regulation (EC) No. 767/2009 intend to ensure the safety 
of  the  product,  in  addition  to  those  from  Regulation  (EC)  No.  178/2002  and 
Regulation (EC) No 183/2005, pertaining to feed hygiene. Additionally, Annex I 
of the Directive 2002/32/EC on undesirable substances in animal feed states 
the  maximum  levels  of  such  substances  in  products  intended  for  animal  feed, 
including  those  relevant  for  algae  such  as  arsenic,  cadmium,  lead,  mercury, 
iodine, PCBs and dioxins. 

Even though the Novel Food Regulation (Regulation (EU) 2015/2283) relates 
to food and not feed, the approval of an algae species as a food (ingredient) can 
indicate that this species might also be suitable for feed. For the approval as a 
novel food, the substance must undergo strict safety assessments. Furthermore, 
an ingredient that is nutritious and safe for humans is likely to offer similar benefits 
for  animal  diets.  This  Regulation,  and  the  informative  tool  “Novel  Food 
Catalogue”, can therefore also be a useful instrument for the algae feed sector. 
However, while there is a correlation, it does not guarantee that all (novel or not 
novel) foods will be suitable for animal feed without further evaluation.  

If  genetically  modified  algae  are  produced  or  used  for  feed  production, 
Regulation  (EC)  No  1829/2003  on  genetically  modified  food  and  feed  is 
applicable.  Procedures  for  the  authorisation  and  supervision  of  genetically 
modified  food  and  feed  are  set  therein.  Furthermore,  it  contains  additional 
provisions for the labelling of genetically modified food and feed. 

5.1.2.  EU Regulations relevant to algae production  

The  Common  Market  Organisation  Regulation  (CMO)  for  fishery  and 
aquaculture  products  (Regulation  (EU)  No  1379/2013)  aims  to  ensure  a 
sustainable and competitive market for fishery and aquaculture products within 
the European Union. It also explicitly covers algae, including seaweeds, which 
are therein defined as fisheries and aquaculture products. With this, the additional 
labelling  requirements  outlined  in  this  regulation,  for  example  regarding  their 
origin  declaration,  also  apply  to  algae.  Furthermore,  it  covers  various  aspects 
such as market access, trade, and the promotion of sustainable practices in the 
sector. 

The Common Fisheries Policy (CFP) (Regulation (EU) No 1380/2013) contains 
rules  for  the  sustainable  management  of  European  fishing  fleets  and  the 
conservation  of  fish  stocks.  Its  objective  is  to  ensure  that  fisheries  and 
aquaculture  operate  ecologically,  economically,  and  contribute 
to  social 
sustainability. It also aims to preserve employment and the economic viability of 
the sector. Catch limits are implemented to help fishers optimise their catch while 
preventing overfishing. Furthermore, specific areas of the sea may be designated 
as closed to fishing activities. 

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The  Alien  Species  Legislation  (Regulation  (EC)  No  708/2007)  governs  the 
introduction and management of alien species, which can include certain types 
of algae. It ensures that non-native algae do not disrupt local ecosystems, setting 
requirements for algae farming when covered under the regulation. 

If  the  feed  operator  intends  to  produce  organic  certified  algae  feed  or  feed 
materials, the Organic Regulation (EU) 2018/848 is a relevant legislation, as it 
sets  standards 
the 
Implementation  Regulation  (EU)  2021/1165  specifies  which  products  and 
substances are allowed to be used in organic production. 

for  organic  production  and 

labelling.  Additionally, 

Furthermore, the cultivation of algae could have several significant environmental 
impacts that may require assessment under the EIA Directive 2011/92/EU. 

The Animal By-Products Regulation (EC) No 1069/2009 can be relevant, and 
it also governs the use of animal by-products in feed. This regulation would apply 
if algae were derived from or processed with animal by-products. 

The  regulations  in  this  and  the  previous  sub-section  should  cover  the  most 
relevant EU regulations regarding the production of algae and algae-containing 
feeds  or  ingredients.  However,  it  is  important  to  be  aware  that  additional 
regulations may apply, depending on individual circumstances, to the production. 

5.1.3.  National regulations regarding algae feed 

There are currently no national regulations in the EU Member States specifically 
governing the use of algae for feed applications. However, certain more general 
national  regulations  may  still  be,  or  may  become,  relevant  under  certain 
circumstances and  could  result  in additional requirements or restrictions  in  the 
respective Member State. 

An example would be the “Lebensmittel- und Futtermittelgesetzbuch”, which is 
the umbrella law for food and feed in Germany. It outlines requirements for the 
use  of  feed  materials.  While  it  does  not  mention  algae  specifically,  “feed 
materials”  also  include  those  derived  from  algae.  Such  general  national 
regulations  may  apply  in  several  countries  and  should  be  considered  as  well. 
Another example is “Fødevareloven”, which is the main law governing food and 
feed safety in Denmark, also covering feed materials, which includes algae for 
feed. In France, the “Code Rural et de la Pêche Maritime” establishes the general 
legal basis and obligations for feed safety, animal health, and the management 
of aquaculture and fisheries. 

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5.1.4.  Regulatory barriers 

To  assess  the  most  pressing  regulatory  issues  pertaining  to  algae  as  feed 
ingredients,  surveys  and  interviews  were  conducted  with  relevant  industry 
stakeholders.  It  was  found  that  there  were  no  immediate  issues  with  the 
regulations themselves, indicating that the regulatory landscape is functioning 
well  with  respect  to  the  production  of  algae-containing  feed  and  algae  feed 
ingredients. 

However, a few challenges in the application of these regulations were mentioned 
during the interviews. These include the complexity of the regulatory landscape, 
the  difficulties  associated  with  using  new  algae  species,  and  the  issue  of 
seaweeds often containing higher arsenic levels than permitted. 

The  most  frequently  raised  concern  was  that  the  regulatory  landscape  is  very 
challenging  to  navigate.  This  complexity  can  be  particularly  burdensome  for 
smaller feed operators, who may lack the resources and expertise to effectively 
interpret and comply with the intricate and fragmented European feed law, which 
is dispersed across various regulations and directives. This situation can lead to 
confusion  and  potential  non-compliance,  hindering  their  ability  to  operate 
effectively in the market. Providing clear guidelines or a public consultation option 
for algal feed operators could be of great benefit for the industry. 

Another aspect that was highlighted relates to the use of new algae species in 
feed.  The  safety  assessments  for  new  species  are  both  costly  and  time-
consuming, creating a barrier to innovation in the feed industry. By including new 
algae  species  in  the  Novel  Food  catalogue,  options  for  their  use  in  feed  can 
expand. These species would have already undergone safety assessments and 
their  suitability  for  human  consumption  would  have  been  assessed.  While  this 
does  not  guarantee  their  suitability  for  feed  applications,  it  still  indicates  their 
potential suitability and compliance for feed, which would be a great advantage 
for the  feed  industry.  Simplifying and  accelerating  the  novel food authorisation 
process would therefore also facilitate faster development within the feed industry 
and enable the exploration of potentially more effective algae species. 

Additionally, a challenge was highlighted regarding the (organic) arsenic limits 
in  algae,  which  is  particularly  relevant  for  seaweeds.  While  inorganic  arsenic 
found in some types of seaweed is highly toxic and can pose adverse health risks 
if  consumed  in  large  amounts  (though  this  is  an  unlikely  scenario),  organic 
arsenic  is  found  naturally  in  several  marine  organisms  and  is  considered  less 
harmful  for  human  consumption  (227),  and  some  consider  it  even  safe  (228). 
However, in other studies, it is argued that there is a significant lack of toxicity 

(227)  Taylor  et  al.  (2016).  “Human  Exposure  to  Organic  Arsenic  Species  from  Seafood,”  The 
Science of the Total Environment 580, 266–82, https://doi.org/10.1016/j.scitotenv.2016.12.113.   
(228) Kim Anderle et al. (2023). “Assessment of EU Regulatory Landscape in a Global Context,”.  

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data  and  human  studies  regarding  the  exposure  risk  of  organic  arsenic (229). 
Some available data suggests that certain components of organic arsenic can be 
metabolised in the human body, indicating a potential for toxicity (230).  

Currently, as stated in Directive 2002/32/EC, the limit for the harmful inorganic 
arsenic is set at a maximum of 2 ppm, whereas the total arsenic limit for algae is 
set at 40 ppm. However, many seaweed meals often exceed this 40 ppm limit 
due  to  higher  concentrations  of  organic  arsenic.  It  was  emphasised  that  the 
current total arsenic limit is very restrictive and hinders the seaweed market for 
feed, indicating the need to reconsider the current limit for total arsenic content in 
algae meals.  However,  any  potential increase  of  the  overall  maximum  limit  for 
total arsenic should only occur once there is certainty about the safety of organic 
arsenic.  Further  research  and  thorough  safety  assessments  regarding  organic 
arsenic should be conducted, filling the gaps and potentially followed by revising 
the current value. 

5.2.  Industry standards and certification 

In addition to legislation, industry standards can further ensure the quality, safety 
and  sustainability  of  algae  and  algae-related  products  to  ensure  harmonised 
application across the EU. This, in turn, creates market trust and supports growth. 
Certifications  are  based  on  adherence  to  certain  standards.  In  the  following 
sections, certifications that may be of interest to algae and algae feed producers 
are  introduced.  Furthermore,  an  overview of  the  standards  from  the  European 
Committee for Standardization (CEN) that may be relevant for algae feed is given. 
Suggestions for new standards are made in Section 5.2.3. 

(229)  Taylor  et  al.  (2016).  “Human  Exposure  to  Organic  Arsenic  Species  from  Seafood,”  The 
Science of the Total Environment 580, 266–82, https://doi.org/10.1016/j.scitotenv.2016.12.113.  
(230)  Taylor  et  al.  (2016).  “Human  Exposure  to  Organic  Arsenic  Species  from  Seafood,”  The 
Science of the Total Environment 580, 266–82, https://doi.org/10.1016/j.scitotenv.2016.12.113.  

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5.2.1.  Certification 

•  EU organic certification: 

Feed that meets the requirements of organic regulations 
can qualify for organic certification. The organic logo can 
only be used if an authorised control body has issued the 
organic  certification  for  a  product.  To  achieve  the 
certification, certain conditions regarding how the product 
must  be  produced,  processed,  transported,  and  stored 
must be met, as outlined in the Organic Regulation (EU) 
2018/848. 
Implementing  Regulation  (EU)  2021/1165 
establishes which products and substances are allowed to 
be used in organic production. Requirements specifically 
for the certification of algae and for the use of algae in feed 
are listed in these regulations. 

Private certification:  

While  the  EU  Organic  certification  is  an  official  label  that  is  government-regulated, 
there are also privately managed certifications. Both certification types – official and 
private  –  play  important  roles  in  ensuring  quality,  safety,  and  sustainability. 
Government-regulated  certifications  provide  a  level  of  assurance  backed  by  legal 
authority,  while  private  certifications  often  offer  specialised  standards  tailored  to 
specific market needs. In the following sections, some private certifications directly or 
indirectly relevant to algae feed are introduced. 

•  ASC-MSC  Seaweed Standard  & ASC  Feed  Standard: 
ASC and the MSC have developed a standard specifically 
for  algae.  It  applies  to  farmed  and  wild  harvested 
seaweeds. The prerequisite for this certification is, that the 
impact  of  the  operations  on  the  surrounding  natural 
environment must be sustainable, and that they operate in 
a  socially  sustainable manner.  Seaweed,  but  also  algae 
oil, can be and has been certified by ASC-MSC (231;232). 
Another relevant certification that was established in 2023 
It  entails 
by 
environmental  and  social  criteria  that  must  be  met  and 
requires 
feed 
ingredients  responsibly  (233;234).  The  use  of  responsibly 
sourced  feed  is  a  requirement  for  farms  that  want  to 
achieve 
responsible 
aquaculture (235). 

their  Feed  Standard. 

to  source  all  major 

feed  producers 

the  ASC 

Standard 

ASC 

the 

for 

is 

(231) ASC-MSC (n.d.). Seaweed Standard. 
(232) Veramaris (n.d.). Spotlight Project: ASC-MSC Certifiation Renewal.  
(233) Veramaris (n.d.). Spotlight Project: ASC-MSC Certifiation Renewal.  
(234) ASC-MSC (n.d.). Seaweed Standard. 
(235) Marine Stewardship Council (2021). “First Algae-Derived Omega-3 Producer Achieves ASC-
MSC Certification,”. Available here.  

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•  MarinTrust: 

Marine  ingredient  production  facilities  can  be  certified 
through the MarinTrust Standard, which enables them to 
showcase their commitment to responsible sourcing and 
sustainable  production.  This  certification  covers  marine 
ingredients such as fish oil, fishmeal, and algae (236). 

•  BAP – Best Aquaculture Practices: 

for 

for 

As  a 
the 
third-party  certification  programme 
aquaculture sector, Best aquaculture Practices (BAP) also 
covers  standards  and  certifications 
the  whole 
production chain, which also includes the feed mill, as well 
as farm, processing, and hatcheries (237). 
For facilities that process or manufacture aquafeeds with 
algae, the Aquaculture Facility Certification for Feed Mills 
can  be  interesting.  This  standard  has  a  focus  on  meals 
including 
from  different  aquatic  sources, 
and  oils 
algae (238). 

•  GLOBALG.A.P.: 

Amongst several aquaculture products, seaweeds can be 
certified by GLOBALG.A.P. The certification is connected 
to  standards 
for  safe  and  responsible  production 
processes.  This  encompasses  the  topics  of  food  safety, 
environment,  human  and  animal  health  and  welfare, 
production processes, and traceability (239). 

•  Other private standards that lead to certification: 

Aside  from  those  certification  options  that  specifically  cover  algae,  several 
other  standards  and  certifications  exist,  which  can  be  interesting  for  (algae) 
feed producers. 

5.2.2.  CEN Standards 

The European Committee for Standardization (CEN) is a European organisation 
that develops and maintains official standards across various sectors, including 
the feed sector. The EU and the European Free Trade Association (EFTA) have 
acknowledged  CEN  officially  as  being  responsible 
for  developing  and 
establishing  standards  at  EU  level.  Development  of  these  standards  may  be 

(236) MarinTrust, “MarinTrust Identity”. Available here. 
(237)  Best  Aquaculture  Practices,  “Who  We  Are  Stewards  of  Aquaculture,”  Best  Aquaculture 
Practices Certification. Available here. 
(238) Global Seafood Alliance, “Feed Mills Standard Issue 3.2,” July 9, 2024.  Available here. 
(239) FoodPLUS GmbH, “Integrated Farm Assurance for Aquaculture,” accessed April 17, 2025, 
Available here. 

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supported  by  standardisation  requests  from  the  European  Commission.  CEN 
standards are primarily aimed at industry stakeholders, providing guidelines that 
help to ensure quality, safety, and interoperability of products and services across 
Europe (240). 

For the application of algae in feed, standards of the committees  CEN/TC 454 
“Algae and algae products” as well as CEN/TC 327 “Animal feeding stuffs” are 
especially relevant. Table 19 and Table 20 in Annex I show a selection of relevant 
standards from these committees.  

5.2.3.  Recommendations for additional new standards 

The  existing  standards,  along  with  those  currently  under  development  but  not 
published yet, cover many important aspects that facilitate the creation of algae 
feed or feed components in a manner compliant with current laws. 

Through  an  investigation  of  these  standards,  an  assessment  of  the  current 
situation,  and  discussions  with  experts (241),  a  few  additional  aspects  were 
identified where the algae feed sector could benefit further from standardisation: 

1)  Claims: While current regulations cover claims for feed, their application 
still leaves room for interpretation. A standard regarding the use of claims 
(e.g.  nutritional,  environmental,  health)  for  algae  and  algae-containing 
feed could be beneficial for the sector. Such a standard would facilitate the 
safe  and  compliant  promotion  of  the  advantages  that  algae-containing 
feed can offer. 

2)  Labelling of origin: A legal requirement related to algae and certain algae 
containing products is the labelling of their origin. A standard on the origin 
of  algae  biomass  can  be  useful.  It  could  cover  appropriate  methods  for 
verifying the origin of algae biomass but also enhance the accuracy and 
reliability of labelling for algae and algae products. It could also be a step 
towards promoting the use of EU-sourced algae. 

3)  Contaminants: Contaminants are a crucial aspect, especially in feed and 
food,  to  ensure  human  health.  Standardisation  of  analytical  detection 
methods  for  contaminants  in  algae  is  recommended,  which  should  also 
include an overview of all known algae contaminants. This standard would 
enhance  the  understanding  of  important  contaminants  and  facilitate 
compliance with legal limits for algae.  

(240) CEN-CENELEC, “About CEN,” CEN-CENELEC, accessed April 17, 2025. Available here. 
(241) Specifically, from members of the European Algae Biomass Association (EABA). 

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4)  Water  management:  With  water  being  a  core  resource  in  algae 
production, a standard on measurements for water management in algae 
cultivation could be useful. This could include guidelines for the reuse of 
water and measurements of water consumption in cultivation sites. This 
could  be  another step  towards  ensuring  sustainable development  in  the 
algae sector, both environmentally and economically.  

5)  Preservation methods: As a legal requirement, the shelf life of the algae 
feed material and products needs to be assessed and labelled. A standard 
regarding recommended preservation methods and storage for algae for 
different end purposes could be useful, guiding stakeholders in search of 
the right preservation approach. Increasing the shelf life can also be a way 
to increase economic and environmental sustainability. 

The  participants  of  the  validation  process  agreed  to  the  recommendation  of 
developing these official standards and found them realistic. 

LCA standardisation 

the  chosen  methods  and  considerations.  However, 

Another  issue  relevant  to  standardisation  that  has  already  been  mentioned  in 
Section 3.1 and Section 3.2 of this report pertains to LCAs. The wide range of 
approaches  for  performing  LCAs  for  algae  feed  is  leading  to  different  results, 
the 
depending  on 
investigation of the standardisation landscape and consultation with experts have 
revealed  that  several  standards  for  LCAs  that  also  relate  to  algae,  including 
product  category  rules  for  algae,  either  already  exist  or  are  currently  under 
development. This progress is expected to lead to more comparable LCAs in the 
future. A selection of existing standards regarding this topic can be found in Table 
21 in Annex I. 

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6.  Market examples 

The application of algae in grower feed is still relatively young. However, what 
was once considered a niche application is now being embraced by an increasing 
number  of  companies.  Several  companies  produce  algae  ingredients  for 
aquafeed,  and  feed  manufacturers  are  incorporating  these  into  their  products. 
The adoption of these feeds in aquaculture is on the rise. 

Regarding the production of algae oil for aquaculture feed, currently two major 
suppliers exist, Veramaris and Corbion: 

Veramaris (DSM & Evonik Joint Venture) 

Veramaris is a leading biotechnology company specialising in the production of 
algae-derived omega-3 oils, primarily for use in aquaculture feed. A joint venture 
between  DSM  and  Evonik,  Veramaris  produces  its  oil  from  natural  marine 
microalgae through a fermentation-based process, eliminating the sole reliance 
on wild-caught fish as a source of EPA and DHA. Its large-scale production facility 
is located in Nebraska, and its headquarters are in the Netherlands. 

Veramaris  is  the  first  –  and  currently  only  –  ASC-MSC  certified  microalgae  oil 
producer for fish and shrimp feeds and has won multiple awards for its algae oil 
as an alternative feed ingredient. The algae oil contains 65% EPA and DHA. The 
product  is  used  by  major  European  feed  producers,  and  the  company  has 
established  several partnerships,  including  collaborations  with  Skretting,  Santa 
Priscila, and Pacific Coral Seafood. 

Veramaris is dedicated to fostering growth that sustains the future for animals, 
people,  and  the  planet.  Its  2024  Sustainable  Development  Report  highlights 
ongoing efforts to reduce the environmental impact of operations while scaling 
production to meet increasing global demand (242).  

Corbion 

Corbions algae oil is used by leading feed manufacturers and is a key ingredient 
in  salmon  feeds  across  Norway  and  other  European  markets.  Corbion  will  be 
presented in more detail below, where they also share their insights on the role 
of algae in aquaculture. 

(242) Veramaris 

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Other companies 

Additionally, several other companies are producing algae oil or algae meal for 
aquaculture,  such  as  MiAlgae  (algae  oil  for  aquaculture;  located  in  the  UK), 
Fermentalg  (algae  protein  concentrate  for  aquaculture;  located  in  France)  or 
Algaevita (omega-3 rich algae meal for aquafeed; located in Slovenia). 

In the following section, three successful industry examples are presented. This 
includes  direct  insights  from  an  algae  ingredient  producer,  an  aquafeed 
manufacturer  utilising  alga,  and  an  aquaculture  company  that  uses  algae-
containing feed. 

6.1.  Example 1: Algae ingredient producer 

Corbion  

Company size 

2,399 employees (full-time equivalent) 

Established in 

1903 

Turnover 

1,288 million € (based on continuing operations) 

Location 

Headquartered in Amsterdam, 13 manufacturing facilities, 8 innovations 
centres and many sales offices across the world. Fermentation-powered 
Algae manufacturing facility: Brazil, operating at industry-leading scale. 

Primary applications of 
algae in the company 

Algae species and 
compounds used 

Our Nutrition business markets algae-based Omega-3 and other lipid 
solutions that are produced in a controlled environment via closed system 
fermentation, harnessing the power of the original source (algae). Our 
Omega-3 ingredients are used in over 2 million MT (2,000 KT) of fish feed 
annually. While Corbion’s initial focus was primarily centred around 
supplying Omega-3 in aquaculture, increasing demand coming from other 
markets is observed, such as pet food and human nutrition.  

Schizochytrium sp. – for our Omega-3 DHA solutions in several formats 
that fit our customers and industry applications, such as biomass, liquid 
suspensions and oils. Corbion’s Omega-3 is produced sustainably using 
renewable energy and cane sugar as feedstock, resulting in a significantly 
lower CO2 impact when compared to alternatives. 

Currently available algae 
products 

We service animal markets (aquaculture, pet and terrestrial) under our 
product line ‘‘AlgaPrime’. Human markets are serviced under ‘AlgaVia’. 

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Corbion  

1)  Where do you see the main benefits and biggest potential of algae in aquafeeds? 

“As  aquaculture  expands  to  meet  rising  global  demand  for  seafood,  the  industry  constantly  searches  to 
develop resilient, sustainable feed strategies that reduce reliance on finite marine resources, which are also 
capped by quotas. With fish oil (FO) supply limited and a growing supply gap of 20  - 40 KT per year, the 
industry urgently needs an alternative. Algae-derived Omega-3 DHA provides a traceable and sustainable 
alternative at scale with stable pricing that strengthens industry growth while safeguarding fish health and 
welfare. 

The key benefits of algae-based Omega-3 DHA in aquafeeds include: 

•  Supply chain resilience: ensuring consistent access to critical nutrients like Omega-3 is essential for 
aquaculture’s long-term viability. Algae-based solutions provide a stable, year-round supply, mitigating 
inevitable FO price and availability fluctuations; 
Food security: our solution directly supports the industry’s ability to scale responsibly while reducing 
pressure on wild fish quotas. Corbion, as one of the world’s biggest suppliers of Omega-3, 
provides  its  algae-based  AlgaPrime™  Omega-3  DHA  for  more  than  2  million  MT  of  feed  annually 
proving its viability as a sustainable, reliable and large-scale alternative ingredient; 

• 

•  Unmatched traceability & purity: our fully traceable supply chain eliminates the risks associated with 
IUU  (illegal,  unreported,  and  unregulated  fishing)  while  our  products  are  free  from  dioxins,  heavy 
metals,  and  PCBs.  Studies  show  that  our  algae-derived  and  land-based  Omega-3  can  reduce 
contaminants in aquafeeds by up to 79%; 
Lower  environmental  footprint:  algae-based  Omega-3  DHA  has  a  30-40%  lower  carbon  footprint 
than  FO,  as  verified  by  ISO-certified  Life  Cycle  Assessments  (LCAs),  supporting  the  industry’s 
decarbonisation efforts; 

• 

•  Performance & scalability: studies confirm that our Omega-3 solution enables high inclusion levels 
without  compromising  feed  conversion  ratios  (FCR)  or  fish  health  and  wellbeing.  Through  ongoing 
investment in production scale and yield improvements, we continue to expand capacity  to meet the 
sector’s growing sustainability needs.” 

2)  What challenges have you encountered in the production of algae ingredients, and if so, 

how did you solve them?  

“Thanks  to  our  successful  capacity-expansion  and  strain  improvement  programmes,  we  managed  to 
develop cost-competitive land-based solutions to satisfy the ever-growing demand of Omega-3. While we 
overcame several challenges during scale-up, we are thankful to the support from our customers in adapting 
our solutions in their feed-manufacturing processes. Continued improvements in scale, strain development 
and  cross  industry  cooperation  have  been  key  enablers  to  break  through.  We  are  proud  that  today  we 
became the world’s leading manufacturer of Omega-3. Annually, our Omega-3 DHA solution is used in more 
than 2 million MT (2,000 KT) of fish feed and all leading aquaculture feed manufacturers make use of our 
solutions. 

Meanwhile, the quantity of certified marine sources is limited. Heavily fluctuating and volatile prices for fish 
oil continue to be a challenge. Contrary to this, our controlled fermentation process for Omega-3 comes with 
stable manufacturing costs and significant benefits in terms of sustainability and quality.” 

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Corbion  

3)  What measures do you take to ensure the sustainability of your algae production? 

“At Corbion, we recognise the urgent need to decouple Omega-3 production from marine ecosystems while 
ensuring a stable, reliable, high-quality supply for the aquaculture and nutrition industries. Our algae-based 
Omega-3 DHA is a key enabler of this transition, offering a 30-40% lower carbon footprint compared to 
traditional fish oil, as demonstrated by our ISO-certified Life Cycle Assessment (LCA). 

Our production system is designed for maximum resource efficiency and circularity: 

•  Circular, co-located production: our facility is situated in the middle of sugar cane fields and 

integrated with a sugar mill, ensuring a fully circular system. Algae are fed with locally sourced 
sugar, while bagasse (a by-product of sugar cane processing) serves as a renewable energy 
source, powering both the sugar mill and our algae facility; 

•  Water stewardship: Water used in production is repurposed for irrigating sugar cane fields, 

minimising consumption and contributing to responsible water management; 
Zero marine impact: Unlike fish oil production, our closed-system fermentation ensures zero  

• 

impact on marine biodiversity and no reliance on wild fish stocks, preserving ocean ecosystems; 

•  Deforestation-free supply chain: While our land-use footprint is already small, our inputs are 

verified deforestation-free since 2006; 

•  Continuous innovation: We are advancing higher-yield algae strains and optimising 

production efficiencies to further reduce environmental impact while maintaining consistent, high-
quality Omega-3 output. 

By  eliminating  pressure  on  marine  resources  and  delivering  a  traceable,  scalable,  and  sustainable 
alternative  to  fish  oil,  Corbion’s  algae-based  Omega-3  DHA  directly  supports  EU  priorities  on  ocean 
health, food security, and climate action.” 

4)  What feedback have you received from feed or aquaculture producers regarding the use of 

your algae products? 

“Our customers appreciate our high quality and algae-based Omega-3 solutions that we offer at large scale 
to them as part of resilient and sustainable feed strategies to meet growing demand.  

They see us as a partner facilitating further growth. Next to the real-life experience of our customers, studies 
have confirmed that our product enables high inclusion levels without significant impact on FCR, fish health 
and welfare.” 

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5)  Currently, algae oil is especially successful within the algae products in aquafeeds. Do you 

see similar potential in other algae-based ingredients for aquafeed in the future?  
(e.g. algae protein, whole algae biomass, algae additives/bioactive compounds, …) 

“As  aquaculture  expands  to  meet  rising  global  demand  for  seafood,  the  industry  constantly  searches  to 
develop resilient, sustainable feed strategies and reduced reliance on finite marine resources. This can be 
reached through the innovative use of alternative ingredients and trimmings. Increased flexibility makes it 
easier to achieve sustainable results. 

At Corbion we are committed to unleashing the power of algae fermentation, and we work closely with the 
aquaculture  feed  industry  to  provide  the  best  possible  solutions,  using  advanced  technology  to  carefully 
match the nutrients in algae with other ingredients.  

Algae hold immense potential to enhance the overall nutritional profile of fish feed. In the near term, we see 
other  fatty  acids  and  carotenoids  as  the  most  promising  areas  to  focus  on  for  continued  innovation  and 
growth.” 

6) 

In your opinion, what does the EU algae-feed sector really need to thrive? 

“To  incentivise  investments  and  support  sustainable  growth  and  competitiveness  of  the  EU  algae-
ingredients  sector,  we  believe  that  the  introduction  of  a minimum  inclusion  rate  for  algae-ingredients 
could contribute – like blending mandates that have been introduced for ethanol or biodiesel with gasoline. 
Such  a  policy  approach  would  create  a  structured  demand  for  algae-derived  Omega-3  DHA  and  other 
innovative algae-based solutions, fostering both market stability and expansion. 

Why is this critical? 

1.  Sustainability  &  environmental  benefits:  algae-based  Omega-3  DHA  provides  a  renewable  and 
sustainable alternative to traditional fish oil, enabling the growth of aquaculture while reducing pressure 
on marine ecosystems and aligning with the EU’s Green Deal and Clean Deal objectives. A blending 
mandate would drive the adoption of sustainable practices across aquaculture, directly contributing to 
biodiversity conservation and climate neutrality goals. 

2.  Market  development  &  competitiveness:  establishing a minimum  inclusion  rate  would  incentivise 
investments in algae production infrastructure and innovation. Such mandates provide businesses the 
confidence to scale up operations, resulting in economies of scale, technological advancements, and 
enhanced competitiveness on a global stage. Algae-based Omega-3 is already available at large scale 
and at competitive prices dependent from increasingly volatile fish oil prices. 

3.  Industrial decarbonisation: as a renewable alternative to fish oil, algae-based products can reduce 
the  carbon  footprint  of  aquaculture.  Minimum  inclusion  rates  would  drive  the  adoption  of  this 
decarbonisation solution, contributing to the New Clean Deal’s aim of achieving climate-neutral and 
resource-efficient industries. 

4.  Technological progress: for algae-based products, the inclusion rate policy can spur research and 
development  by  setting  clear  market  targets.  Encouraging  innovation  in  strain  selection,  production 
processes, and end-use applications could unlock untapped potential for this technology, benefiting 
the wider bioeconomy. 

5.  Regulatory  harmonisation:  simplified  market  access  and  clear  EU-level  mandates  would  enable 
algae-based products to gain faster acceptance, reducing market entry barriers. This clarity is essential 
for aligning the interests of producers, aquaculture stakeholders, and policymakers. 

In conclusion, a minimum inclusion rate would act as a catalyst for the algae-ingredient sector, ensuring that 
it  achieves  its  sustainability  and  growth  potential  while  positioning  Europe  as  a  global  leader  in  algae 
ingredients sector innovation.”  

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6.2.  Example 2: Feed producer 

Aller Aqua  

Company size 

650 employees 

Turnover 

274 million € 

Location 

Denmark, Germany, Poland, Serbia, China, Egypt, and Zambia  
(with sales active in 70+ countries) 

In which form do you use 
algae in aquafeed? 

What are the target fish 
species that you produce 
algae-containing feed for? 

We are currently using algae oil and some feed additives in our feeds. 

The main target is marine species with high EPH/DHA requirements. 

1)  Where do you see the main benefits and biggest potential of algae in aquafeeds? 

“-   Specific nutritional properties (EPA/DHA); 

-  Reduced dependency on wild fish (FFDR) and other marine ingredients; 

- 

- 

Important and interesting for us to work on new and sustainable resource; 

Increased concern about micro plastic and other contaminants in more traditional ingredients”  

2)  What challenges have you encountered in the production of algae feed, and if so, how did 

you solve them?  

“We primarily use algae oil or algae-derived additives in our feed production. The amount in use is small, 
so there are no limitations in relation to volume. Sometimes it becomes a price limitation, if the products 
are too expensive for our recipes to take it.” 

3)  What measures do you take to ensure the sustainability of your feed and how do you see 
the role of algae-feed in this regard? Would you encourage the inclusion of algae as an 
aspect in sustainable feed certification? 

“We carefully select our raw materials, considering their impact on the environmental footprint of our final 
products. Algae present several significant benefits, including reduced water and land requirements for 
their  production.  However,  for  these  advantages  to  be  fully  realised,  there  is  a  need  to  scale  up  their 
cultivation and facilitate commercial production and distribution.” 

4)  Currently, algae oil is especially successful within the algae products in aquafeeds. Do 
you  see  similar  potential  in  other  algae-based  ingredients  for  aquafeed  in  the  future?  
(e.g. algae protein, whole algae biomass, algae additives/bioactive compounds, …) 

“If the product range is available in the form of algae protein concentrate, algae meal, and algae-based 
functional additives, then the potential is significantly higher, not only in the aquafeed sector but also across 
the entire range for other animal farming sectors and the nutraceutical industry.” 

5)  What  are  the  cost  implications  of  using  algae  in  your  feed  compared  to  traditional 

ingredients?  

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Aller Aqua  

“Currently, incorporating algae-derived products, like oil or functional additives, is more expensive than 
using conventional ingredients.  

However, the price comparison for algae oil is influenced by fluctuations in fish oil prices, which can be 
affected by lower fish catch during the fishing season.” 

6)  What innovations or advancements in the EU algae-feed sector would you like to see in 

the future? 

“The algae industry should strategically advance toward the production of algae oil, high-protein algae 
meal,  and  functional  additives.  By  focusing  on  these  areas,  the  algae  industry  can  enhance  its  role  in 
various markets, including nutrition, food production, and the nutraceutical sector.  

The algae industry should focus on optimising and up-scaling production using the latest advancement in 
production technology.” 

6.3.  Example 3: Aquaculture producer 

Cermaq 

Company size 

2,850 employees 

Established in 

In 1995 as Statkorn Holding, a spin-off from Statens Kornforretning. 
The company changed its name to Cermaq in 2001 

Location 

Norway, Chile and Canada 

In which form do you use 
algae in aquafeed? 

Algae oil 

What are the target fish 
species that you use algae-
containing feed for? 

Atlantic salmon and Pacific salmon 

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1)  Where do you see the main benefits and biggest potential of algae in aquafeeds? 

“Algae oil has a nice potential in aquafeeds. The main benefit, of course, lies in the high content of omega-
3 fatty acids, particularly EPA and DHA. These are essential for fish health and performance. When you 
include  algae  oil  in  the  feed,  it  provides  those  important  fatty  acids  that  are  crucial  for  better  immune 
function, enhanced growth, and improved overall health. This translates to better performance in the fish, 
which is key for both the industry and consumers. 

Another major benefit is sustainability. As we know, the aquaculture industry has historically relied heavily 
on marine raw materials, like fishmeal and fish oil. Algae oil offers a sustainable alternative, helping to 
reduce our dependency on wild-caught fish. This is crucial for building a more resilient and less vulnerable 
supply  chain.  Reducing  this  dependency  on  marine  resources  also  mitigates  risks  related  to  supply 
disruptions, environmental concerns, and fluctuating market condition. 

We  are also  looking at  the  potential  to  widen  the raw  material  basket.  Right now,  our  industry  is  quite 
dependent some ingredients, which can make the supply chain vulnerable. If we expand the raw materials 
basket, we can build a more resilient and flexible system that is less prone to disruptions. Diversification 
ensures we are not overly dependent on a single source, which is crucial for long-term stability.”  

2)  What measures do you take to ensure the sustainability of your fish production? 

“Sustainability is a key focus for Cermaq, and we take several measures to ensure our fish production is 
responsible and efficient. 

First, we prioritise sourcing sustainable feed ingredients to reduce our dependence on any raw materials. 
This includes a variety of alternative ingredients ensuring that our feed formulations are both nutrient-rich 
and  sustainable.  We  also  adhere  to  our  General  Supplier  Code  of  Conduct,  which  sets  minimum 
sustainability  standards  across  our  entire  supply  chain,  ensuring  ethical  practices  and  responsible 
sourcing. Additionally, our Feed Supplier Specific Code of Conduct ensures that our feed suppliers meet 
high standards in areas like marine ingredient sourcing, traceability, and food safety. 

Within our farms, we focus on resource efficiency—optimising water, energy, and feed use to minimise 
waste and emissions. We also prioritise fish health to enhance disease resistance and resilience, which 
leads to better performance with less environmental impact. 

Certifications also play a key role in our sustainability strategy. Cermaq is committed to meeting the highest 
industry standards, and many of our operations are certified under ASC (Aquaculture Stewardship Council) 
and BAP (Best Aquaculture Practices). These certifications ensure that we meet rigorous environmental, 
social,  and  animal  welfare  criteria,  and  they  provide  third-party  verification  of  our  commitment  to 
responsible aquaculture. 

Transparency and traceability are key to our approach, allowing us to provide full visibility into our supply 
chain, which helps build trust with consumers and stakeholders. Ultimately, by following these codes and 
best  practices,  we  aim  to  create  a  sustainable,  resilient  production  system  that  benefits  both  the 
environment and the industry.” 

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3)  What innovations or advancements in the algae-feed sector would you like to see in the 

future? 

“Looking ahead, there are several exciting innovations we would love to see in the algae-feed sector.  

First, I think there is potential for improving the efficiency and scalability of algae cultivation. Scalability is 
key  in  the  algae-feed  sector,  especially  as  the  demand  for  sustainable  ingredients  grows  with  the 
aquaculture  industry.  By  improving  scalability,  we  can  reduce  costs  and  ensure  a  consistent  supply  of 
algae-based  feed  ingredients  to  meet  the  needs  of  a  growing  business  like  ours.  Advancements  in 
cultivation techniques will be crucial for achieving this, helping us make algae oil a more accessible and 
cost-effective resource for sustainable aquaculture. 

Additionally, increasing the efficiency of algae production—both in terms of yield and resource use—will 
be a key driver for broader adoption in the aquafeed industry. 

Second,  we  would  like  to  see  more  research  and  development  into  algae  species  that  can  provide  a 
broader range of nutrients. While we are seeing great success with omega-3 fatty acids like EPA and DHA, 
there is a growing interest in algae that can offer additional bioactive compounds—things like antioxidants, 
vitamins, and other essential nutrients. The ability to tailor algae strains to meet the specific nutritional 
needs of different fish species would be a significant leap forward. 

Finally, I think there is an opportunity for greater innovation in feed processing technology. By improving 
how  algae  and  other  feed  ingredients  are  processed  and  incorporated  into  the  final  product,  we  could 
enhance the bioavailability of the nutrients, ensuring that the fish get the maximum benefit. This would 
help optimise performance, reduce waste, and further improve sustainability. 

I am excited to see how the algae-feed sector evolves, especially as we continue to innovate in areas like 
efficiency, nutritional profiles, and sustainable production methods. These advancements will be crucial in 
supporting the growing demand for sustainable aquaculture.” 

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7.  Future trends 

7.1.  Global  and  EU  status  of  fish-based  ingredients  in 

aquafeeds 

Fishmeal  and  fish  oil  are  both  common  ingredients  in  aquafeeds.  Fishmeal  is 
derived from small fatty fish species such as anchovy, sprat or herring. Fish oil is 
extracted during the processing of these fatty fish into meal. Globally, 17 million 
tonnes,  accounting  for  22%  of  the  world  landings  of  aquatic  animals,  were 
processed into fishmeal and fish oil for non-food purposes in 2022. Approximately 
21 kg of fishmeal and about 2 to 6 kg of fish oil can be produced from 100 kg of 
raw material (243). 

Based  on  the  average  production  over  the  past  ten  years,  it  is  estimated  that 
around  4.9  million  tonnes  of  fishmeal  are  produced  annually.  The  global 
production  of  fish  oil  ranges  from  0.8  to  1.3  million  tonnes  per  year.  Total 
production  of  fishmeal  and  fish  oil  can  fluctuate  significantly  depending  on  the 
year,  largely  due  to  climatic  events  such  as  the  El  Niño  Southern  Oscillation, 
which affects the catchability of key species like anchovy (244;245). 

While  the  quantity  of  wild-caught  fish  for  producing  fish  oil  and  fishmeal  has 
decreased over the past decade, the share of by-products from fish processing 
has steadily increased, as shown in Figure 2 of Chapter 2.1.1. These by-products, 
such  as  cut-offs  or  offal,  can  originate  from  wild-caught  fish  or  aquaculture 
processing. 

In  2021,  87%  of  the  globally  produced  fishmeal  was  used  in  aquafeeds,  with 
China  being  the  largest  consumer.  During  the  same  year,  75%  of  the  globally 
produced fish oil, amounting to approximately 670,000 tonnes, was also utilised 
in  aquafeeds.  Of  the  total  fishmeal  produced,  approximately  10%  was  used  in 
aquafeeds destined for Europe, while 39% of the global fish oil production was 
used in European aquaculture (246). 

(243) EUMOFA (2023). Fishmeal and Fish Oil. Available here. 
(244) EUMOFA (2023). Fishmeal and Fish Oil. Available here. 
(245) FAO (2024). The State of World Fisheries and Aquaculture 2024 – Blue Transformation in 
action. Rome, https://doi.org/10.4060/cd0683en. 
(246) EUMOFA (2023). Fishmeal and Fish Oil. Available here. 

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Figure 8 – World fishmeal use by sector 

Source: EUMOFA, 2023 (247). 

Figure 9 – World fish oil use by sector 

Source: EUMOFA, 2023 (248). 

According  to  the  EUMOFA  report  on  fishmeal  and  fish  oil,  in  2023,  the  EU 
produced  between  370,000  and  520,000  tonnes  of  fishmeal  and  between 
120,000  to  190,000  tonnes  of  fish  oil,  accounting  for  10-15%  of  global 
production (249). 

The main suppliers of fishmeal to the EU are Morocco, Peru, Iceland, Norway, 
and South Africa. Norway and Peru contribute not only fishmeal but also provide 
about half of the fish oil imported into the EU (250). 

In 2022, the export value of fishmeal reached its lowest point in a decade, while 
fish oil experienced its second lowest value during the same period. These low 

(247) EUMOFA (2023). Fishmeal and Fish Oil. Available here.  
(248) EUMOFA (2023). Fishmeal and Fish Oil. Available here. 
(249) EUMOFA (2023). Fishmeal and Fish Oil. Available here. 
(250) EUMOFA (2023). Fishmeal and Fish Oil. Available here. 

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fish oil exports were primarily due to the strong increase in the export prices of 
fish oil to countries outside the EU compared to 2021 (251). 

Table 11 – Fishmeal and fish oil production in the EU, including quantity and 
value of imports and exports in 2022. 

EU production amount per year [tonnes] 

370,000 to 520,000 

120,000 to 190,000 

Fishmeal 

Fish oil 

EU import in 2022 

Amount [tonnes] 

247,234 

189,900* 

Change from 2021 to 2022 

11% increase 

5% decrease 

Total value [Euro] 

403 million 

500 million 

EU export in 2022 

Amount [tonnes] 

161,245 

141,591 

Change from 2021 to 2022 

13% decrease 

12% decrease 

Total value [Euro] 

298 million 

375 million 

EU total consumption in 2022 [tonnes] 

450.000 

203.000* 

Source: EUMOFA, 2023. 
*Calculation based on the EUMOFA report (2023). 

According  to  the  EUMOFA  fishmeal  and  fish  oil  report  from  2023,  the  EU’s 
consumption  of  fishmeal  was  450,000  tonnes  in  2022.  Based  on  the  above-
mentioned  average  EU  production  of  fish  oil  and  considering  the  import  and 
export  figures  of  2022,  the  amount  of  fish  oil  consumed  in  the  EU  can  be 
calculated to be approximately 203,000 tonnes. 

It is also important to consider that most, but not all, fishmeal and fish oil is used 
in aquaculture. The EUMOFA report states that in 2021, 87% of the worldwide 
produced fishmeal and 75% of the fish oil was used in aquaculture. Projecting 
those  figures  to  the  consumption  amounts  for  the  EU,  the  amount  used  for 
aquaculture feed in the EU would equal about 390,000 tonnes of fishmeal 
and  around  152,000  tonnes  of  fish  oil  (for  fish  oil:  a  variation  of  +/-17% 
depending on the annual production levels in the EU). 

(251) European Commission: Directorate-General for Maritime Affairs and Fisheries & EUMOFA. 
(2023). Der  EU-Fischmarkt:  Ausgabe  2023.  Publications  Office  of 
the  European 
Union. https://data.europa.eu/doi/10.2771/704. 

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Based on Table 11, the EU imports significantly more fishmeal and fish oil than it 
exports. Additionally, it is evident that a larger share of by-products contributes to 
the  production  of  fishmeal  compared  to  fish  oil.  Given  the  EU's  significant 
consumption of fish oil from global production, alongside the lower reliance on 
by-products for fish oil production, it is crucial to consider reducing the use of fish 
oil  in  aquafeeds  consumed  within  the  EU. This reduction  would promote more 
sustainable  practices  by  alleviating  pressure  on  marine  resources  and 
encouraging greater utilisation of alternative or by-product-based sources. 

7.2.  Historical  market 
developments 

trend  data  and  expected 

7.2.1.1.  Developments in aquaculture and fisheries 

Referring  to  the  production  figures  for  2022,  the  2024  report  of  Food  and 
Agriculture  Organization  of  the  United  Nations  (FAO)  highlighted  a  significant 
milestone: “World fisheries and aquaculture production has hit a new high, with 
aquaculture  production  of  aquatic  animals  surpassing  capture  fisheries  for  the 
first time”. This marks a major shift in the global seafood industry, emphasising 
the  importance  of  aquaculture  in  meeting  global  food  demands.  This  key 
message should also draw attention to the urgent need to enhance sustainable 
fish farming practices, with a focus on reducing pressure on wild fish stocks and 
minimising the environmental footprint of feed ingredients. 

Of  the  185  million  tonnes  of  produced  aquatic  animals  in  2022,  51%  was 
contributed by aquaculture. The aquaculture sector has experienced continuous 
growth in the past, and this trend is expected to continue in the coming years. 
According  to  FAO’s  predictions,  global  aquaculture  production  is  expected  to 
increase by 17% by 2032 compared to 2022, and EU aquaculture production by 
8.9%. On the other hand, capture fisheries production has plateaued for around 
four decades, and this trend is expected to continue if we adhere to preserving 
our wild stocks (Figure 10). 

influenced  by  several  key 

The projected growth rate of the aquaculture sector for the period 2022 to 2032 
will  be 
the  broader 
implementation and enforcement of environmental regulations, reduced quantity 
and quality of water and suitable aquaculture locations, the increasing impact of 
aquatic  animal  diseases  in  intensive  aquaculture,  and  lower  productivity 

factors.  These 

include 

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gains (252). These challenges highlight the need for innovations and sustainable 
solutions to support continued growth in the sector.  

Figure 10 – World fisheries and aquaculture production of aquatic animals 
1980-2032 

Source: FAO, 2024 (253). 

7.2.1.2.  Developments for fish oil and fishmeal 

Historical data of worldwide fish oil and fishmeal production shows a significant 
decrease until the mid-2000s. Between 2001 and 2011, an average of 5.5 million 
tonnes of fishmeal was produced, while the average in the subsequent decade 
was only around 4.9 million tonnes. Despite the decrease of the production from 
whole fish, it has been possible to maintain a relatively stable production due to 
the increased use of by-products since the mid-2000s. The production amounts 
stabilised  at  around  5  million  tonnes  of  fishmeal  and  1  million  tonnes  of  fish 
oil (254). The development for fishmeal is shown in Figure 11. 

(252) FAO (2024). The State of World Fisheries and Aquaculture 2024 – Blue Transformation in 
action. Rome, https://doi.org/10.4060/cd0683en 
(253) FAO (2024). The State of World Fisheries and Aquaculture 2024 – Blue Transformation in 
action. Rome, https://doi.org/10.4060/cd0683en 
(254) FAO (2024). The State of World Fisheries and Aquaculture 2024 – Blue Transformation in 
action. Rome, https://doi.org/10.4060/cd0683en 

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Figure 11 – World fishmeal production 

Source: FAO, 2024 (255). 

The  aquaculture  growth  and  demand  for  fishmeal  and  fish  oil  led  to  a  price 
increase  as  production  decreased.  There  has  been  a  strong  imbalance  in  the 
supply and demand dynamics in the past few years, especially for fish oil. From 
2011 until 2023, the prices of fish oil increased by around 181% while fishmeal 
prices  increased  by  about  67%.  This  development  also  led  to  lower  inclusion 
rates in aquaculture feeds (256).  

The substantial increase in fish oil prices between 2021 and 2023 was driven by 
several  factors.  Peru,  which  is  the  world’s  largest  fish  oil  producer  from 
anchovies, implemented fishing restrictions to preserve anchovy, particularly due 
to  a  high  presence  of  juveniles  as  a  result  of  the  impacts  of  El  Niño.  These 
restrictions  led  to  lower  catches,  reducing  the  global  supply,  which  in  turn 
increased  the  prices  of  fish  oil.  The  effect  on  fish  oil  prices  was  particularly 
noticeable,  as  there  is  currently  no  widely  used  alternative  providing  EPA  and 
DHA, which is needed for many fish species to stay healthy, and it is also used 
for food supplements (257). Furthermore, the ongoing disruptions in global supply 
chains due to the COVID-19 pandemic and inflationary pressures in 2022 further 
exacerbated the price increases (258). 

(255) FAO (2024). The State of World Fisheries and Aquaculture 2024 – Blue Transformation in 
action. Rome, https://doi.org/10.4060/cd0683en 
(256) EUMOFA (2023). Fishmeal and Fish Oil. Available here. 
(257) Just Vitamins (n.d.) “Why Have Fish Oils Increased in Price So Much?". Available here. 
(258) Barreiro, L. (2022). “Aquafeed Outlook 2023: Prices, Novel Ingredients and Feed Efficiency". 
Available here. 

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Figure 12 – Fishmeal and fish oil prices in Europe 

Source: EUMOFA, 2023 (259). 

For the EU aquaculture production, a growth of 8.9% is projected from 2022 to 
2032, while global aquaculture production is estimated to increase by 17% during 
the same period (260). 

This substantial growth in aquaculture production creates a significant increase 
in demand for aquafeed. However, the FAO anticipates that fishmeal production 
will  increase  by  only  9%  and  fish  oil  by  12%  between  2022  and  2032.  It  is 
assumed, that this increase will mostly be archived by utilising whole fish grown 
in capture fisheries combined with by-products. The share of fishmeal sourced 
from by-products is projected to grow from 27% to 30% between 2022 to 2032, 
while the proportion of fish oil from by-products is expected to stay steady at about 
57% (261).  It  should  be  noted  that  the  current  by-product  inclusion  rates  vary 
across different literature sources.  

Given the projected growth in aquaculture production and the limited increases 
in  fishmeal  and  fish  oil  supply,  a  supply  gap  is  expected  in  meeting  the  feed 
demands of the expanding industry. 

Regarding the EU’s demand, the global increase in fish-based ingredients might, 
in theory, help to close the apparent supply gap for the EU. However, given that 
the EU must compete with other regions, and considering that global aquaculture 
production  is  projected  to  grow  even  more  robustly,  driving  higher  overall 

(259) EUMOFA (2023). Fishmeal and Fish Oil. Available here. 
(260) FAO (2024). The State of World Fisheries and Aquaculture 2024 – Blue Transformation in 
action. Rome, https://doi.org/10.4060/cd0683en. 
(261) FAO (2024). The State of World Fisheries and Aquaculture 2024 – Blue Transformation in 
action. Rome, https://doi.org/10.4060/cd0683en. 

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demand, not all the additional supply will be allocated to the EU. Consequently, 
the  actual  magnitude  of  the  gap  will  heavily  depend  on  how  this  increased 
production  is  distributed  on  an  international  scale.  Market  realities  such  as 
competition, allocation dynamics, and pricing pressures are likely to ensure that 
the EU faces a noticeable shortfall in the availability of fishmeal and fish oil for 
aquafeed. 

7.3.  Potential  of  algae-based  ingredients  to  replace 

fishmeal and fish oil in aquafeeds 

As  the  demand  for fish  oil  and  fishmeal increases  alongside  the growth  of  the 
aquaculture  sector,  it  is  crucial  to  identify  solutions  that  can  address  the 
anticipated  supply  gap  while  also  reducing  reliance  on  unsustainably  sourced 
fish-based ingredients, thereby alleviating pressure on marine ecosystems. This 
calls for the exploration of alternative sources, one of which is the use of algal 
ingredients, which have the potential to serve as a viable and more sustainable 
option. 

Obtaining precise figures on the current availability and usage of algal ingredients 
in  aquafeeds  is  challenging,  as  the  industry  rarely  discloses  this  information 
publicly.  Consultations  with  industry  stakeholders  suggest  that  the  average 
inclusion rate of algal ingredients in total feed is currently around 1%, consisting 
primarily of algae oil (2025). 

The global market for EPA and DHA omega-3 reached a value of USD 1.58 billion 
in 2021, with a total volume of 115,758 metric tonnes. Within this market, algae 
oils accounted for approximately 2,034 tonnes – around 1.8% of the volume and 
15% of the total market value (262). 

However,  depending  on  the  source  used,  these  estimates  can  vary  greatly. 
Glencross  et al.  estimated  that algal oils  contributed  already  for approximately 
12,000 tonnes of EPA and DHA globally in 2023 (263). 

In Chapter 2.3.1, detailed figures on the current algae market are provided, along 
with projections for its growth, including species specific figures. 

(262) CEVA (2024). Report of the current algae industry in Europe. Available here. 
(263) Glencross, B. D., Bachis, E., Betancor, M. B., et al. (2024). Omega-3 Futures in Aquaculture: 
Exploring  the  Supply  and  Demands  for  Long-Chain  Omega-3  Essential  Fatty  Acids  by 
Aquaculture  Species. Reviews 
in  Fisheries  Science  &  Aquaculture, 33(2),  167–216. 
https://doi.org/10.1080/23308249.2024.2388563 

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7.3.1.  Algae meal for the replacement of fishmeal 

Can algae meal become a substitute for fishmeal in the near future? 

Fishmeal has historically been the primary protein source in aquafeeds, valued 
for  its  high  protein  content,  essential  amino  acids,  and  digestibility.  However, 
increasing  prices  and  sustainability  concerns  have  prompted  the  search  for 
alternative ingredients such as microalgae meals and insect meals. Some algae 
have a remarkably high protein content and a suitable amino acid profile, making 
them ideal candidates to replace fishmeal in aquafeeds.  

Feed  industry  experts  believe  that  phototrophic  algae  species  hold  significant 
potential  for  use  in  aquafeeds.  They  expect  that  within  the  next  5  years,  an 
inclusion level of approximately 3% algae meal will be possible in aquafeed. 
However, it is unlikely that algae meal will soon become the primary substitute to 
fishmeal,  as  current  processing  technologies  have  not  yet  matured  to  support 
high  inclusion  levels.  While  some  fishmeal  protein  may  be  replaced,  algae 
biomass is more likely to be incorporated as a functional ingredient – for example, 
to provide potential benefits from other components like pigments or beta-glucan, 
aiming to  improve fish  health  and  quality.  Further technological  advancements 
and  additional  research  are  essential  for  algae-based  ingredients  to  become 
competitive  with  fishmeal  or  other  alternatives  in  terms  of  both  cost  and 
performance.  Some  options  for  improvement  are  examined  more  closely  in 
Section 7.4.2. 

Forecast for the replacement of fishmeal with algae meal 

The quantity of fish meal used for aquaculture feed in the EU was calculated to 
be about 390,000 tonnes in 2022. Based on an expected total growth of 8.9% in 
the EU aquaculture sector between 2022 and 2032, as projected by the FAO, an 
increase of around 7.1% can be calculated for 2030. This would translate into a 
projected  demand  of  roughly  418,000  tonnes  of  fishmeal  per  year  for  EU 
aquaculture feed by 2030, assuming no changes in feed composition. 

Stakeholders  have  highlighted  that  there  was  no  significant  inclusion  of  algae 
meal in aquafeeds before 2022. Calculating with the estimate of a 3% inclusion 
rate within the next 5 years (until 2030), the requirement of algae meal for EU 
aquaculture feed could be 12,500 tonnes, resulting in a replacement of an 
equal amount of fish meal by 2030. 

While most stakeholders mentioned that a forecast for the algae feed sector for 
more  than  5  years  would  be  very  vague,  some  estimated  that  by  2040,  an 
average inclusion of 6% algae meal could be reached. 

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7.3.2.  Algae oil for the replacement of fish oil 

Can algae oil become a substitute for fish oil in the near future? 

Fish oil is rich in omega-3 long-chain polyunsaturated fatty acids, particularly EPA 
and DHA. The current inclusion level of fish oil in the feeds of carnivorous fish 
species like salmon and trout is approximately 10% (see Figure 1 in Chapter 2.1 
on feed composition). Algae oil is one of few alternative sources of EPA and DHA 
and has the potential to replace fish oil to a significant extent in aquafeeds (264).  

Based  on  several  reports,  consultations  with  industry  stakeholders,  and  as 
concluded in the MCA in Chapter 3.1, it would be possible to replace up to 100% 
of fish oil with algae oil in aquaculture feed. However, it is not expected that such 
a high inclusion level is realistic in the coming years, as explained in the earlier 
chapters. Even in the more distant future, it is highly likely that fish oil will continue 
to  be  used  alongside  algal  ingredients  in  aquafeed.  However,  as  outlined  in 
earlier  chapters,  such  a  high  inclusion  level  is  not  considered  realistic  in  the 
coming years. Even in the more distant future, it is highly likely that fish oil will 
continue to be used alongside algal ingredients in aquafeed. Nevertheless, these 
components  should  be  sourced  sustainably,  including  from  by-products  of 
aquaculture  processing  and  responsibly  harvested  forage  fish.  According  to 
aquaculture feed producers and experts in the field, an average inclusion level 
of  5%  algae  oil  could  be  achievable  within  the  next  five  years.  They  further 
estimate that at this inclusion rate, approximately two-thirds of the total fish 
oil content in feed could be replaced. 

Forecast for the replacement of fish oil with algae oil 

It was calculated that approximately 152,000 tonnes of fish oil were used in 2022 
in EU’s aquafeed. Furthermore, the FAO estimates that the aquaculture sector 
will grow by 8.9% from 2022 to 2032. Assuming a linear growth rate, about 7.1% 
increase in aquaculture could take place by 2030. Not considering a change in 
feed composition, this would result in the requirement for 163,000 tonnes 
of fish oil per year in 2030. 

With the assumption that incorporating 5% algae oil into aquafeed could replace 
about two-thirds of the total required fish oil, approximately 109,000 tonnes of 
fish oil could be replaced with algae oil by 2030. It is important to note that, 
according to the interviewed stakeholders, the replacement ratio of fish oil with 
algae oil is not 1:1, as the EPA and DHA level in algae oil is usually higher, but 
rather  2:3,  meaning  that  to  replace  109,000  tonnes  of  fish  oil,  a  total  of  about 

(264) EUMOFA (2023). Fishmeal and Fish Oil. Available here. 

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73,000 tonnes of algae oil would be required by 2030 at a 5% inclusion rate 
in aquafeed in the EU. 

Although no precise figures regarding the current average inclusion of algae oil 
exist,  stakeholders  estimated  that  approximately  1%  is  currently  included  in 
aquafeed,  primarily  achieved  during  the  recent  years.  It  should  also  be 
acknowledged  that  by  2022,  small  amounts  of  algae  oil  had  already  been 
included in aquafeeds. However, due to the rough estimates on which this data 
is  based,  these  earlier  inclusions  are  not  factored  into  the  calculation,  as  they 
would only have made a relatively minor impact. Therefore, for this calculation, it 
was assumed, that the estimated 1% inclusion was achieved between 2022 and 
2025. This leaves a requirement for an additional 4% inclusion, which would 
necessitate approximately an extra 58,000 tonnes of algae oil per year by 
2030.  It  is  important  to  note  that  the  EU's  average  fish  oil  consumption  was 
provided  as  a  range  with  a  variability  of  approximately  ±17%  around  the 
average  value  used  in  these  calculations  (see  Table  11).  Consequently,  the 
estimated demand for algae oil based on this average may also vary within that 
range. Additionally, the fact that the current inclusion rates are rough estimates 
should be considered when making future projections. 

The calculated numbers were discussed with producers of algae and algae oil. 
They found these figures realistic; however, it is important to note that, while the 
method  and  sources  used  for  the  calculations  were  as  requested,  they 
recommended  calculating  the  values  for  fish  oil  and  algae  oil  based  on  the 
amounts  of  EPA  and DHA.  This approach may provide  more accurate  results, 
particularly  given  the  variability  in  the  concentrations  of  these  targeted 
compounds, especially in algae oil. 

During stakeholder interviews, it was mentioned that a forecast for algae inclusion 
for any time beyond five years into the future would be very difficult and unreliable. 
However,  some  anticipated  that  by  2040,  a  total  replacement  of  forage  fish-
derived ingredients with algae – meaning an algae oil inclusion of approximately 
8% – could be achieved.  

7.4.  Requirements  for  replacing  fish-based  ingredients 
with algae-based feed ingredients in the current EU 
aquaculture 

7.4.1.  Required algae species 

Certain  microalgae  hold  immense  potential  for  replacing  fishmeal  with  algae 
derived protein and offer suitable EPA- and DHA-containing oil. As assessed in 

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Chapter 2.1,  macroalgae  biomass  was  not  found  to  be  a  promising  option  to 
replace fishmeal and fish oil. 

Microalgae, particularly species such as Nannochloropsis sp. and Chlorella sp., 
have been used in aquaculture for a long time, especially in hatcheries (265). The 
use  of  algae  meal  and  algae  oil  in  aquafeeds,  however,  is  a  more  recent 
development.  Meals  derived  from  several  microalgae  such  as  Schizochytrium 
sp., Chlorella sp., Nannochloropsis sp., Dunaliella sp. or Spirulina sp. have been 
evaluated in various scientific reports to understand their potential as fish feed 
ingredients (266). While several species have a favourable composition, amongst 
the species explored in this report, Nannochloropsis sp. and Chlorella sp. have 
been deemed especially suitable for the replacement of fishmeal. 

Nevertheless, only a few algae species have the potential to produce oil that is 
rich in omega-3 fatty acids. Among the potential microalgae, Schizochytrium sp. 
stands  out  due  to  its  significantly  high  levels  of  DHA,  making  it  a  suitable 
candidate  to  replace  this component  in  fish oil.  A  strain  of  Schizochytrium  that 
can also produce EPA, or the combination of DHA from Schizochytrium sp. with 
another EPA-producing species, can both be feasible options. The algae oils that 
are  currently  commercially  used  for  aquaculture  feed  are  produced  from 
Schizochytrium  sp.  However,  the  use  of  other  species  is  also  common  for 
producing algae oil intended for the food or nutraceutical industry (267).  

Given that the commercially available Schizochytrium sp. derived oil has a very 
favourable composition, which can be used by farmed aquatic animals, it will be 
increasingly  used  in  aquafeeds  for  the  foreseeable  future.  In  addition  to  the 
established use of Schizochytrium sp., industry stakeholders also point out that 
further research might explore different species or strains of Schizochytrium with 
an even more favourable fatty acid profile.  

Other algae species, for example, Phaeodactylum tricornutum and Nitzschia sp., 
are also rich in omega-3 oils (268), though they do not have high levels of DHA. 
Industry experts have indicated that it is unlikely that other microalgae species 
will emerge as viable competitors to Schizochytrium in terms of the oil fraction. 

It  is  important  to  highlight  that  algae's  value  extends  beyond  the  so  far 
components  mentioned  so  far.  Bioactive  compounds  like  pigments  and 
carbohydrates,  which  have  antioxidant  and  immunomodulatory  properties, 
should  not  be  overlooked,  as  they  can  promote  fish  health.  Many  micro-  and 
macroalgae  species  contain  carbohydrates  with  prebiotic  properties,  making 

(265) CEVA (2024). Report of the current algae industry in Europe. Available here. 
(266)  Yarnold  et  al.  (2019).  Microalgal  Aquafeeds  As  Part  of  a  Circular  Bioeconomy.  Trends  in 
Plant Science, 24(10). https://doi.org/10.1016/j.tplants.2019.06.005 
(267) CEVA (2024). Report of the current algae industry in Europe. Available here. 
(268)  Yarnold  et  al.  (2019).  Microalgal  Aquafeeds  As  Part  of  a  Circular  Bioeconomy.  Trends  in 
Plant Science, 24(10). https://doi.org/10.1016/j.tplants.2019.06.005 

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them  valuable  additions  in  aquafeed  as  functional  ingredients  or  feed 
additives (269). These aspects are explored in more detail in Chapter 2.1.2 of this 
report. Isolating and making use of various components, such as these bioactive 
compounds, along with the oil and meal from suitable algae species, could be a 
favourable approach. 

7.4.2.  Technological and spatial feasibility 

The aquaculture and aquafeed industries agree that the usually higher costs of 
algal  ingredients  compared  to  fish  based  ingredients  are  the  primary  factor 
limiting  the  incorporation  of  algae-based  ingredients  into  aquafeeds.  To 
overcome this challenge, further upscaling of production as well as optimisation 
of technology and production methods is essential. A comprehensive framework 
regarding  financial  incentives  to  address  the  economic  hurdles  has  been 
developed in Chapter 4. Additionally, the technological and spatial feasibility is 
assessed in this sub-chapter, including different options for improvement and the 
utilisation of sugar side streams for algae growth in Europe. 

7.4.2.1.  Optimisation of algae utilisation and technology 

A  large  amount  of  micro-  and  macroalgae  is  used  in  food  additives  and 
supplements  as  well  as  to  extract  thickening  agents,  such  as  hydrocolloid 
products which are obtained from the seaweeds. This application extends also to 
the non-food sector (270). A promising strategy can be the use of the remaining 
biomass, after the extraction of those hydrocolloids or certain other components. 
This approach could help to reduce the costs, making algae derived biomass and 
bioactive compounds more affordable (271). 

Chapter 2.2 focused on options to enhance the bioavailability and digestibility of 
the  relevant  components  of  different  algae  species.  As  concluded,  there  is  no 
universal solution regarding the optimal treatment, and some species are even 
sufficiently effective without further treatment. However, the objective remains to 
further enhance the processes for extracting valuable components from algae or 
producing biomass with optimal nutrient and bioactive component bioavailability. 
This  includes  ensuring  that  the  ingredients  are  easily  digestible  and  free  of 
antinutritional  factors,  which  are  components  that  affect  the  morphology  and 
function of the gastrointestinal tract, particularly in farmed carnivorous fish. It is 
also  evident  that  the  digestion  of  microalgae  with  a  thick  cell  wall,  such  as 

(269)  Nagappan  et  al.  (2021).  Potential  of  microalgae  as  a  sustainable  feed  ingredient  for 
aquaculture. Journal of Biotechnology, 342. https://doi.org/10.1016/j.jbiotec.2021.09.003 
(270) FAO (2024). The State of World Fisheries and Aquaculture 2024 – Blue Transformation in 
action. Rome, https://doi.org/10.4060/cd0683en. 
(271) Mwendwa et al. (2023). Potential for Use of Seaweed as a Fish Feed Ingredient: A Review. 
Journal of Agricultural Science, 152(2). http://dx.doi.org/10.5539/jas.v15n2p96 

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Nannochloropsis sp. and Chlorella sp., is more difficult for fish than algae with 
thin or no cell walls. Pre-treatment techniques such as microbiological treatment 
or physical treatment methods, including extraction, frying, blanching, or soaking, 
can  be  applied  to  improve  digestibility  and  reduce  antinutritional  factors (272). 
Success has been limited, and improving the pre-treatment methods to enhance 
the availability of nutrients for fish will increase efficiency and, consequently, the 
competitiveness of algae-based ingredients. 

Experts point out that a noticeable challenge regarding the beneficial components 
in algae lies in their considerable variability. Not only between species, but also 
due  to  factors  such  as  harvesting  time,  origin,  and  production  method.  This 
variability  makes  it  difficult  to  reliably  provide  a  beneficial  effect  of  a  particular 
algae  biomass  on  fish  performance.  More  research  in  this  field  is  required  to 
produce algae biomass with consistent nutrient profiles or bioactive compounds 
that  deliver  reliable  and  beneficial  results  in  farmed  aquatic  animals.  This  is 
particularly relevant when targeting bioactive compounds. 

7.4.2.2.  Algae cultivation inside and outside of Europe and 

side stream utilisation 

Algae cultivation inside and outside of Europe 

All algae require water and certain nutrients, such as nitrogen, phosphorus, and 
trace  elements 
for  growth.  Additionally,  autotrophic  algae  such  as 
Nannochloropsis  sp.  need  CO₂  and  light  to  grow,  while  for  the  cultivation  of 
heterotrophic algae, such as Schizochytrium sp., a sugar source is required. This 
can be a particular hurdle, as the production of sugar specifically for the growth 
of  algae  is costly  and resource-consuming  and  competes  with  other industries 
such as the food industry. 

The  algae  oil  producer  Corbion  uses  the  by-products  from  a  sugarcane  mill in 
Brazil to produce Schizochytrium sp. (273). Another example of a major algae oil 
producer is  Veramaris,  which  sources  sugar  produced  from  corn  in  the  United 
States,  which  is  cultivated near their  algae production  facilities.  However, they 
state that any pure source of sugar could be used as a substrate (274). 

Most of the large producers of algae oil are currently not producing in Europe. 
According  to  some  industry  stakeholders  interviewed,  the  challenge  lies  in  the 
lack  of  large-scale  algae  fermentation  facilities  with  access  to  low-cost  sugar 

(272)  Ahmad,  A.,  Hassan,  S.W.,  Banat,  F.  (2022).  An  overview  of  microalgae  biomass  as  a 
sustainable  aquaculture  feed  ingredient:  food  security  and  circular  economy,  Bioengineered, 
13(4). https://doi.org/10.1080/21655979.2022.2061148 
(273) CEVA (2024). Report of the current algae industry in Europe. Available here. 
(274) Veramaris (n.d.). How it’s made. 

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source with a relatively low carbon footprint in Europe. According to the industry 
stakeholders,  the  conditions  in  Europe  are  not  ideal  for  producing  such  large 
quantities of suitable sugar crops for algae production. The geographical position 
with  sub-optimal  climatic  conditions  outside  of  southern  Europe  and  certain 
financial-economic  aspects,  such  as  higher  labour  or  land  costs,  can  be  a 
hurdle (275). Finding solutions to these issues would provide a significant boost to 
the algae market, enabling it to better serve the needs of the European aquafeed 
industry.  

A  great  benefit  that  was  pointed  out  and  highly  valued  by  the  interviewed 
stakeholders  was  the  fact,  that  logistic  costs  and  import  costs  could  be 
significantly  reduced  if  large  scale  production  facilities  would  be  established 
directly in Europe. Additionally, the proximity to major markets like Norway, which 
requires large volumes of EPA and DHA rich oil to produce Atlantic salmon, would 
be a considerable advantage. Additionally, another strength of Europe regarding 
the micro-algae sector is its strong position as a science and technology base, 
as well as its research and development funding policies (276).  

It  is  important  to  note  that  some  companies  already  make  use  of  these 
advantages, as they are already producing the algae for their algae oil or algae 
meal for aquafeed in Europe. One example is the algae oil producer MiAlgae (277). 
They have solved the issue of the availability of suitable low-cost sugar crops in 
a  different  way:  they  utilise  distillery  co-products  from  the  whisky  industry  in 
Scotland, also benefiting from proximity to the whisky distilleries (278). 

Side stream utilisation for algae cultivation 

Circular approaches, such as using nutrient-rich water or side streams from other 
industries, as well as co-product development, can not only enhance ecological 
sustainability  but  also  represent  a  more  economical  option  for  algae  feed 
production. 

All algae require water and certain nutrients – such as nitrogen, phosphorus, and 
trace elements – for growth. Therefore, approaches that reuse or recover these 
resources  from  industrial  side  streams  or  during  production  can  be  relevant 
across all algae cultivation methods. 

The reports entitled “Algae potential for (waste)water treatment and fertiliser/plant 
biostimulants  production”  and  “Regulatory  barriers,  recommendations,  good 

(275) Vigani et al. (2014). Microalgae-based products for the food and feed sector: an outlook for 
Europe, Publications Office. https://data.europa.eu/doi/10.2791/3339 
(276) Vigani et al. (2014). Microalgae-based products for the food and feed sector: an outlook for 
Europe, Publications Office. https://data.europa.eu/doi/10.2791/3339 
(277) MiAlgae  
(278) MiAlgae 

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(sustainable) practices and future paths on using viable recycled media in organic 
microalgae fertilising products”, both of which are part of the Study to Support a 
Sustainable EU Algae Industry alongside this current report, explore in detail the 
use  of  such  side  streams  and  CO₂  for  microalgae  production.  However,  while 
many  parallels  exist  for  feed  production,  it  should  be  recognised  that  these 
studies focus primarily on the application of algae as fertilisers. It is important to 
acknowledge  that  additional  regulatory  considerations  and  restrictions  apply 
when producing algae for feed purposes. In general, side streams used for feed 
production must be of food-grade quality to ensure the safety and acceptability of 
the resulting feed products. While a regulatory assessment regarding the use of 
by-products was not part of this research, it is worth noting that when the term 
“waste” is used, it should be interpreted with caution. Legally, a product classified 
as “waste” cannot be used directly in feed production. It must first attain “end-of-
waste”  status  (as  defined  in  the  EU  Waste  Framework  Directive  2008/98/EC), 
which  confirms  that  it  no  longer  qualifies  as  waste  and  can  be  repurposed  for 
specific uses, such as feed production. These legal considerations are examined 
in  greater  depth  in  the  aforementioned  reports.  It  is  also  worth  noting  that  the 
forthcoming Circular Economy Act may introduce changes that could facilitate or 
simplify  the  application  of  circular  approaches,  potentially  benefiting  algae 
production as well. 

The use of by-products may be one of the most promising solutions – particularly 
for the cultivation of heterotrophic algae for oil production in Europe. Research in 
this field is ongoing, and several projects and studies have already investigated 
the use of sugar-rich side streams to cultivate heterotrophic algae species such 
as Schizochytrium sp. 

While  the  valorisation  of  waste  streams  through  algae  cultivation  offers  an 
excellent opportunity, it must be stressed that the generation of waste should be 
avoided  in  the  first  place.  Waste  valorisation  should  complement,  not  replace, 
broader waste prevention efforts. 

In  the  following  paragraphs,  various  options  for  utilising  side  streams  and  by-
products  –  specifically  as  carbon  sources  for  the  production  of  heterotrophic 
algae in Europe – are explored: 

Sugar beet molasses 

While sugarcane is not a common sugar crop in Europe, sugar beet is the primary 
source  of  sugar  on  the  continent.  One  notable  by-product  of  sugar  beet 
processing is molasses, which remains after the extraction of sucrose. It has been 
successfully  demonstrated  that  sugar  beet  molasses  can  serve  as  a  suitable 
carbon source for the growth of heterotrophic algae, such as Chlorella vulgaris. 

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Moreover,  it  has  been  assessed  that  this  approach  can  significantly  reduce 
cultivation costs (279). 

Brewery and distillery by-products 

the  company  MiAlgae  shows  approaches 

to  produce 
As  an  example, 
heterotrophic  microalgae  from  distillery  wastes  are  already  used  in  practice. 
While the whisky industry may be very suitable as an industry partner for a carbon 
source in Scotland, brewery or distillery side streams from other industries may 
be  more  prevalent  in  other  countries  across  Europe.  Logistics  and  local 
partnerships are also key in this case. For example, according to the abstract of 
the research paper by Yang et  al. (280), waste beer yeast hydrolysate could be 
successfully used to cultivate Schizochytrium sp. for DHA production. 

Dairy by-products (whey, lactose) 

Dairy  effluents  are  often  not  utilised  further  and  can  cause  environmental 
problems and disposal costs for the producer. The liquids are rich in nutrients and 
can contain up to 5% lactose (281). 

Growing heterotrophic algae that are suitable for DHA production was tested as 
an option in a few studies. One of the targeted species in research by Russo et. 
al. (282) was Aurantiochytrium mangrovei. For this species, a hydrolysis step of 
the lactose into glucose and galactose was necessary. These sugars can also be 
utilised by Schizochytrium sp. However, the study found that the nutrient content 
in the dairy effluent used alone (in the case of mozzarella manufacturing) was not 
leading to sufficient growth results compared to standard media. As a result, the 
combination  of  these  dairy  by-products  with  brewery  waste  as  a  medium  was 
chosen, which led to good growth performance, showing promising results as an 
alternative  for  a  sustainable  production  method  reducing  costs  of  DHA 
production. It should also be noted that other species or strains may be able to 
directly utilise lactose. The use of demineralised effluents from lactose-free milk 

(279) Şimşek & Çetin (2022). “The Effect of Waste Molasses on the Growth and the Amount of 
Lipid and Protein of Chlorella Vulgaris,” International Journal of Nature and Life Sciences 6, no. 
1: 41–47, https://doi.org/10.47947/ijnls.1092216  
(280) Yang Qingyi et al. (2025). “Production of DHA Algal Oil from Schizochytrium  Sp. Fed with 
Waste  Beer  Yeast  Hydrolysate,”  Food  and  Machinery  41,  no.  2:  173–80, 
http://www.ifoodmm.com/spyjxen/article/abstract/202502022.  
(281)  Russo  et  al.  (2021).  “Formulation  of  New  Media  from  Dairy  and  Brewery  Wastes  for  a 
Sustainable Production of DHA-Rich Oil by Aurantiochytrium Mangrovei,” Marine Drugs 20, no. 1 
39, https://doi.org/10.3390/md20010039. 
(282)  Russo  et  al.  (2021).  “Formulation  of  New  Media  from  Dairy  and  Brewery  Wastes  for  a 
Sustainable Production of DHA-Rich Oil by Aurantiochytrium Mangrovei,” Marine Drugs 20, no. 1 
39, https://doi.org/10.3390/md20010039. 

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production could also be promising, as it contains high amounts of lactose and is 
usually challenging to dispose of for the dairy industry (283). 

Fruit by-products 

Fruit waste is abundant and low-cost. However, the specific composition of fruit 
wastes can vary greatly. On average, the organic matter of fruit waste consists of 
approximately 75% insoluble hemicellulose and soluble sugars, such as glucose, 
saccharose  and  fructose.  Other  components  are  cellulose  (9%)  and  lignin 
(5%) (284). 

Multiple  studies  have  demonstrated  the  successful  cultivation  of  various 
heterotrophic  algae  species.  It  should  be  noted  that  fruit  waste  intended  for 
microalgae  production  usually  needs  to  be  pre-treated  or  processed  before  its 
use, which can also be costly. This would make this approach more suitable for 
high  value  products.  Especially  with  further  development  to  lower  the  costs  of 
heterotrophic algae production it may be a viable option (285). 

Wood wastes, e.g. from forestry, agriculture, and municipality 

Another approach is the utilisation of woody biomass waste as a sugar source for 
algae cultivation. This solution does not compete with food crops or other land 
uses,  making  it  a  promising  option  that  was  further explored  in  the  EU-funded 
FLEXI-GREEN FUELS project. In this project, the cellulose from the woody waste 
was  treated  with  enzymes  to  convert  it  into  glucose,  which  was  then  used  to 
cultivate  oil-rich  algae,  specifically  Auxenochlorella  protothecoides,  which  is 
capable  of  heterotrophic  growth.  These  oil  rich  algae  were  utilised  to  produce 
biofuels (286).  

While  this  project  primarily  targeted  biodiesel  as  the  final  product,  it  still 
demonstrates the general feasibility of this approach, which could also be applied 
to algae-oil production intended for other sectors, such as the feed industry.  

(283) Rasmussen et al. (2020). “Valorization of Side-Streams from Lactose-Free Milk Production 
Innovative  Food  Science  &  Emerging  Technologies  62:  102337, 
by  Electrodialysis,” 
https://doi.org/10.1016/j.ifset.2020.102337. 
(284) Lee et al. (2024).“Upcycling Fruit Waste into Microalgae Biotechnology: Perspective Views 
and  Way 
100203, 
https://doi.org/10.1016/j.fochms.2024.100203. 
(285) Lee et al. (2024).“Upcycling Fruit Waste into Microalgae Biotechnology: Perspective Views 
and  Way 
100203, 
https://doi.org/10.1016/j.fochms.2024.100203. 
(286) European Commission (2024). “Brewing Biofuels from Scrap Wood, with Help from Oil-Rich 
Algae,” Brewing biofuels from scrap wood, with help from oil-rich algae, Available here.  

Chemistry:  Molecular 

Chemistry:  Molecular 

Forward,” 

Forward,” 

Sciences 

Sciences 

Food 

Food 

8: 

8: 

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Glycerol as a by-product from biodiesel production 

Glycerol is the main by-product in biodiesel production and is usually considered 
an issue for biodiesel producers, as its disposal poses environmental challenges 
and  is  costly.  The  consumption  of  glycerol  by  heterotrophic  algae  can  be  a 
solution, not only for the disposal, but also for the growth of these microalgae for 
algae oil production (287). 

The feasibility of this approach has been explored in several studies, for example 
in  the  study  by  Kujawska  et  al. (288).  In  this  study,  Schizochytrium  sp.  was 
successfully  cultivated  using  glycerol  as  the  carbon  source,  with  the  aim  of 
valorising the DHA, demonstrating a high potential for this approach. 

Given  the  broad  variety  of  possible  side  streams  and  by-products,  it  is  also 
important to consider several individual factors, such as: 

•  Which industries are already established at the specific location? 
• 

Is  the  specific  side  stream  currently  utilised  in  other  industries  (at  this 
specific location)? 

•  Are  sufficient  funds  available  to  pre-treat  the  relevant  waste  product, 

where necessary? 

•  Are there any additional regulatory considerations that must be addressed 
when  utilising  a  specific  side  stream  in  a  certain  country  for  algae  feed 
production? 

•  How consistent are the nutrient levels in this specific by-product from the 

potential site? 

•  Can agreements be established for long-term cooperation? 

Aspects  like  these  must  be  evaluated  individually,  highlighting  that  there  is  no 
universal solution. Overall, utilising by-products for algae production in Europe is 
feasible and represents an important step toward making especially heterotrophic 
algae  production  more  sustainable,  both  ecologically  and  economically,  while 
simultaneously helping to reduce waste and enhances resource efficiency. 

7.5.  Conclusions on future trends 

As  the  aquaculture  industry  continues  to  expand,  the  demand  for  fish  oil  and 
fishmeal increases. This urgent need for sustainable and viable alternatives has 

(287)  Kujawska  et  al.  (2021).  “Optimizing  Docosahexaenoic  Acid  (DHA)  Production  by 
Schizochytrium  Sp.  Grown  on  Waste  Glycerol,”  Energies  14,  no.  6:  1685, 
https://doi.org/10.3390/en14061685. 
(288)  Kujawska  et  al.  (2021).  “Optimizing  Docosahexaenoic  Acid  (DHA)  Production  by 
Schizochytrium  Sp.  Grown  on  Waste  Glycerol,”  Energies  14,  no.  6:  1685, 
https://doi.org/10.3390/en14061685. 

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prompted the industry to explore ingredients from unconventional sources. In this 
context,  algae  have  emerged  as  promising  option  to  replace  traditional  feed 
components. Over the past years, especially algae oil has gained popularity as 
an  alternative,  demonstrating  high  potential  to  effectively  replace  fish  oil  and 
offering a more sustainable solution to reduce the reliance on wild-caught fish-
based ingredients.  

While algae oil has shown significant promise, the incorporation of algae meal is 
still limited. The industry is not yet ready to incorporate more than 3% of algae 
meal,  although  research  suggests  that  a  10%  inclusion  level  and  more, 
depending  on  the  fish  species,  could  be  achievable.  It  was  estimated  that  by 
2030, approximately 12,500 tonnes of fishmeal could be replaced in the EU with 
an average inclusion of 3% algae meal in aquafeeds. 

In contrast, the mature algae oil market, supported by the product’s favourable 
fatty acid profile, has facilitated its growing use in aquafeeds. Predictions indicate 
that  about  two  thirds  of  the  total  current  used  fish  oil  in  the  EU  –  more  than 
100,000 tonnes per year – could be replaced with algae oil by 2030. Specifically, 
it  was  calculated  that  a  5%  inclusion  of  algae  oil  in  aquafeeds  could  replace 
109,000 tonnes of fish oil. This would require a 73,000 tonnes of algae oil per 
year, assuming a replacement ratio of 2:3. It is estimated that approximately 1% 
algae  oil  is  currently  included  in  average  aquafeed,  indicating  a  need  for  an 
additional 58,000 tonnes of algae oil per year in the EU by 2030. 

However, economic constraints remain a limiting factor for broader application in 
aquafeeds. To address these challenges, advances in technology, utilisation of 
by-products from other markets, and thereby the development of viable solutions 
for producing algae ingredients directly in Europe is essential. These strategies 
would improve the feasibility and scalability of algae-based feed solutions for the 
aquaculture sector.  

Although the transition to algae-based feed ingredients presents challenges, the 
potential benefits for the aquaculture industry and the environment make it a great 
alternative in aquafeeds. Further research and development are crucial to paving 
the way for a more sustainable future for the fish farming sector. 

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8.  Conclusions and summary of recommendations 

8.1.  Conclusions 

In light of the challenges posed by the extensive use of wild-caught fish as an 
aquafeed ingredient – including ongoing overfishing and the expected supply gap 
due  to  its  limited  availability  –  there  is a  clear need  for an  alternative  solution. 
WP1  concludes that algae, particularly certain microalgae, can serve as a viable 
substitute for fish-based ingredients.  

While  increasing  amounts  of  plant-based  oils  and  meals  have  been  used  to 
replace  fish-based  ingredients  in  aquafeeds  over  the  past  few  decades, 
maintaining  levels  of  eicosapentaenoic  acid  (EPA)  and  docosahexaenoic  acid 
(DHA) – omega-3 fatty acids typically found in fish – remains a challenge. Algae 
present a promising solution, as they are the original source of these essential 
omega-3 fatty acids. Furthermore, certain microalgae are not just rich in protein, 
but  also  possess  a  suitable  amino  acid  profile,  making  them  an  excellent 
substitute for fishmeal. Based on the findings discussed, several key conclusions 
can be drawn: 

1.  There  is  a  clear need  for  alternative  solutions  to  wild-caught  fish  as  a  finite 
aquafeed ingredient due to ongoing overfishing and the expected supply gap. In 
light  of  these  challenges,  WP1  confirms  the  urgent  necessity  for  sustainable 
substitutes. 

2. Algae can provide a suitable amino acid profile and are the original source of 
essential omega-3 fatty acids (EPA and DHA), making them suitable to replace 
fishmeal and fish oil. This addresses one of the key challenges of plant-based 
replacements which often lack these fatty acids. 

3. Especially certain microalgae can serve as a viable substitute for fish-based 
ingredients  in  aquafeeds  while  macroalgae are  not as  suitable.  However,  both 
types can provide valuable functional and bioactive compounds, which may serve 
as high-value feed additives and can contribute positively to overall fish health. 

4. The evaluated microalgae species Schizochytrium sp., Nannochloropsis sp., 
and  Chlorella  sp.  were  identified  as  particularly  suitable  candidates  for 
aquafeeds. These were selected based on high DHA and EPA content and high 
protein levels with an amino acid profile comparable to that of fish meal. 

5.  Processing  methods  can  enhance  the  digestibility  and  nutrient  availability 
algae,  though  their  effectiveness  and  necessity  depend  on  the  species.  Pre-
treatments such as cell wall disruption and enzymatic treatment can be effective 
in some cases. 

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6.  Fish  feeds  with  significant  amounts  of  algae  demonstrate  comparable  feed 
conversion ratios (FCR), specific growth rates (SGR) and overall fish health to 
fish-based  formulations.  This  conclusion  was  reached  in  the  Multi  Criteria 
Analysis (MCA) which has been informed by multiple trials and interviews. 

7.  The  replacement  of  fish-based  ingredients  with  algae  resulted  in  better  fish 
quality and lower contamination levels in aquaculture fish. This supports broader 
food safety and consumer health objectives. 

8. Algae-based feed ingredients are generally more expensive than fish-based 
ingredients, though algae oil has at times been less costly. On average, algae-
based feed costs about 10% more. 

9.  Algae  offer  greater price  stability  due  to  production  in  closed  environments, 
which  protects  against  external  pressures  like  overfishing  or  climate  events, 
adding resilience to the feed supply chain. 

10. The environmental performance of algae-containing feed varies significantly 
across  different  sources,  especially  depending  on  the  set-up. In  terms  of  CO2, 
some  small-scale  LCAs  show  higher  emissions,  but  these  do  often  not  reflect 
industry-scale efficiencies or innovations. 

11. Large-scale production and circular approaches can make algae-containing 
feeds  more  sustainable  than  conventional  fish  feed.  For  example,  for  a 
commercially available algae-based DHA product, the LCA found 30-40% lower 
climate impact compared to fish oil. 

12. Utilising algae instead of forage fish reduces the pressure on wild fish stocks, 
benefiting  marine  ecosystems  and  biodiversity,  thus  supporting  regenerative 
aquaculture practices. 

13. Reducing the Forage Fish Dependency Ratio (FFDR) is essential, and even 
modest  algae  inclusion  can  significantly  contribute  to  achieving  this  target. 
Establishing a FFDR target would be feasible. 

14. A significant reduction of PCBs and dioxins can be achieved by substituting 
fish-based  ingredients  with  algae.  These  contaminants  mainly  originate  from 
marine ingredients. 

15.  Strategies  like  applying  the  ALARA  principle  and  lowering  limit  values  for 
PCBs and dioxins in the feed contaminants regulation (Directive 2002/32/EC) are 
feasible. Various technologies and sourcing options, including the use of algae, 
are available to effectively reduce contaminants. 

16. While a total replacement of fish-based ingredients with algae is possible and 
beneficial, combining algae with other alternatives and sustainably sourced by-
products, such as trimmings from aquaculture, is more practical for the industry. 

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17. Insect-based feeds also perform well but are still significantly more expensive 
than both fish- and algae-based feeds, currently limiting their adoption. 

18.  Plant-based  feeds  without  any  fish  or  alternative  ingredients  showed 
significantly worse performance in feed efficiency and fish health, reinforcing the 
need for balanced formulations. 

19. Algae could contribute 10-15% of total feed in salmon and trout, and 20-25% 
in seabass and seabream. However, cost remains a limiting factor, especially for 
lower-value species. 

20. Setting a minimum target of 25% of EPA and DHA from non-fish sources like 
algae oil is feasible and would drive demand and production. 

21. A holistic framework including regulation, financial tools, and market-based 
incentives is needed to support widespread adoption of algae in aquafeeds. 

22.  Establishing  an  enabling  policy  and  regulatory  environment  is  crucial  for 
accelerating algae integration into feed value chains. 

23.  Correcting  market  distortions  by  removing  subsidies  for  unsustainable  fish 
feeds and offering tax incentives for sustainable options can drive algae adoption. 

24.  Inclusion  of  sustainable  aquaculture  in  the  EU  Taxonomy  and  the  use  of 
innovative finance tools such as blue bonds can support the algae sector. 

25.  The  regulatory  landscape  already  permits  algae  use  in  feed.  Additional 
industry standards and certifications could further facilitate adoption. 

26. By 2030, a 3% inclusion of algae meal in EU aquafeeds could replace around 
12,500 tonnes of fishmeal. 

27. By 2030, an algae oil inclusion of 5% could replace over 100,000 tonnes of 
fish oil annually in the EU, requiring about 73,000 tonnes of algae oil. 

28. Currently, algae oil represents about 1% of feed inclusion. Scaling up to meet 
2030 targets would require an additional 58,000 tonnes per year. 

29. Further research is needed into strain selection, processing techniques, and 
nutrient bioavailability to optimize algae for feed. 

30.  Using 
hydrocolloids could reduce overall costs and improve sustainability. 

leftover  biomass  after  extracting  valuable  components 

like 

31.  Producing  algae  within  the  EU  can  strengthen  local  supply  chains,  reduce 
import dependency and improve resilience. 

32. A key barrier in Europe is the lack of large-scale fermentation infrastructure 
with access to low-cost, sustainable sugar sources. 

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33. Viable sugar sources for algae fermentation exist in Europe (e.g., molasses, 
brewery by-products, wood waste) but require further research and optimisation. 

As aquaculture is expected to experience significant growth and wild fish stocks 
remain finite, algae present a substantial opportunity – not only to fill the gap but 
also to replace portions of unsustainably sourced fish-based ingredients. Algae 
oil and algae meal for aquafeed are in high demand but the industry still requires 
support in the further development and scaling up of algae-based feed solutions. 
By investing in this promising and innovative sector, we can help pave the way 
towards a thriving and more sustainable aquaculture industry.  

8.2.  Summary of recommendations 

1)  Optimal inclusion levels of algae in aquafeeds 

Theoretic  optimum  of  algal  inclusion:  A  complete  replacement  of  fish-
based  ingredients  with  algal  alternatives  is  technically  possible.  Algae 
meal  and  oil  together  could  account  for  10-15%  of  the  total  feed  for 
salmon and trout and approximately 20-25% for seabass and seabream 
(the upper value would equal approximately the replacement of all whole 
forage fish derived ingredients currently used in feeds for these species); 
However, economic factors would be limiting for a long time, especially for 
lower  priced  fish  species.  A  more  practical  and  scalable  approach  may 
involve  a  combination  of  algae,  other  alternative  ingredients,  and 
sustainably  sourced  fish-based  ingredients,  in  particular  trimmings  and 
offal from aquaculture production. 

2)  Introducing minimum targets for non-fish-derived EPA+DHA 

In  terms  of  fish  oil,  a  minimum  of  25%  of  the  total  included  EPA+DHA 
should  be  set  as  an  initial  target  for  the  inclusion  of  non-fish-derived 
EPA+DHA. It is also recommended to re-evaluate the minimum target for 
non-fish-derived sources as the market continues to evolve. 

3)  Reducing the forage fish dependency ratio (FFDR) 

An FFDR (possibly individually considered as FFDRm and FFDRo) around 
the  current  average  values  should  be  encouraged.  Additionally,  a 
significantly lower FFDR could be rewarded with incentives to promote the 
use  of  by-products  and  alternative  ingredients.  It  is  recommended  to 
simultaneously integrate these targets with other indicators such as LCAs 
and  certifications,  which  can  provide  a  more  holistic  approach.  As  the 
aquaculture sector grows, the average FFDR values will decrease further, 
due to forage fish being a limited resource. Therefore, the targets should 
not  be  static  but  re-evaluated  and  potentially  lowered  accordingly  in 
regular time frames, for example every five years. 

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4)  Including the ALARA principle for feed contaminants 

It  is  advisable  to  include  the  ALARA  principle  also  for  feed  in  Directive 
2002/32/EC (Directive on undesirable substances in animal feed), when it 
is evaluated in the next round. 

5)  Reducing allowable contaminant levels 

The lowering of the current limit values according to the feed contaminant 
regulation (Directive 2002/32/EC) for dioxins and the sum of dioxins and 
dioxin-like  PCBs  is  recommended.  A  lowering  of  non-dioxin  like  PCBs 
should also be feasible. Additionally, the action threshold for dioxins and 
dioxin-like PCBs is suggested to be lowered. 

6)  Developing additional industry standards 

In  addition  to  existing  industry  standards,  key  gaps  remain  in  the  algae 
feed sector where new standards would be beneficial. It is recommended 
to develop standards that cover the following aspects: 

o  Claims: Specification of potentially suitable claims (e.g. nutritional, 
environmental,  health)  for  algae  and  algae-containing  feed, 
supporting their use; 

o  Origin  of  biomass:  Specification  of  appropriate  methods  for 
verifying the origin of biomass, enhancing accurate labelling; 
o  Contaminants:  Specification  of  analytical  detection  methods  for 
contaminants  in  algae,  also  including  an  overview  of  all  known 
algae contaminants; 

o  Water  management:  Guidelines 

for  water 

reuse  and 

measurements of water consumption in algae cultivation; 

o  Preservation  methods:  Specification  of  suitable  preservation 
methods and storage for algae for the various end purposes. 

7)  Developing a framework of strategies and financial incentives 

The development of a comprehensive EU-wide framework (described in 
4.1.3 above) of strategies and financial incentives supporting the inclusion 
of algae in feed is recommended. For this framework, an inclusion of the 
following aspects is recommended: 

o  Establishing  an  enabling  regulatory  and  policy  environment, 
including policies, enhanced certification schemes, and technical 
support; 

o  Correcting  market  distortions  through  fiscal  measures,  such  as 
phasing out subsidies for unsustainable fish feeds and providing 
tax incentives for more sustainable options; 
Integrating sustainable aquaculture into the EU Taxonomy; 
Introducing  innovative  financing  mechanisms,  including  blue 
bonds, loans and guarantees; 

o 
o 

o  Strengthening data infrastructure and transparency. 

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Annexes 

Annex I – Tables 

1.1  Nutritional requirements for European key fish species 

Table 12 – Nutritional requirements for Atlantic salmon, Salmo salar 

Fry 

Fingerling 

Juvenile 

Grower 

Marine 
grower 

Proximate feed composition (% dry feed basis)  

Crude protein, % min 

50 

45-50 

Crude lipid, % min 

16-18 

Carbohydrate, % max 

Crude fibre, % max 

Digestible energy, min kJ/g 

10 

2 

19 

20 

10 

3 

19 

45 

20 

12 

3 

19 

Amino acids (% minimum requirement of the dietary protein) 

Arginine 

Histidine 

Isoleucine 

Leucine 

Lysine 

Methionine 

Phenylalanine 

Threonine 

Tryptophan 

Valine 

EPA+DHA 

Sources: (289;290;291;292;293).  

2 

0.7 

0.8 

1.4 

2 

1.1 

1.2 

0.8 

0.2 

1.3 

0.5 

2 

0.7 

0.8 

1.4 

1.8 

1 

1.2 

0.8 

0.2 

1.3 

0.5 

2 

0.7 

0.8 

1.4 

1.8 

1 

1.2 

0.8 

0.2 

1.3 

0.5 

42-45 

20-24 

40-45 

24-30 

12 

3 

20 

1.6 

0.8 

0.8 

1.4 

1.8 

1 

1.2 

0.8 

0.2 

1.3 

12 

3 

20 

1.6 

0.7 

0.8 

1.4 

1.8 

1 

1.2 

0.8 

0.2 

1.3 

1-2.6 

1-2.6 

(289)  National  Research  Council  (2011).  Nutrient  Requirements  of  Fish  and  Shrimp, 
https://doi.org/10.17226/13039. 

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Arginine 

Histidine 

Isoleucine 

Leucine 

Lysine 

Methionine 

Phenylalanine 

Threonine 

Tryptophan 

Valine 

EPA+DHA 

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Table 13 – Nutritional requirements for European seabass, Dicentrarchus labrax 

Fry 

Fingerling 

Juvenile 

Grower 

Proximate feed composition (% dry feed basis)  

Crude protein, % min 

Crude lipid, % 

Carbohydrate, % max 

Digestible energy, kJ/g 

Amino acids (% dry feed) 

50 

15-18 

12 

45-50 

15-18 

12 

19 

3.9-4.6 

4.8 

2.6 

0,6 

45-50 

15-18 

45 

15-18 

12 

19 

4.6 

1.6 

2.6 

4.3 

4.8 

2.3 

2.6 

2.7 

0.6 

2.9 

12 

19 

4.6 

1.6 

2.6 

4.3 

4.8 

2.3 

2.6 

2.7 

0.6 

2.9 

 0.5-0.7 

1.3-1.5 

1.3-1.5 

1.1-1.20 

1.1-1.20 

At a size range of 24 – 80 g, the period when a 3 mm pellet is consumed, the optimum requirement for 
growth is 1.3 – 1.5% EPA+DHA, for both species. Beyond ~80 g (4.5 mm pellet) seabream require 1.20 
– 1.25% EPA+DHA, whereas seabass require 1.10 – 1.20% EPA+DHA.  

Sources: (294;295;296). 

(290) FAO (n.d.). Nutritional Requirements. 
(291) FAO (n.d.). FAQs  
(292)  Zhang  et  al.“Omega-3  Long-Chain  Polyunsaturated  Fatty  Acids  in  Atlantic  Salmon: 
Functions,  Requirements,  Sources,  de  Novo  Biosynthesis  and  Selective  Breeding  Strategies,” 
Reviews in Aquaculture 16, no. 3 (2024): 1030–41, https://doi.org/10.1111/raq.12882. 
(293)  Hung  Van  Tran,  Hien  Van  Doan,  and  Vlastimil  Stejskal  (2021).  “Environmental 
Consequences  of  Using  Insect  Meal  as  an  Ingredient  in  Aquafeeds:  A  Systematic  View,”  15, 
https://doi.org/10.1111/raq.12595. 
(294) National Research Council. 2011. Nutrient Requirements of Fish and Shrimp. Washington, 
DC: The National Academies Press. https://doi.org/10.17226/13039  
(295) National Research Council. 2011. Nutrient Requirements of Fish and Shrimp. Washington, 
DC: The National Academies Press. https://doi.org/10.17226/13039  
(296) Houston, S.J.S. et al. (2018). Assessing EPA + DHA requirements of Sparus aurata AND 
Dicentrarchus 
lipid  metabolism. 
growth, 
http://hdl.handle.net/1893/27444  

composition 

Impacts 

labrax: 

and 

on 

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Table 14 – Nutritional requirements for gilthead seabream, Sparus aurata 

Fry 

Fingerling 

Juvenile 

Grower 

Proximate feed composition (% dry feed basis)  

Crude protein, % min 

Crude lipid, % 

15-20 

 12-24 

50-60 

 12-25 

45-50 

12-25 

Carbohydrate, % max 

Digestible energy, kJ/g 

Amino acids (% dry feed) 

Arginine 

Histidine 

Isoleucine 

Leucine 

Lysine 

Methionine 

Phenylalanine 

Threonine 

Tryptophan 

Valine 

EPA+DHA 

20 

19 

5.55 

1.89 

2.55 

4.75 

5.13 

2.6 

2.98 

0.75 

3.21 

<4.7 

5.0 

2.6  

0.6 

20 

19 

5.4 

1.7 

2.6 

4.5 

5 

2.4 

2.9 

2.8 

0.6 

3 

20 

19 

5.4 

1.7 

2.6 

4.5 

5 

2.4 

2.9 

2.8 

0.6 

3 

1.3-1.5 

1.3-1.5 

1.1-1.20 

1.2-1.25 

At a size range of 24 – 80 g, the period when a 3 mm pellet is consumed, the optimum requirement for 
growth is 1.3 – 1.5% EPA+DHA, for both species. Beyond ~80 g (4.5 mm pellet) seabream require 
1.20 – 1.25% EPA+DHA, whereas seabass require 1.10 – 1.20% EPA+DHA  

Sources: (297;298;299). 

(297) National Research Council. 2011. Nutrient Requirements of Fish and Shrimp. Washington, 
DC: The National Academies Press. https://doi.org/10.17226/13039. 
(298) FAO (n.d.).  Summary of dietary nutrient requirement and utilization of gilthead seabream, 
Sparus aurata. Available here. 
(299) Houston, S.J.S. et al. (2018). Assessing EPA + DHA requirements of Sparus aurata AND 
Dicentrarchus 
lipid  metabolism. 
growth, 
http://hdl.handle.net/1893/27444 

composition 

Impacts 

labrax: 

and 

on 

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Table 15 – Nutritional requirements for rainbow trout, Oncorhynchus mykiss 

Fry 

Fingerling 

Juvenile 

Grower 

Proximate composition (% dry feed basis)  

Crude protein, % min 

Crude lipid, % 

Carbohydrate, % max 

Digestible energy, kJ/g 

Amino acids (% dry feed) 

40-50 

16-24 

12 

15.5 

45 

16-24 

12 

15.5 

43 

42 

16-24 

16-24 

12 

15.5 

12 

15.5 

Arginine 

Histidine 

Isoleucine 

Leucine 

Lysine 

Methionine 

Phenylalanine 

Threonine 

Tryptophan 

Valine 

EPA+DHA 

Sources: (300;301;302). 

2 

0.7 

0.8 

1.4 

1.8 

1 

1.2 

0.8 

0.2 

1.3 

1.5 

2 

0.7 

0.8 

1.4 

1.8 

1 

1.2 

0.8 

0.2 

1.3 

1.5 

2 

0.7 

0.8 

1.4 

1.8 

1 

1.2 

0.8 

0.2 

1.3 

1.5 

2 

0.7 

0.8 

1.4 

1.8 

1 

1.2 

0.8 

0.2 

1.3 

1.5 

(300) National Research Council. 2011. Nutrient Requirements of Fish and Shrimp. Washington, 
DC: The National Academies Press. https://doi.org/10.17226/13039. 
(301) Baidya et al. (2021).“Effect of Different Wavelengths of LED Light on the Growth, Chlorophyll, 
β-Carotene  Content  and  Proximate  Composition  of  Chlorella  Ellipsoidea,”  Heliyon  7,  no.  12, 
https://doi.org/10.1016/j.heliyon.2021.e08525. 
(302)FAO  (n.d.).  Summary  of  dietary  nutrient  requirement  and  utilization  of  gilthead  seabream, 
Sparus aurata. Available here. 

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1.2  Composition of selected algae species 

Table 16 – Proximate composition of selected algae [%] 

Nr.  Algae species 

Crude 
protein 

Crude 
lipid 

Ash 

Crude 
fibre 

Moistur
e 

NFE 

Microalgae 

Chlorella  
ellipsoidea (% dry 
weight not clear) 

33-46 

7-11 

10-11 

6-8 

9-10 

 15-
33 

Chlorella vulgaris 

48 

Chlorella vulgaris 

21 

13 

12 

12 

6 

9 

18 

9 

4 

1 

5 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

Chlorella 
minutissima 

Nannochloropsis 
sp. 

Nannochloropsis 
sp. 

Nannochloropsis 
oceanica 

Nannochloropsis 
oculata 

Schizochytrium 
sp. 

Schizochytrium 
sp. 

Macroalgae 

11 

Ulva lactuca 

12 

Ulva lactuca 

13 

Ulva lactuca 

14 

Ulva rigida 

15 

16 

Saccharina 
latissima 

Saccharina 
latissima 

43 

30-60 

5-32 

33-36 

11-12 

49 

33-34 

13-39 

15 

8.5 

14 

7-16 

16.3 

31 

13 

39 

42 

8 

0.19 

1 

0 

2 

11 

8-12 

0-2 

3 

10 

1 

 19-
40 

39 

20 

11 

55 

15 

28.4 

16.9 

58 

0.1-10 

69-82 

90-97 

28.7 

43 

9-15 

1-2 

22-43 

35-57 

6-13 

0-2 

16-52 

7-19 

17 

Palmaria palmata 

14 

18 

Palmaria palmata 

14-30 

19 

Palmaria palmata 

22 

2 

0 

0 

26 

15-27 

24 

46 

10 

Sources: 1 (303), 2 (304), 3 (305), 4 (306), 5 (307), 6 (308), 7 (309), 8 (310), 9 (311), 10 (312), 11 (313), 12 (314),13 (315), 
14 (316), 15 (317), 16 (318), 17 (319),18 (320),19 (321). 

149 

Carbo- 
hydrat
e 

8 

14 

5-35 

18-20 

11 

20-26 

44-63 

28-62 

34 

3-25 

 
 
 
  
  
 
 
 
  
 
 
 
 
  
  
  
  
 
 
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
 
 
Work Package 1: Advancing algae-based alternatives in EU aquafeeds: pathways to reducing 
fish-based ingredients 
Annex to the Final Report 

(303) Baidya et al. (2021).“Effect of Different Wavelengths of LED Light on the Growth, Chlorophyll, 
β-Carotene  Content  and  Proximate  Composition  of  Chlorella  Ellipsoidea,”  Heliyon  7,  no.  12, 
https://doi.org/10.1016/j.heliyon.2021.e08525. 
(304) Tokuşoglu, Ö. & üUnal, M.K. (2006) “Biomass Nutrient Profiles of Three Microalgae: Spirulina 
Platensis, Chlorella Vulgaris, and Isochrisis Galbana,” Journal of Food Science 68, no. 4: 1144–
48, https://doi.org/10.1111/j.1365-2621.2003.tb09615.x. 
(305)  El-Chaghaby  et  al.  (2019)  “Assessment  of  Phytochemical  Components,  Proximate 
Composition  and  Antioxidant  Properties  of  Scenedesmus  Obliquus,  Chlorella  Vulgaris  and 
Spirulina Platensis Algae Extracts,” Egyptian Journal of Aquatic Biology and Fisheries 23, no. 4: 
521–26, https://doi.org/10.21608/ejabf.2019.57884. 
(306)  Arguelles,  E.  (2021).  “Biochemical  Composition  and  Bioactive  Properties  of  Chlorella 
Minutissima  (Chm1)  as  a  Potential  Source  of  Chemical  Compounds  for  Nutritional  Feed 
Supplement and Disease Control in Aquaculture,” Current Applied Science and Technology 21: 
6577, retrieved from https://li01.tci-thaijo.org/index.php/cast/article/view/245911  
(307) Khatoon et al. (2014). “Effects of Different Salinities and pH on the Growth and Proximate 
Composition of Nannochloropsis Sp. and Tetraselmis Sp. Isolated from South China Sea Cultured 
under  Control  and  Natural  Condition,” 
International  Biodeterioration  &  Biodegradation, 
Challenges 
in  Environmental  Science  and  Engineering,  CESE-2013,  95:  11–18, 
https://doi.org/10.1016/j.ibiod.2014.06.022  
(308) Arkronrat, Deemark, & Oniam, (2016). “Growth Performance and Proximate Composition of 
Mixed  Cultures  of  Marine  Microalgae  (Nannochloropsis  Sp.  &  Tetraselmis  Sp.)  with 
Monocultures,”. Available here. 
(309)  Jisha,  Singh,  &  Valsamma  (2021).  “Comparative  Nutritional  Characterization  of  Marine 
Microalgae  Chaetoceros  muelleri  and  Nannochloropsis  oceanica  used  as  Live  Feeds  in 
Aquaculture” Journal of Aquatic Biology & Fisheries, 9. Available here. 
(310)  S.  Banerjee  et  al.  (2011).  “Growth  and  Proximate  Composition  of  Tropical  Marine 
Chaetoceros Calcitrans and Nannochloropsis Oculata Cultured Outdoors and under Laboratory 
Conditions,” African Journal of Biotechnology 10, no.  1375–83. 
(311)  Ludevese-Pascual,  Dela  Peña,  and  Tornalejo  (2016),  “Biomass  Production,  Proximate 
Composition and Fatty  Acid  Profile of the  Local  Marine Thraustochytrid Isolate, Chizochytrium 
Sp. LEY7 Using Low-Cost Substrates at Optimum Culture Conditions,” Aquaculture Research 47, 
1: 318–28, https://doi.org/10.1111/are.12494  
(312)  Bélanger  et  al  “Apparent  Digestibility  of  Macronutrients  and  Fatty  Acids  from  Microalgae 
(Schizochytrium  Sp.)  Fed  to  Rainbow  Trout  (Oncorhynchus  Mykiss).”  Animals,  11(2),  456; 
https://doi.org/10.3390/ani11020456  
(313)  Yaich  et  al.  (2011)  “Chemical  Composition  and  Functional  Properties  of  Ulva  Lactuca 
Seaweed 
895–901, 
https://doi.org/10.1016/j.foodchem.2011.03.114  
(314) Rasyid (2017) “Evaluation of Nutritional Composition of The Dried Seaweed Ulva Lactuca 
from  Pameungpeuk  Waters,  Indonesia,”  Tropical  Life  Sciences  Research  28,  2:  119–25, 
https://doi.org/10.21315/tlsr2017.28.2.9  
(315) Premarathna et al. (2022) “Comparative Analysis of Proximate Compositions, Mineral and 
Functional Chemical Groups of 15 Different Seaweed Species,” Scientific Reports 12, 1: 19610, 
https://doi.org/10.1038/s41598-022-23609-8  
(316) Javier Echave et al. (2021) “Nutritional Composition of the Atlantic Seaweeds Ulva Rigida, 
Codium  Tomentosum,  Palmaria  Palmata  and  Porphyra  Purpurea,”  in  The  1st  International 
Electronic Conference on  Chemical  Sensors and Analytical Chemistry (International Electronic 
Conference 
67, 
and 
Sensors 
https://doi.org/10.3390/CSAC2021-10681  
(317) Bétina Lafeuille et al. (2023), “Variation of the Nutritional Composition and Bioactive Potential 
in Edible Macroalga Saccharina Latissima Cultivated from Atlantic Canada Subjected to Different 
Growth and Processing Conditions,” Foods 12, 8: 1736, https://doi.org/10.3390/foods12081736  
(321)  Monteiro  Vasconcelos  et  al.  (2024),  “Physicochemical  Properties  of  Wild  and  Cultivated 
Saccharina Latissima Macroalgae Harvested in the Canadian Boreal-Subarctic Transition Zone,” 
Heliyon 10, no. 8, https://doi.org/10.1016/j.heliyon.2024.e29626  

Analytical  Chemistry,  MDPI), 

on  Chemical 

Chemistry 

Collected 

Tunisia,” 

Food 

128, 

4: 

in 

150 

 
 
 
 
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1.3  Contaminants in fish oil 

Table 17 – Contaminants in fish oil that are used to make feed in Norway  

Contaminant 

Fish oil 

The following results are based on 10 samples evaluated by the Norwegian 
Institute of Marine Research (Havforskningsinstituttet). 

PCB-28 (µg/kg) 

PCB-52 (µg/kg) 

PCB-101 (µg/kg) 

PCB-138 (µg/kg) 

PCB-153 (µg/kg) 

PCB-180 (µg/kg) 

<0.3-1.7 

<0.3-5.1 

<0.2-7.3 

<0.2-11.1 

<0.3-16.9 

<0.2-3.3 

Sum PCB6 (µg/kg) (ppb) 

=  Non-dioxin-like  PCBs  =  sum  of  PCB  28,  PCB  52, 
PCB 101, PCB 138, PCB 153 and PCB 180 

1.3-43.8       Average: 13.5 

Sum dioxins (PCDD/PCDF) (ngTEQ/kg) (ppt) 

0.1-1.8       Average: 0.8 

Sum dioxins and dl-PCB (ngTEQ/kg) (ppt) 

0.3-4.8       Average: 2.0 

Sum dl-PCB (ngTEQ/kg) 

0.07-3.6     Average: 1,3 

Sum Dieldrin and Aldrin (µg/kg) 

Sum Endosulfan (µg/kg) 

Sum Toxaphene (µg/kg) 

Sum Chlordane (µg/kg) 

Sum Heptachlor (µg/kg) 

Sum HCH (µg/kg) 

HCB (µg/kg) 

op-DDD (µg/kg) 

op-DDE (µg/kg) 

op-DDT (µg/kg) 

pp-DDD (µg/kg) 

pp-DDE (µg/kg) 

pp-DDT (µg/kg) 

0.4-25.5 

3.3-4.1 

5.1-36.5 

1.2-17.9 

1.9-5 

0.3-0.9 

1.3-23 

0.25-3.2 

<0.25-1.5 

<0.25-2.5 

<0.25-13.0 

0.52-39.6 

0.25-6.8 

(319)  Bruno  Miguel  Campos  et  al.  (2022)  “Proximate  Composition,  Physicochemical  and 
Microbiological  Characterization  of  Edible  Seaweeds  Available  in  the  Portuguese  Market,” 
Frontiers in Bioscience-Elite 14, no. 4: 26, https://doi.org/10.31083/j.fbe1404026  
(320) Ruth S. Hagen Rødde et al. (2004) “Seasonal and Geographical Variation in the Chemical 
(L.)  Kuntze”  47,  2:  125–33, 
Composition  of 
https://doi.org/10.1515/BOT.2004.012  
(321) Echave et al. (2021). “Nutritional Composition of the Atlantic Seaweeds Ulva Rigida, Codium 
Tomentosum,  Palmaria  Palmata  and  Porphyra  Purpurea.”  Chem.  Proc.,  5(1),  67; 
https://doi.org/10.3390/CSAC2021-10681  

the  Red  Alga  Palmaria  Palmata 

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Contaminant 

Sum DDT (µg/kg) 

PBDE-28 (µg/kg) 

PBDE-47 (µg/kg) 

PBDE-99 (µg/kg) 

PBDE-100 (µg/kg) 

PBDE-153 (µg/kg) 

PBDE-154 (µg/kg) 

PBDE-183 (µg/kg) 

SumPBDE7 (µg/kg) 

PBDE-49 (µg/kg) 

PBDE-66 (µg/kg) 

PBDE-75 (µg/kg) 

PBDE-209 (µg/kg) 

α-HBCD (µg/kg) 

β-HBCD (µg/kg) 

γ-HBCD (µg/kg) 

Sum HBCD (µg/kg) 

TBBP-A (µg/kg) 

BHA (mg/kg) 

Source: Sele et al. (2024) (322). 

Fish oil 

1.9-67.6 

0.02-0.09 

0.13-1.56 

0.06-0.28 

0.06-0.38 

<0.09- 

0.06-0.2 

<0.09- 

0.46-2.66 

0.03-0.74 

0.03-0.07 

0.02-0.08 

0.20-0.34 

0.03-0.74 

<0.06- 

<0.06-0.08 

0.09-0.79 

<0.4-0.21 

0.37-8.8 

(322) Sele et al. (2024), “Program for Overvåking Av Fiskefôr,” Havforskningsinstituttet, Available 
here. 

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1.4. Limits for dioxins and PCBs 

Table 18 - Legal upper limits for dioxins and PCBs in selected animal feed products 

Dioxins (*1) 

Sum of dioxins and 
dioxin-like PCBs (*2) 

Non-dioxin-like 
PCBs (*3) 

Feed or feed 
materials 

Maximum content  
in ng WHO-PCDD/F-
TEQ/kg (ppt) (*4) relative 
to a feed with a moisture 
content of 12% 

Maximum content  
in ng WHO PCDD/F-PCB-
TEQ/kg (ppt) (*4) relative 
to a feed with a moisture 
content of 12% 

Maximum content   
in μg/kg (ppb) 
relative to a feed with 
a moisture content of 
12% (*5) 

Fish oil 

Feed materials of 
plant origin 

5.0 

0.75 

Compound feed… 

0.75 

...with the 
exception of 
compound feed 
for fish […]  

1.75 

20.0 

1.25 

1.5 

5.5 

175 

10 

10 

40 

*1Dioxins  =  [sum  of  polychlorinated  dibenzo-paradioxins  (PCDDs)  and  polychlorinated  dibenzofurans  (PCDFs) 
expressed  in  World  Health  Organisation  (WHO)  toxic  equivalents,  using  the  WHO-TEFs  (toxic  equivalency  factors, 
2005) (*5)] 

*2Sum  of  dioxins  and  dioxin-like  PCBs  =  (sum  of  polychlorinated  dibenzo-paradioxins  (PCDDs),  polychlorinated 
dibenzofurans (PCDFs) and polychlorinated biphenyls (PCBs) expressed in World Health Organisation (WHO) toxic 
equivalents, using the WHO-TEFs (toxic equivalency factors), 2005 (*5)) 

*3Non-dioxin-like PCBs = (sum of PCB 28, PCB 52, PCB 101, PCB 138, PCB 153 and PCB 180  (ICES – 6) (*5)) 

*4Table  of  TEF  (=  toxic  equivalency  factors)  for  dioxins,  furans  and  dioxin-like  PCBs:  WHO-TEFs  for  human  risk 
assessment based on the conclusions of the World Health Organisation (WHO) – International Programme on Chemical 
Safety (IPCS) expert meeting which was held in Geneva in June 2005 (Martin van den Berg et al., The 2005 World 
Health Organisation Re-evaluation of Human and Mammalian Toxic Equivalency Factors for Dioxins and Dioxin-like 
Compounds. Toxicological Sciences 93(2), 223–241 (2006)) 

*5Upper-bound concentrations; upper-bound concentrations are calculated on the assumption that all values of the 
different congeners below the limit of quantification are equal to the limit of quantification. 

Source: (323). 

(323) “DIRECTIVE 2002/32/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 7 
May 2002 on Undesirable Substances in Animal Feed.” 

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1.5. Limits for dioxins and PCBs 

Table 19 – Relevant CEN standards on animal feeding stuffs (CEN 327) 

Committee: CEN/TC 327 “Animal feeding stuffs” 

Reference 

Title 

Scope 

EN 
15510:2017 

EN 
15550:2017 

Animal feeding stuffs: Methods of sampling and 
analysis - Determination of calcium, sodium, 
phosphorus, magnesium, potassium, iron, zinc, 
copper, manganese, cobalt, molybdenum, and lead 
by ICP-AES 

Animal feeding stuffs: Methods of sampling and 
analysis - Determination of cadmium and lead by 
graphite furnace atomic absorption spectrometry 
(GF-AAS) after pressure digestion 

EN 
15741:2020 

Animal feeding stuffs: Methods of sampling and 
analysis - Determination of OCPs and PCBs by GC-
MS 

Supports quality control by 
ensuring nutritional and mineral 
composition of algae-based feed 
ingredients. 

Important for monitoring heavy 
metal contaminants in algae-
based feed. 

Ensures algae-based ingredients 
are free from organochlorine 
pesticides (OCPs) and poly-
chlorinated biphenyls (PCBs). 

EN 
15742:2020 

Animal feeding stuffs: Methods of sampling and 
analysis - Determination of OCPs by GC-ECD 

Provides an alternative method 
for contaminant testing. 

EN 
15784:2021 

CEN/TS 
17764-1:2006 
& CEN/TS 
17764-2:2006 

CEN/TS 
15754:2008 

CEN/TS 
17174:2018 

CEN/TS 
17455:2020 

Animal feeding stuffs: Methods of sampling and 
analysis - Detection and enumeration of Bacillus 
spp. used as feed additive 

Supports microbiological quality 
control when algae are blended 
with probiotic additives. 

Animal feeding stuffs - Determination of the content 
of fatty acids: Part 1 (Preparation of methyl esters) 
and Part 2 (Gas chromatographic method) 

Essential for profiling the fatty 
acid composition of algae-
derived oils. 

Animal feeding stuffs - Determination of sugar 
content - High-performance exchange 
chromatographic method (HPAEC-PAD) 

Necessary for evaluating 
carbohydrate levels in algae 
feed. 

Animal feeding stuffs: Methods of sampling and 
analysis - Performance criteria for single laboratory 
validated and ring-trial validated methods of analysis 
for the determination of heavy metals 

Animal feeding stuffs: Methods of sampling and 
analysis - Performance criteria for single laboratory 
validated and ring-trial validated methods of analysis 
for the determination of mycotoxins 

Guidelines for validating 
contaminant testing methods. 

Ensures algae feed is free of 
mycotoxins. 

EN 
15781:2009 

Animal feeding stuffs - Determination of 
maduramicin-ammonium by reversed-phase HPLC 
using post-column derivatisation 

Applicable for ensuring safe 
incorporation of complex feed 
additives. 

EN 
15787:2021 

Animal feeding stuffs: Detection and enumeration of 
Lactobacillus spp. used as feed additive 

EN 
15621:2017 

Animal feeding stuffs: Determination of calcium, 
sodium, phosphorus, magnesium, potassium, 
sulphur, iron, zinc, copper, manganese, and cobalt 
after pressure digestion by ICP-AES 

CEN/TS 
15520:2019 

Animal feeding stuffs: Sampling techniques and 
systems 

Relevant for blending algae and 
insect proteins with probiotic feed 
additives. 

Important for determining the 
mineral profile of insect- and fish-
based feed components. 

Offers precise sampling 
standards suitable for insect-
based feed materials. 

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Table 20 – Relevant CEN standards on algae and algae products (CEN 454) 

Committee: CEN/TC 454 “Algae and algae products” 

Reference 

Title 

Scope 

CEN/TR 
17559:2022 

Algae and algae 
products - Food 
and feed 
applications: 
General overview 
of limits, 
procedures, and 
analytical methods 

Provides foundational guidance on limits, procedures, and 
analytical methods for algae-based ingredients in feed. 

EN 
17399:2024  

Algae and algae 
products - 
Vocabulary 

It defines the terms related to functions, products, and properties 
of algae and algae products. It includes microalgae, macroalgae, 
cyanobacteria and Labyrinthulomycetes. 

EN 
17980:2024  

Algae and algae 
products - 
Sampling - 
Guidelines for the 
definition of 
sampling programs 
and sampling 
protocols 

Guidelines for creating sampling programs and protocols for 
algae and algae products. It applies to algae, including 
microalgae, macroalgae, cyanobacteria, and related organisms. It 
outlines key considerations for collecting representative samples. 
This document is to be used for the collection of samples for lot 
characterisation for commercial or legal/regulatory purposes. 

EN 17480:2021 

Algae and algae 
products - Methods 
for the 
determination of 
productivity of 
algae growth sites  

This document specifies the methods to be used for the 
determination of productivity of algae growth sites. This document 
excludes methods for sampling, harvesting and pre-
/postprocessing. Excluded as well is “wild growth”, which is 
defined as algae growing in nature without human interference 
except when harvesting the algae. 

EN 17605:2022 

Algae and algae 
products - Methods 
of sampling and 
analysis - Sample 
treatment 

This document specifies the sample preparation of dry and wet 
samples of algae and algae products. This document enables 
laboratories analysing algae samples to report accurate dry 
weight percentages and to obtain representative samples 
possible for further examination. 

EN 17908:2023 

Algae and algae 
products - Methods 
of sampling and 
analysis – 
Determination of 
total lipids content 
using the 
Ryckebosch -
Foubert method 

This document specifies a laboratory method for the 
determination of the total lipid content in micro- and macroalgae 
by the Ryckebosch-Foubert method. 

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Committee: CEN/TC 454 “Algae and algae products” 

EN 18034:2024 

Algae and algae 
products - Methods 
of sampling and 
analysis - 
Determination of 
chlorophyll a 
content 

EN 17477:2021 

Algae and algae 
products - 
Identification of the 
biomass of 
microalgae, 
macroalgae, 
cyanobacteria and 
Labyrinthulomycete
s - Detection and 
identification with 
morphological 
and/or molecular 
methods 

EN 17983:2024 

Algae and algae 
products - 
Measurement for 
renewable algal 
raw material for 
energy and non-
energy applications 

This document specifies a laboratory method for the 
determination of ‘chlorophyll a’ content in algae. The method was 
initially tested and evaluated on the microalgae species 
Nannochloropsis sp. and a heat-treated algal product tomato 
soup with Nannochloropsis sp. supplement, and the macroalgae 
Ulva sp., Furcellaria lumbricalis, and Saccharina latissima. During 
an Interlaboratory Trial the method was tested on the microalgae 
Nannochloropsis sp. and the macroalgae Saccharina latissima. 
The microalgae Nannochloropsis sp. and Phaeodactylum sp. and 
the macroalgae Ulva sp. and Saccharina latissima were tested in 
a Round Robin test. This document is only validated for 
‘chlorophyll a’, but it can be used for other chlorophylls as well. 

This document specifies a method for the detection and 
identification of microalgae, macroalgae, cyanobacteria and 
Labyrinthulomycetes by using morphological methods and/or 
molecular methods. The morphological methods in this document 
are applicable to harvested wet biomass and to harvested dried 
unground biomass from microalgae, macroalgae, cyanobacteria 
and Labyrinthulomycetes that have been grown and/or harvested 
for further processing and/or use. The molecular methods in this 
document are applicable to harvested wet biomass and to 
harvested dried and/or ground biomass from microalgae, 
macroalgae, cyanobacteria and Labyrinthulomycetes that have 
been grown and/or harvested for further processing and/or use. 
This document describes a toolbox, consisting of several 
identification methods that can be chosen according to the 
applicability and purpose of the identification. This document 
does not deal with genetic purity of the biomass or quantification 
of the identified taxa. This document is not suitable for the 
analysis of highly processed biomass with highly degraded DNA 
where the fragments’ length is not sufficient for amplification of 
the targets and the morphological characteristics cannot be 
assessed. 

This document specifies methods for the measurement of energy 
content and main elements balances of algae from cultivation or 
from wild growth and algae products to provide biomass, intended 
for renewable algal raw material used as bioenergy and in bio-
based products. This document also specifies carbon source 
parameters specific to algae as bio-based and it is applicable to 
studies covering algae production life cycle assessment (LCA) 
e.g. algal biomass farming or wild collection. This document does 
not apply to methods of algae and algae products sampling, 
harvesting and pre/postprocessing. This document does not 
apply to algae and algae products intended for the food and feed 
sector; however, it may be useful also for these applications. 

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Committee: CEN/TC 454 “Algae and algae products” 

Algae and algae products – 

The following 
standards are 
currently under 
drafting by 
committee 
CEN/TC 454: 

•  Determination of the amino acid profile of micro- and macroalgae 
•  Determination of inorganic arsenic in algae and algae products by anion-

exchange (HPLC-ICP-MS) 

•  Nitrogen content measurement and protein content calculation for micro- and 

microalgae 

•  Determination of the uronic acid content of macroalgae biomass 
•  Determination of the phycocyanin content in Arthrospira (Spirulina) 
•  Determination of the fatty acid composition 
•  Determination of the carotenoid content in algae 

Table 21 – Selection of Sustainability-, GHG-, CFP-, LCA-related standards 
applicable to algae 

Standard applicable to algae 

Definition (treatment) 

Number 

Title 

CFP 

Carbon  
Accountin
g 

Carbon  
captur
e 

EN 16751 

Bio-based products – Sustainability criteria 

EN 16760 

Bio-based products – Life cycle assessment 

EN 16848 

Bio‐based products – Requirements for Business-to-
Business communication of characteristics using a 
Data Sheet 

no 

no 

no 

(YES) 

no 

no 

EN 16935 

Bio‐based products – Requirements for Business‐to‐
Consumer communication and claims 

no 

no 

ISO 
14040 

ISO 
14044 

Environmental management — Life cycle 
assessment — Principles and framework 

Environmental management — Life cycle 
assessment — Requirements and guidelines 

no 

no 

no 

no 

no 

no 

no 

no 

no 

no 

EN 17983: 
2024 

Algae and algae products - Measurement for 
renewable algal raw material for energy and non-
energy applications 

EN 18027: 
2025 

Bio-based products - Life cycle assessment - 
Additional requirements and guidelines for comparing 
the life cycles of bio-based products with their fossil-
based equivalents 

YES  YES 

(YES) 

YES 

(YES) 

no 

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Annex II – Calculations 

1.1  FFDR Calculations 

FFDR formula 

FFDR =  eFCR* x  (% forage fishmeal inclusion  + % forage fish oil inclusion) 

       (fishmeal yield (22,5%) +  fish oil yield (5%)) 

(324) 

*The economic FCR (eFCR) is one of the most commonly used versions of the 
FCR that is used to quantify the livestock production efficiency: 

*eFCR =       weight of feed fed      _ 

     weight of fish harvested  

The FFDR can be also calculated individually for fishmeal (FFDRm) and fish oil 
(FFDRo). For example, the ASC uses the following calculations: 

FFDRm =  eFCR* x  (% forage fishmeal inclusion) 

24 

 FFDRo =  eFCR* x            (% forage fish oil inclusion)          _ 
   5.0 or 7.0 (depending on source of fish) 

(325) 

It is important to note, that fishmeal and fish oil that was obtained from fishery by-
products (e.g. trimmings or offal) is excluded from these equations. 

Formula example with 5% algae 

Taking  into  consideration  the  current  values  (“FFDR  development  and  current 
values”) as well as the assumptions mentioned in “Calculation for a hypothetical 
inclusion  of  5%  algal  ingredients”  of  Chapter  3.2.2,  the  FFDR  calculation  with 
feed including 5% algal ingredients would result in: 

(324) IFFO (n.d.). FFDR Data. 
(325) ASC, “ASC Salmon Standard Version 1.4.” 

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FFDR (salmonids) = 1.27 x        (9.9%)          = 0.46 

              (22.5% + 5%) 

An inclusion of a total of 5% algal ingredients could result in a  reduction of the 
current FFDR (0.68 in 2020) for salmonids by about 32%. 

FFDR (marine finfish) = 0.86  x       (12.4%)          = 0.39 

                     (22.5% + 5%) 

An inclusion of a total of 5% algal ingredients could result in a reduction of the 
current FFDR (0.53 in 2020) for marine finfish by about 26%. 

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Annex III – Multi Criteria Analysis (MCA) 

1.1 

Identification of Criteria 

Fish and Feed Performance Criteria 

This category encompasses five criteria which collectively describe the effect of 
each feed option on fish performance in terms of their growth, health and quality. 
More specifically, this category includes the following criteria:  

1.  Feed conversion ratio (FCR) 

The FCR is a cornerstone metric in aquaculture that measures the efficiency of 
feed utilisation. Feed formulations are developed in a way to maximise the FCR, 
a  critical  factor  in  enhancing  fish  production (326).  It  is  calculated  using  the 
formula: 

FCR = Fish-feed consumed [kg]  
            Fish-weight gained [kg]            

FCR indicates how effectively a fish converts feed into body mass; the lower the 
FCR, the more efficient the feed. Optimising FCR not only enhances production 
efficiency but also reduces feed waste, minimises environmental pollutants (e.g., 
uneaten feed contributing to eutrophication), and lowers lifecycle greenhouse gas 
emissions (327). 

2.  Specific growth rate (SGR) 

The SGR measures the daily growth of fish as a percentage of their body weight 
and is a direct indicator of growth performance under different feed regimes. It is 
calculated using the formula: 

SGR = 100 x (Final weight − Initial weight)   
                            number of days fed 

A  higher  SGR  indicates  better  growth,  which  translates  to  shorter  production 
cycles  and  improved  economic  viability.  SGR  is  a  critical  measure  for 

(326) Yarnold et al. (2019) “Microalgal Aquafeeds As Part of a Circular Bioeconomy,”  Trends in 
Plant Science 24(10). https://doi.org/10.1016/j.tplants.2019.06.005 
(327)  Ahmad,  A.,  Hassan,  S.W.,  Banat,  F.  (2022).  An  overview  of  microalgae  biomass  as  a 
sustainable  aquaculture  feed  ingredient:  food  security  and  circular  economy,  Bioengineered, 
13(4). https://doi.org/10.1080/21655979.2022.2061148  

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understanding  the  biological  effectiveness  of  different  feed  compositions  and 
their compatibility with the selected fish species. 

3.  Fish health 

Fish health encompasses several parameters, including mortality rates, physical 
health issues (e.g., gut health or disease resistance), and potential health benefits 
attributed  to  feed  composition.  Fish  health  directly  influences  overall  fish  farm 
productivity, ecosystem health, and the perception of aquaculture products in the 
market. 

4.  Fish quality 

Fish  quality  reflects  the  commercial  value  of  the  final  product,  focusing  on 
attributes  such  as  texture,  taste,  colour,  and  overall  consumer  acceptability. 
These parameters are influenced by feed composition, particularly the inclusion 
of  alternative  ingredients  like  algae  or  insect  protein,  which  may  impact  the 
nutritional profile and characteristics of fish. 

5.  Contaminants in feed 

The  potential  presence  of  contaminants,  such  as  dioxins,  polychlorinated 
biphenyls  (PCBs),  and  persistent  organic  pollutants  (POPs),  is  a  critical 
consideration. These substances can accumulate in fish tissue, posing risks to 
human health and market acceptance. 

Economic Criteria 

1.  Production costs 

This  criterion  represents  the  cost  of  producing  each  feed  type,  including  the 
sourcing  and  processing  of  ingredients,  labour,  and  transportation.  Production 
cost is a key factor influencing the feasibility and scalability of alternative feeds. 

2.  Retail price 

The  price  at  which  feed  is  sold  to  aquaculture  producers  reflects  not  only  the 
production cost but also market dynamics and profit margins. This criterion was 
evaluated to understand the economic competitiveness of each feed type and its 
affordability for farmers.  

3.  Price stability 

Price  stability  measures  the  consistency  of  feed  costs  over  time,  a  critical 
consideration for producers managing long-term budgets. Factors influencing this 
criterion include the availability of raw materials, market volatility, and geopolitical 
factors. 

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Environmental criteria 

1.  Environmental impact from feed production 

This  criterion  assesses  the  resource  intensity  and  ecological  footprint  of  feed 
production. It includes metrics such as land use (i.e. the amount of land required 
for  cultivating  feed  ingredient),  freshwater  use  (i.e.  water  consumed  during 
production processes), energy use (i.e. total energy input, including fossil fuels 
and electricity), and Greenhouse Gas emissions (i.e. emissions associated with 
production and transportation of feed ingredients). 

2.  Forage Fish Dependency Ratio (FFDR) 

This ratio is a critical indicator of sustainability, reflecting the pressure placed on 
marine  ecosystems.  The  FFDR  measures  the  reliance  on  wild-caught  fish  for 
producing  fishmeal  and  fish  oil  in  aquafeeds.  The  formula  for  its  calculation  is 
listed in Annex II Section 9.6. 

Lower FFDR values are preferable, signalling reduced dependency on forage fish 
and  greater  alignment  with  environmental  sustainability  and  biodiversity 
protection  goals.  The  formula  indicates  the  quantity  of  wild  (forage)  fish  that  is 
used in feeds in relation to the quantity of fed animal production. It is important to 
note that fish oil or fishmeal from by-products are not included in the formula.  

While the FFDR has been reduced significantly within the past decades (328), it 
can  be  further  reduced  by  incorporating  alternative  ingredients  to  replace 
fishmeal or fish oil derived from forage fish. 

1.2  Allocation of weights to criteria 

Fish and Feed performance criteria 

Within  the  Feed  and  Fish  Performance  category,  five  distinct  criteria  were 
considered:  Feed  Conversion  Ratio  (FCR),  Specific  Growth  Rate  (SGR),  Fish 
Health, Fish Quality, and Contaminants. Each of these criteria was assigned a 
specific  weight  based  on  its  perceived  importance  to  overall  feed  efficacy  and 
aquaculture profitability. 

FCR  received  the  largest  weight  (30%)  because  it  is  recognised  as  the  most 
critical  parameter  for  feed  evaluation.  This  was  emphasised  repeatedly  by 
stakeholders during the workshop, as FCR directly determines the feed efficiency 

(328) “FFDR Data | IFFO - The Marine Ingredients Organisation.” “FFDR Data | IFFO - The Marine 
Ingredients Organisation.” 

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and  profitability  for  fish  farmers.  If  a  feed  fails  to  optimise  the  feed-to-growth 
conversion, it will not be adopted by farmers regardless of its other benefits. From 
a business standpoint, achieving a low FCR ensures that production costs remain 
competitive while maximising outputs. 

The SGR, although related to growth, was deliberately assigned a lower weight 
(15%). The reasoning behind this decision was to avoid overemphasising growth 
parameters and skewing the analysis. Stakeholders agreed that while growth is 
important,  it  overlaps  substantially  with  FCR  and  giving  both  SGR  and  FCR  a 
high weight would disproportionally emphasise these factors at the expense of 
others. 

Fish health was assigned a weight of 25%, since it is considered as one of the 
most  important  factors  in  aquaculture  systems.  Feed  directly  impacts  fish 
mortality  rates,  and  poor  fish  health  has  significant  repercussions  on  farm 
productivity,  costs,  and  profitability.  Fish  farmers  depend  on  consistent  fish 
survival  rates  to  ensure  stable  production  outputs  and  returns  on  their 
investments. If the mortality rate is very high, the resulting economic losses will 
outweigh any gains achieved through optimised FCR or growth. 

The  weight  for  fish  quality  was  set  at  20%.  While  not  as  central  to  farm 
productivity as FCR or health, fish quality is critical to meeting market demand. 
Consumers demand high-quality fish, and failure to meet these expectations can 
result in reduced marketability and sales. Stakeholders recognised that, although 
farmers  focus  on  operational  metrics  like  growth  and  survival,  the  ultimate 
success  of  aquaculture  relies  on  delivering  fish  products  that  meet  consumer 
preferences. 

the 

Finally,  contaminants  were  assigned 
lowest  weight  (10%).  While 
contamination is undoubtedly a concern, workshop participants indicated that it 
was not as pressing as the other performance criteria. This could be attributed to 
existing feed production standards and quality control measures, which mitigate 
contamination risks. Additionally, participants may have perceived contaminants 
as less critical when compared to factors that directly influence profitability and 
farm productivity. 

Economic criteria 

The  economic  criteria  were  divided  into  three  components:  Production  Costs, 
Retail Selling Price, and Price Stability. The allocation of weights to these criteria 
reflects their differing roles in determining the economic viability of feed options. 

Price stability received the highest weight (35%), as stakeholders emphasised 
its  importance  for  long-term  planning  and  operational  stability.  Price  stability 
allows  farmers  to  forecast  costs  accurately  and  plan  production  cycles  with 

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confidence.  By 
predictability and mitigates risks associated with market fluctuations. 

reducing  economic  uncertainty,  stable  pricing  ensures 

Production costs also received a weight of 35%, highlighting its significance for 
feed producers. While production costs do not directly impact fish farmers' profit 
margins,  they  play  a  critical  role  in  determining  the  price  of  feed  products.  If 
production  costs  are  excessively  high,  feed  manufacturers  will  face  pricing 
limitations,  as  exorbitant  prices  could  deter  customers.  To  remain  competitive, 
feed  producers  must  balance  production  costs  with  market  demand,  which 
highlights the importance of this criterion. 

Retail selling price was assigned a slightly lower weight (30%). Although selling 
price influences farmer profitability, stakeholders recognised that the profit margin 
remains  relatively  stable  across  feed  options.  In  other  words,  the  relationship 
between production costs and selling price is tightly controlled, limiting its overall 
impact. Therefore, while retail price is important, it was considered slightly less 
influential than production costs and price stability. 

Environmental criteria 

The environmental criteria were divided into two equally weighted components: 
Environmental Impact from Feed Production and Forage Fish Dependency 
Ratio (FFDR), each receiving a weight of 50%. The equal allocation reflects that 
environmental damage cannot be prioritised – biodiversity loss and pollution are 
equally  detrimental  and  cannot  be  measured  against  one  another  in  terms  of 
severity. 

The  inclusion  of  FFDR  addresses  a  specific  environmental  concern  often 
overlooked in traditional LCAs, that is the impact of feed production on marine 
biodiversity. High FFDR values indicate a greater dependency on wild fish stocks, 
contributing  to  overfishing  and  posing  a  threat  to  marine  ecosystems. 
Stakeholders  emphasised  the  need  to  consider  FFDR  alongside  traditional 
environmental  impact  metrics  to  ensure  a  more  comprehensive  evaluation  of 
environmental sustainability and address often-overlooked aspects of resource 
dependency. 

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1.3  List of literature sources utilised for the MCA 

•  EUMOFA (2023) (329) 
•  Kok et al. (2020) (330) 
•  Jensen et al. (2020) (331) 
•  Nagappan (2021) (332) 
•  Tibbetts et al. (2020) (333) 
•  Fry et al. (2016) (334) 
•  Santigose et al. (2021) (335) 
•  Samuelsen et al. (2024) (336) 
•  FAO (2024) (337) 
•  Santigosa et al. (2023) (338) 
•  Zlaugotne et al. (2023) (339) 
•  Liu et al. (2020) (340) 
•  Nøstbakken (2015) (341) 

of 

Fed 

Major 

Species,” 

Aquaculture 

Aquaculture 

(329) EUMOFA (2023). Fishmeal and Fish Oil. Available here. 
(330) Kok et al. (2020). “Fish as Feed: Using Economic Allocation to Quantify the Fish In : Fish Out 
Ratio 
528:735474, 
https://doi.org/10.1016/j.aquaculture.2020.735474  
(331) Jensen et al. (2020) “An Update on the Content of Fatty Acids, Dioxins, PCBs and Heavy 
Metals in Farmed, Escaped and Wild Atlantic Salmon (Salmo Salar L.) in Norway,” Foods 9, 12: 
1901, https://doi.org/10.3390/foods9121901  
(332)  Nagappan  et  al.  (2021),  “Potential  of  Microalgae  as  a  Sustainable  Feed  Ingredient  for 
Aquaculture,” Journal of Biotechnology 341(20). https://doi.org/10.1016/j.jbiotec.2021.09.003 
(333) Tibbetts et al. (2020), “Apparent Digestibility of Proximate Nutrients, Energy and Fatty Acids 
in  Nutritionally-Balanced  Diets  with  Partial  or  Complete  Replacement  of  Dietary  Fish  Oil  with 
Microbial Oil from a Novel Schizochytrium Sp. (T18) by Juvenile Atlantic Salmon (Salmo Salar 
L.),” Aquaculture 520:735003, https://doi.org/10.1016/j.aquaculture.2020.735003  
(334)  P.  Fry  et  al.  (2016)  “Environmental  Health  Impacts  of  Feeding  Crops  to  Farmed  Fish,” 
Environment International 91:201–14, https://doi.org/10.1016/j.envint.2016.02.022  
(335) Santigosa, Brambilla, and Milanese (2021) “Microalgae Oil as an Effective Alternative Source 
of  EPA  and  DHA  for  Gilthead  Seabream  (Sparus  Aurata)  Aquaculture.”  Animals,  11(4),  971; 
https://doi.org/10.3390/ani11040971  
(336) Samuelsen, Kousoulaki, and Bogevik (2024). “Microalgae Suspension as a Source of N-3 
Long-Chain  PUFA  in  Feed  for  Atlantic  Salmon  (Salmo  Salar  L)  –  Technical  Constraints  and 
Nutritional Quality.” Aquaculture 581. https://doi.org/10.1016/j.aquaculture.2023.740459 
(337) FAO “The State of World Fisheries and Aquaculture 2024.” Available here. 
(338)  Santigosa  et  al  “Algal  Oil  Gives  Control  of  Long-Chain  Omega-3  Levels  in  Full-Cycle 
Production  of  Atlantic  Salmon,  without  Detriment  to  Zootechnical  Performance  and  Sensory 
Characteristics.” 
54(4). 
https://doi.org/10.1111/jwas.12947 
(339)  Zlaugotne  et  al.  (2023)  “Life  Cycle  Assessment  of  Fish  Feed  for  Oil  Alternatives  - 
Environmental Impact of Microalgae, Rapeseed and Fish Oil,” https://doi.org/10.15159/AR.23.074  
(340)  Cui  Liu  et  al.  (2022)  “Utilization  of  Nannochloropsis  Oceanica  in  Plant-Based  Feeds  by 
738651, 
Salar),” 
Atlantic 
https://doi.org/10.1016/j.aquaculture.2022.738651  
(341)  Ole  Jakob  Nøstbakken  et  al.  (2015)  “Contaminant  Levels  in  Norwegian  Farmed  Atlantic 
Salmon (Salmo Salar) in the 13-Year Period from 1999 to 2011,” Environment International 74: 
274–80, https://doi.org/10.1016/j.envint.2014.10.008  

Aquaculture 

Aquaculture 

Salmon 

Society 

Journal 

(Salmo 

World 

561: 

the 

of 

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•  Eroldoğan (2022) (342) 
•  Davis et al. (2021) (343) 
•  Biancarosa et al. (2019) (344) 
•  Belforti et al. (2015) (345) 
•  Hamann & Jacobsen (2018) (346) 
•  Scholz et al. (2021) (347) 
•  Reyes et al. (2020) (348) 
•  Modahl & Brekke (2021) (349) 
•  Tschirner & Kloas (2017) (350) 
•  Black et al. (2023) (351)  
•  Arru et al. (2019) (352) 
•  Sánchez-Muros et al. (2015) (353) 
•  Tran et al. (2021) (354) 
•  Su et al. (2023) (355). 

& 

Risk 

36(8), 

Assessment, 

(342)  Eroldoğan  et  al  (2022).  “From  the  Sea  to  Aquafeed.”  Reviews  in  Aquaculture  15(3). 
https://doi.org/10.1111/raq.12740  
(343) Davis et al. (2021) “Life Cycle Assessment of Heterotrophic Algae Omega-3.” Algal Research 
60: 102494. https://doi.org/10.1016/j.algal.2021.102494 
(344) Biancarosa, I., et al. (2019). Replacing fish meal with insect meal in the diet of Atlantic salmon 
(Salmo salar) does not impact the amount of contaminants in the feed and it lowers accumulation 
of  arsenic  in  the  fillet.  Food  Additives  &  Contaminants:  Part  A  -  Chemistry,  Analysis,  Control, 
Exposure 
1191-1205. 
https://doi.org/10.1080/19440049.2019.1619938  
(345) Belforti et al “Tenebrio Molitor Meal in Rainbow Trout (Oncorhynchus Mykiss) Diets.” Italian 
Journal of Animal Sciences 14(4). https://doi.org/10.4081/ijas.2015.4170  
(346) Hamann and Jacobsen (2018), “Microalgae for Salmon Feed,” Available here. 
(347) Bettina Scholz et al. (2021) Northern Icelandic Marine Microalgae as Health Promoting Multi-
Functional  Feed  Protein  and  Lipid  Source  for  Atlantic  Salmon  (Salmo  Salar)  -  A  Whole  Algae 
Concept.” DOI:10.13140/RG.2.2.25481.98405 
(348)  Reyes  et  al  “Nutritional  and  Growth  Effect  of  Insect  Meal  Inclusion  on  Seabass 
(Dicentrarchuss Labrax) Feeds.” Fishes 2020, 5(2). https://doi.org/10.3390/fishes5020016 
(349)  Modahl  and  Brekke  (2022)  “Environmental  performance  of  insect  protein:  a  case  of  LCA 
4(6). 
results 
http://dx.doi.org/10.1007/s42452-022-05065-1   
(350) Tschirner and Kloas (2017). “Increasing the Sustainability of Aquaculture Systems: Insects 
as  Alternative  Protein  Source  for  Fish  Diets,”  GAIA  -  Ecological  Perspectives  for  Science  and 
Society 26, no. 4, 332–40, https://doi.org/10.14512/gaia.26.4.10  
(351) Black, Keyserlingk, and Lattanzi (2023) “Delivering Insect-Based Feed at Scale.” Available 
here. 
(352) Brunella Arru et al. (2019). “The Introduction of Insect Meal into Fish Diet: The First Economic 
Analysis 
1697, 
Sea 
https://doi.org/10.3390/su11061697  
(353) M. Sánchez-Muros et al. (2015). “Nutritional Evaluation of Tenebrio Molitor Meal as Fishmeal 
Substitute for Tilapia (Oreochromis Niloticus) Diet,” Aquaculture Nutrition 22, no. 5 (2015): 943–
55, https://doi.org/10.1111/anu.12313  
(354) Van Tran, Van Doan, and Stejskal (2021). “Environmental Consequences of  Using Insect 
Meal 
14(1). 
an 
https://doi.org/10.1111/raq.12595  
(355) Su et al “Applications of Microalgae in Foods, Pharma and Feeds and Their Use as Fertilizers 
and Biostimulants.” Foods, 12(20), 3878. https://doi.org/10.3390/foods12203878  

in  Norway”  SN  Applied  Sciences 

Aquafeeds.”  Reviews 

Sustainability 

Aquaculture 

Ingredient 

European 

Farming,” 

produced 

Bass 

feed 

fish 

11, 

for 

on 

as 

6: 

in 

in 

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Annex IV – Strategies and financial incentive    
systems used in primary production sector 

1.1  Overview of the strategies and financial incentive 

systems used in the agriculture sector 

1.1.1  Direct financial support 

Direct  financial  support  mechanisms  provide  immediate  financial  assistance  to 
farmers,  helping  to  offset  the  costs  of  adopting  sustainable  practices  while 
ensuring  income  stability.  These  mechanisms  are  central  to  the  CAP,  which 
allocates significant funding to promote environmentally responsible farming. The 
primary instruments within this category include subsidies, grants, and income 
transfers: 

•  Subsidies  are  direct  payments  designed  to  ensure  farmers'  economic 
viability while encouraging sustainable practices. The CAP’s Basic Income 
Support  for  Sustainability  (BISS)  provides  financial  stability  to  farmers 
adhering  to  environmental  requirements.  Additionally,  eco-schemes, 
which constitute at least 25% of direct payments, incentivise sustainable 
agricultural practices, such as crop diversification, soil conservation, and 
reduced  pesticide  use.  Beyond  direct  payments,  rural  development 
programmes  can  be  used  to  fund  targeted  actions  such  as  organic 
farming, integrated pest management, and agroforestry. 

•  Grants, distinct from subsidies, are one-time financial awards that support 
research,  infrastructure  development,  and  pilot  projects.  For  example, 
rural development programmes and Horizon Europe funding programme 
co-finance  projects  that  improve  environmental  performance,  such  as 
renewable energy installations and sustainable irrigation systems. These 
grants ensure that innovative, sustainable farming practices can be tested 
and implemented effectively. 
Income transfers provide financial compensation to farmers for income 
losses  associated  with  sustainable  practices.  They 
include  direct 
payments  linked  to  environmental  compliance  and  compensation  for 
ecosystem  services,  such  as  carbon  sequestration  and  water  quality 
improvement. These transfers ensure that farmers do not suffer economic 
disadvantages when transitioning to more sustainable practices. 

• 

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1.1.2  Market-based instruments 

Market-based  instruments  influence  market  conditions  to  promote  sustainable 
practices by creating financial incentives for producers to adopt environmentally 
friendly methods. These instruments include price support mechanisms, fiscal 
measures, and payments for ecosystem services (PES): 

•  Price  support  mechanisms  stabilise  or  enhance  the  market  prices  of 
sustainably  produced  goods,  ensuring  competitive  pricing  against 
conventional  alternatives.  Public  procurement  programmes  create 
guaranteed  demand  for  sustainable  agricultural  products,  mitigating 
financial  risks  for  producers.  CAP  provides  price  support  mechanisms, 
to  stabilise 
including  public 
agricultural markets during price fluctuations. 

intervention  and  private  storage  aid, 

•  Fiscal measures use taxation policies to encourage sustainable farming 
practices.  Tax  breaks,  such  as  VAT  reductions  for  sustainable  inputs, 
incentivise the adoption of environmentally friendly methods. Conversely, 
input  taxes  on  synthetic  fertilisers  and  pesticides  deter  environmentally 
harmful practices by increasing their cost. However, studies indicate that 
tax exemptions often impose significant revenue losses on governments 
without yielding commensurate sustainability benefits.  

•  PES provide financial compensation to farmers who adopt practices that 
deliver measurable environmental benefits. CAP facilitates PES through 
financial incentives for carbon sequestration, habitat restoration, and water 
management initiatives.  

1.1.3  Trade policy tools 

Trade  policy  tools  regulate  international  trade  to  promote  sustainability  in 
agriculture. These tools influence both export promotion and import regulation 
to support sustainable farming practices: 

• 

•  Export  promotion  initiatives  raise  awareness  of  the  sustainability  and 
quality  of  EU  agricultural  products,  helping  farmers  access  premium 
markets.  The  EU  allocates  substantial  funding  to  promotion  campaigns 
that  highlight  organic  farming  and  sustainable  agricultural  products, 
improving their competitiveness; 
Import regulation and trade policy tools can include differentiated tariffs 
for sustainable products. While the EU has yet to introduce tariff reductions 
specifically  for  sustainable  agricultural  goods,  it  integrates  sustainability 
clauses into trade agreements. The EU’s regulatory framework also seeks 
to restrict the import of products linked to deforestation and unsustainable 
agricultural practices,  aligning  trade  policies  with  broader environmental 
objectives. 

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1.1.4  Risk-sharing instruments 

Risk-sharing  instruments  mitigate  the  financial  risks  associated  with  adopting 
sustainable  practices,  making  it  easier  for  farmers  to  invest  in  environmentally 
responsible methods. These mechanisms include guarantees, which reduce the 
risk  for  lenders  by  assuring  partial  repayment  in  case  of  default,  and 
concessional loans, which offer favourable terms  (e.g., below-market interest 
rates  or  extended  repayment  periods),  that  facilitate  access  to  capital  for 
sustainable farming investments. 

The  CAP  integrates  financial  instruments  such  as  loan  guarantees  and 
microcredit  schemes,  supporting  farmers  and  agribusinesses  investing  in 
sustainability. Many EU Member States have adopted these instruments to attract 
additional capital and maximise the impact of their public resources. By reducing 
the  financial  risks,  risk-sharing  mechanisms  increase  financial  flows  towards 
projects that support sustainable agriculture. 

1.1.5  Support mechanisms 

Support  mechanisms  enhance  the  effectiveness  of  financial  incentives  by 
providing  farmers  with  access  to  knowledge,  training,  and  tools  needed  to 
implement  sustainable  practices  successfully.  These  mechanisms  include 
technical  assistance  programmes,  knowledge  transfer  initiatives,  and 
certification schemes: 

•  Technical  assistance  programmes  provide  farmers  with  advisory 
services,  training,  and  access  to  demonstration  farms.  The  EU’s  Farm 
Advisory System (FAS) supports farmers in complying with environmental 
regulations  and  accessing  digital  tools,  such  as  farm  management 
software and remote sensing technologies, assisting farmers in optimising 
resource use and minimising environmental impact;  

•  Knowledge  transfer  initiatives  bridge  the  gap  between  research  and 
practical application. The European Innovation Partnership for Agricultural 
Productivity and Sustainability (EIP-AGRI) connects researchers, farmers, 
and  policymakers  to  develop  and  share  best  practices  in  sustainable 
farming. The EU CAP Network facilitates information exchange, enabling 
farmers to adopt innovative, environmentally friendly techniques;  

•  Certification  schemes  allow  farmers  to  demonstrate  adherence  to 
sustainability  standards,  granting  access  to  premium  markets.  The  EU 
Organic  Logo,  for  instance,  certifies  products  produced  under  strict 
organic  farming  regulations,  ensuring  compliance  with  biodiversity 
conservation and resource efficiency principles. These schemes enhance 
consumer  confidence 
in  sustainable  agricultural  products  while 
incentivising environmentally responsible farming practices. 

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1.2  Strategies and financial incentive systems used in 

primary production sector 

Financial incentives have long been a cornerstone of policy interventions aimed 
at  promoting  sustainable  practices  in  primary  production  sectors,  such  as 
agriculture, forestry, and fisheries. These incentives – ranging from subsidies and 
tax  breaks  to  grants  and  market-based  mechanisms  –  are  designed  to  align 
economic objectives with environmental and social goals, encouraging producers 
to  adopt  practices  that  reduce  environmental  impact,  enhance  resource 
efficiency, and conserve biodiversity. In the EU, financial incentives have played 
a pivotal role in driving the adoption of sustainable agriculture, as evidenced by 
initiatives under the Common Agricultural Policy (CAP) and the European Green 
Deal. For instance, direct payments for organic farming have incentivised farmers 
to  transition  towards  more  sustainable  production  systems,  leading  to  a  more 
than  50%  increase  in  the  share  of  EU  agricultural  land  under  organic  farming 
between  2012  and  2020,  with  an  average  annual  growth  rate  of  5.7%  (356).  In 
addition  to  direct  payments,  several  other  instruments  have  been  used  in 
agriculture  to  incentivise  sustainable  practices  and  environmental  protection. 
However, the effectiveness of these instruments varies, and their transferability 
to other sectors, such as aquaculture, remains an open question. 

these  adoptions.  The  study  analysed 

Piñeiro et al. (357) conducted a scoping review to explore how different incentives 
encourage farmers to adopt sustainable agricultural practices and the resulting 
impacts  of 
three  categories  of 
incentives: market-based  incentives  (e.g.  adjustments  in  input/output  prices, 
income  transfers,  and  subsidies)  and  non-market  incentives  (e.g.  technical 
assistance,  fiscal  policies,  and  taxation);  regulatory  measures,  such  as 
environmental 
laws,  standards,  or  certifications;  and  cross-compliance 
mechanisms that compensate farmers for adhering to environmental standards. 
Drawing on Piñeiro et al.’s (358) framework, this analysis adapts and expands the 
categorisation  to  better  capture  the  range  of  financial  incentives  relevant  to 
sustainable  agriculture  and  their  potential  applicability  to  aquaculture.  The 
revised categorisation is as follows: 

•  Direct Financial Support: mechanisms that  provide direct  payments  to 
farmers  to  offset  costs  or  reward  sustainable  practices,  including 
subsidies, grants, and income transfers; 

(356) Directorate-General for Agriculture and Rural Development (2023), “Organic Farming in the 
EU: A Decade of Growth,” Available here. 
(357) Valeria Piñeiro et al. (2020) “A Scoping Review on Incentives for Adoption of Sustainable 
Agricultural  Practices  and  Their  Outcomes,”  Nature  Sustainability  3,  10:  809–20, 
https://doi.org/10.1038/s41893-020-00617-y  
(358) Valeria Piñeiro et al. (2020) “A Scoping Review on Incentives for Adoption of Sustainable 
Agricultural  Practices  and  Their  Outcomes,”  Nature  Sustainability  3,  10:  809–20, 
https://doi.org/10.1038/s41893-020-00617-y 

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•  Market-Based Financial Instruments: tools that alter market conditions 
to  promote  sustainable  practices.  Examples  include  price  support 
mechanisms,  fiscal  measures  (e.g.,  tax  breaks),  and  payments  for 
ecosystem services (PES); 

•  Trade  Policy  Tools: measures 

to  promote 
sustainability, including differentiated import duties and tariff reductions for 
sustainably produced goods or inputs; 

influence 

trade 

that 

•  Risk-Sharing  Instruments: financial  tools  that  reduce  risk  and  support 
investment in sustainable practices, including guarantees and loans; 

•  Support  Mechanisms: initiatives 

the  adoption  of 
sustainable  practices  through  technical  assistance,  knowledge  transfer, 
and certification schemes. 

facilitate 

that 

1.2.1  Direct Financial Support 

Direct  financial  support  mechanisms  provide  farmers  with  immediate  financial 
assistance  to  offset  the  costs  of  adopting  sustainable  practices  or  to  reward 
environmentally beneficial outcomes. These mechanisms are designed to make 
sustainable  agriculture  economically  viable  by  reducing  financial  barriers  and 
ensuring 
to  more 
environmentally  friendly  methods.  In  the  EU,  direct  financial  support  is  a 
cornerstone  of  the  CAP,  which  allocates  significant  funding  to  promote 
sustainable  farming  practices  (359).  The  primary  instruments  for direct  financial 
support  employed  in  the  EU  include  subsidies,  grants,  and  income  transfer 
mechanisms.  

farmers  are  not  disadvantaged  by 

transitioning 

that 

Subsidies 

Subsidies  are  direct  financial  payments  provided  to  farmers  to  ensure  income 
stability  and  offset  the  costs  of  adopting  sustainable  practices  or  to  reward 
environmentally beneficial outcomes. Subsidies are a central component of the 
EU’s CAP, which allocates significant funding to support sustainable agriculture. 
The CAP 2023-2027 provides a wide range of environment- and climate-related 
subsidies,  designed  to  incentivise  sustainable  practices  while  ensuring  the 
economic  viability  of  farming.  The  primary  tool  for  promoting  sustainable 
agriculture  is  direct  payments  linked  to  environmental  practices.  These 
payments  provide 
farmers  who  comply  with  basic 
to 
environmental  standards,  such  as  maintaining  permanent  grassland  and 
protecting wetlands. The Basic Income Support for Sustainability (BISS) is one 
of these mechanisms, which ensures that farmers receive a stable income stream 

income  support 

(359)  European  Commission  (2023)  “Approved  28  CAP  Strategic  Plans  (2023-2027)  Summary 
Overview for 27 Member States Facts and Figures.” Available here. 

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while  adhering  to  environmental  requirements.  Additionally,  eco-schemes, 
representing at least 25% of the direct payments, offer voluntary payments for 
practices  with  proven  environmental  and  climate  benefits,  such  as  crop 
diversification, soil conservation, and reduced pesticide use.  

Beyond direct payments, rural development programmes under the CAP offer 
additional  subsidies  to  support  sustainable  agriculture.  Agri-Environment-
Climate  Measures  (AECMs)  further  support  targeted  actions  that  enhance 
biodiversity,  reduce  greenhouse  gas  emissions,  and  improve  soil  and  water 
quality. These measures include payments for organic farming, integrated pest 
management, and conservation techniques like reduced tillage and agroforestry. 
CAP’s  environmental  performance  is  reinforced  through  cross-compliance 
requirements  that  link  CAP  payments  to  specific  environmental  standards, 
ensuring that farmers adhere to sustainable practices. 

Grants 

While subsidies and grants are often used interchangeably, here grants refer to 
one-time  or  project-based  financial  support  for  specific  initiatives,  such  as 
research,  infrastructure  development,  or  pilot  projects.  Unlike  subsidies,  which 
provide ongoing payments, grants are typically competitive and tied to achieving 
specific milestones or outputs. Under the CAP, grants are often delivered through 
rural  development  programmes  and  Horizon  Europe,  which  fund  projects  that 
promote  sustainable  agriculture.  Horizon  Europe  grants  fund  research  and 
innovation  projects  in  sustainable  farming  technologies,  such  as  precision 
agriculture tools and climate-resilient crops. Rural development grants support 
infrastructure  projects  that  improve  environmental  performance,  such  as 
renewable  energy  installations,  water-saving  irrigation  systems,  and  manure 
management facilities. Additionally, these grants can provide training to farmers 
in sustainable practices. 

Income transfers 

that 

farmers  are  not 

Income  transfers  are  payments  made  to  farmers  to  compensate  for  income 
losses or additional costs associated with sustainable practices. These transfers 
ensure 
financially  disadvantaged  by  adopting 
environmentally  friendly  methods,  making  sustainable  agriculture  economically 
viable. Unlike subsidies, which are often tied to specific practices or outcomes, 
income transfers focus on providing financial stability and compensating farmers 
for the broader economic challenges they face. 

Key examples of income transfer under the CAP include direct payments based 
on  the  size  of  their  land  and  their  adherence  to  environmental  standards  and 
compensation  for  ecosystem  services  to  farmers  who  provide  measurable 

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environmental  services,  such  as  carbon  sequestration,  habitat  restoration,  or 
water  quality  improvement.  Income  transfers  also  include  payments  to  offset 
income losses due to extreme weather events or market disruptions. 

1.2.2  Market-based financial instruments 

Market-based instruments are financial mechanisms that alter market conditions 
to promote sustainable practices, creating economic incentives for producers to 
adopt environmentally friendly methods. In the context of EU agriculture, these 
instruments  have  been  widely  used  to  encourage  the  adoption  of  sustainable 
practices,  such  as  organic  farming,  conservation  agriculture,  and  precision 
farming (360). The primary market-based instruments employed in the EU include 
price  support  mechanisms,  fiscal  measures,  and  payments  for  ecosystem 
services, each of which plays a distinct role in shaping producer behaviour and 
market dynamics. 

Price support 

Price support mechanisms stabilise or increase the market prices of sustainably 
produced  agricultural  goods,  either  to  create  stable  markets  for  sustainable 
products or make them more competitive compared to conventional substitutes. 
These  mechanisms  are  designed  to  create  a  stable  market  for  sustainable 
products,  reducing  the  financial  risk  for  farmers  who  adopt  environmentally 
friendly  practices.  By  ensuring  minimum  prices,  governments  seek  to  offer 
farmers a more stable and potentially higher income compared to what they might 
earn in an open market. This stability can incentivise investments in farming and 
encourage 
techniques.  However, 
implementing  public  procurement  programmes  is  often  complex,  demanding 
significant  organisational  capacity  and  expertise  within  the  responsible  public 
institutions. In addition, from a fiscal standpoint, these programmes can be costly 
for  governments,  particularly  if  the  prices  paid  to  farmers  exceed  prevailing 
market rates (361). 

improved  production 

the  adoption  of 

Although  to a  lesser extent  than  direct  payments,  the  CAP  also  provides  price 
support mechanisms designed to stabilise agricultural markets, ensure fair prices 
for farmers, and maintain the supply of high-quality products. These mechanisms 
are particularly important for sectors that are vulnerable to market volatility, such 
as  dairy,  cereals,  and  meat.  Such  measures  offered  by  CAP  include  public 
intervention, private storage aid and exceptional measures. Public intervention 

(360)  European  Commission  (2023)  “Approved  28  CAP  Strategic  Plans  (2023-2027)  Summary 
Overview for 27 Member States Facts and Figures.” Available here. 
(361) Bellmann (2019)  “Subsidies and  Sustainable Agriculture:  Mapping the  Policy Landscape.” 
Available here. 

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involves the purchase of agricultural products by public authorities when market 
prices fall below a predefined threshold. This mechanism helps stabilise prices 
by reducing oversupply and providing a safety net for farmers. Private storage 
aid provides financial support to private operators who store certain agricultural 
products during periods of market imbalance. By temporarily removing products 
from  the  market,  this  mechanism  helps  stabilise  prices  and  prevent  sharp 
declines. In cases of severe market disruption, the CAP allows for exceptional 
measures to stabilise prices and support farmers. These measures can include 
temporary import restrictions, export subsidies, or direct aid to producers. 

Fiscal measures 

Fiscal measures are financial tools used by governments to influence behaviour 
through taxation policies. In the context of agriculture, these measures include 
both tax breaks and input taxes, which aim to promote sustainable practices while 
discouraging environmentally harmful activities. Tax breaks, such as reductions 
or exemptions for sustainable practices or products, provide financial incentives 
for  farmers  to  adopt  methods  like  organic  farming  or  precision  agriculture. 
Conversely, input taxes are levied on environmentally damaging inputs, such as 
synthetic  fertilisers  or  pesticides,  to  discourage  their  use  and  encourage  the 
adoption  of  more  sustainable  alternatives.  Taxing  agricultural  inputs  that  may 
harm the environment and human health aligns with the polluter pays principle, a 
fundamental aspect of EU environmental policy. However, fiscal measures are 
determined at the national level within EU Member States, as the EU does not 
have direct authority over taxation. At Member State level, regulating agricultural 
impacts  on  the  environment  mainly  relies  on  regulation  (i.e.,  command-and-
control  policy 
instruments),  voluntary  measures,  and  agri-environmental 
programs, rather than on taxes (362).  

Despite their potential benefits, tax exemptions have shown limited effectiveness 
due  to  the  significant  revenue  losses  they  impose  on  governments.  Studies 
suggest that the fiscal costs of such measures often outweigh their benefits, as 
they  require  substantial  public  expenditure  yet  fail  to  generate  proportional 
increases  in  responsible  agricultural  investments (363).  Similarly,  input  taxes  in 
agriculture  have  shown  mixed  effectiveness  in  addressing  environmental 
impacts.  OECD (364)  indicates  that  evidence  on  the  impact  of  water  taxes  in 
reducing  extractions  remains  inconclusive,  while  pesticide  taxes  have  had  a 
limited  effect  on  curbing  pesticide  use.  However,  as  highlighted  by  Finger  & 

(362)  Finger  and  Pedersen  “Input  Taxes  in  Agriculture.”  Ecological  Economics,  233:108575. 
https://doi.org/10.1016/j.ecolecon.2025.108575  
(363) Bellmann “Subsidies and Sustainable Agriculture: Mapping the Policy Landscape.” Available 
here. 
(364) OECD (2020) “Taxation in Agriculture,” Available here.  

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Pedersen (365),  input  taxes  alone  are  insufficient  to  address  agricultural  policy 
goals  and  to  be  fully  effective  they  must  be  part  of  a  coordinated  mix  of 
instruments. 

Payment for Ecosystem Services 

Payments  for  Ecosystem  Services  (PES)  are  proactive  payments  made  to 
farmers  for  adopting  specific  practices  that  deliver  measurable  environmental 
benefits. Under the CAP, farmers can receive payments for a range of different 
activities  that  enhance  ecosystem  services,  such  as  carbon  sequestration 
through agroforestry or peatland restoration, habitat creation through hedgerows 
and  flower  strips,  and  water  management  through  buffer  zones  along 
watercourses (366). 

1.2.3  Trade policy tools 

Trade policy tools are measures that regulate international trade, influencing the 
flow  of  goods  and  services  across  borders.  While  their  primary  purpose  is  to 
manage trade, these tools can also be designed to support sustainability goals 
and  encourage  environmentally  friendly  practices.  Trade  tools  can  target  both 
export  of  sustainable  agricultural  products  through  promotion  campaigns  and 
imported  goods  through  preferential  import  duties  or  reduced  tariffs  for 
sustainable products.  

The  EU  undertakes  promotion  campaigns  to  raise  awareness  of  the  quality, 
safety,  and  sustainability  of  EU  agricultural  products.  These  campaigns  are 
designed to open new market opportunities for EU farmers and the wider food 
industry,  as  well as  to  help  them  build  on  their  existing  business.  In  2025,  the 
European  Commission  will  allocate  €132  million.  These  activities  highlight  the 
benefits  of  organic  farming,  geographical  indications,  and  other  sustainable 
practices,  boosting  the  competitiveness  of  EU  agricultural  products  while 
encouraging the adoption of environmentally friendly methods. 

While  the  EU  does  not  currently  use  differentiated  import  duties  or  tariff 
it  supports 
reductions  specifically 
sustainable  agriculture  through  other  trade-related  mechanisms.  For  example, 
the EU includes sustainability clauses in its trade agreements, requiring partner 
countries to adhere to environmental standards and promote sustainable farming 
practices.  Additionally,  the  EU  has  proposed  regulations  to  restrict  imports  of 

for  sustainable  agricultural  products, 

(365)  Finger  and  Pedersen  “Input  Taxes  in  Agriculture.”  Ecological  Economics,  233:108575. 
https://doi.org/10.1016/j.ecolecon.2025.108575  
(366) European Commission (2023), “COMMISSION STAFF WORKING DOCUMENT Guidance 
on  the  Development  of  Public  and  Private  Payment  Schemes  for  Forest  Ecosystem  Services” 
Available here.  

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products  linked  to  deforestation,  indirectly  encouraging  sustainable  production 
methods.  Although  differentiated  tariffs  for  sustainable  products  are  not  yet 
formalised,  discussions  within  the  European  Green  Deal  and  Farm  to  Fork 
Strategy  highlight  the  potential  for  trade  policies  to  align  more  closely  with 
sustainability goals in the future. 

1.2.4  Risk-sharing instruments 

Risk-sharing refer to mechanisms are financial instruments designed to reduce 
the  risks  associated  with  adopting  sustainable  practices,  making  it  easier  for 
farmers  and  producers  to  invest  in  environmentally  friendly  methods.  These 
mechanisms  include  guarantees,  loans,  and  equity  and  provide  financial 
security and encourage innovation. EU Member States are increasingly adopting 
these mechanisms to stimulate investments and maximise the impact of public 
resources  by  attracting  additional  capital  and  enabling  the  reuse  of  funds. 
Thirteen CAP Strategic Plans collectively allocate a public budget of 1 billion Euro 
to  financial  instruments,  including  guarantees  and  loans,  to  improve  access  to 
lending  and  microcredit 
investments  aimed  at  enhancing  producer 
viability (367).  

for 

1.2.5 

 Support mechanisms 

Support mechanisms  refer to initiatives that facilitate the uptake of sustainable 
practices  by  providing  farmers  with  the  knowledge,  skills,  and  resources  they 
need  to  adopt  sustainable  practices.  These  mechanisms  include  technical 
assistance  programmes,  knowledge 
initiatives,  and  certification 
schemes, all of which aim to bridge the gap between research and practice. 

transfer 

Technical assistance programmes 

Technical assistance programmes equip farmers with the knowledge and skills 
needed to adopt sustainable practices. These programmes are often delivered 
through  advisory  services,  training  sessions,  and  demonstration  farms.  For 
instance,  the  Farm  Advisory  System  (FAS)  offer  free  or  subsidised  advisory 
services  to  help  farmers  comply  with  environmental  regulations,  implement 
sustainable practices, and access CAP funding.  Demonstration farms serve as 
practical examples of sustainable agriculture, showcasing innovative techniques 
and  technologies  to  visitor  farmers  who  are  interested  to  learn  new  practices. 
Technical assistance also includes the development and dissemination of digital 
tools,  such  as  farm  management  software, satellite  imagery, and soil  sensors, 

(367)  European  Commission  (2023)  “Approved  28  CAP  Strategic  Plans  (2023-2027)  Summary 
Overview for 27 Member States Facts and Figures.” Available here. 

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which help farmers optimise resource use and reduce environmental impact. The 
Farm Sustainability Tool (FaST) is an EU-funded platform designed to support 
farmers in adopting sustainable practices by providing access to a wide range of 
digital tools and resources. The platform aims to enhance farm sustainability by 
facilitating  knowledge  sharing,  promoting  innovation,  and  enabling  farmers  to 
make data-driven decisions. 

Knowledge transfer and innovation 

Knowledge  transfer  initiatives  bridge  the  gap  between  research  and  practice, 
ensuring farmers have access to the latest innovations in sustainable agriculture. 
In the EU, the European Innovation Partnership for Agricultural Productivity and 
Sustainability (EIP-AGRI) connects farmers, researchers, and advisors to share 
knowledge and develop innovative solutions for sustainable agriculture. The EU 
CAP  Network  serves  as  a  hub  for  knowledge  exchange,  facilitating  sharing  of 
best practices and promotes the adoption of sustainable and innovative farming 
methods. 

Certification schemes 

Certification  schemes  are  voluntary  frameworks  that  enable  farmers  and 
producers  to  demonstrate  their  commitment  to  sustainability,  quality,  and 
environmental  standards.  These  schemes  provide  consumers  with  assurance 
about  the  origin, production methods,  and  environmental impact  of  agricultural 
products,  while  also  helping  producers  access  premium  markets.  In  the  EU, 
certification schemes play a crucial role in promoting sustainable agriculture and 
fostering consumer trust. The EU Organic Logo is a key certification scheme that 
identifies products produced according to strict organic farming standards. The 
logo  guarantees that products meet  EU regulations on  organic production  and 
adhere to principles of animal welfare, biodiversity conservation, and sustainable 
resource use. The EU Organic Logo is recognised across all EU Member States 
and is increasingly visible in international markets. The EU promotes this logo to 
boost  the  competitiveness  of  its  organic  sector,  encourage  the  adoption  of 
environmentally  friendly  farming  methods,  and  meet  the  growing  demand  for 
organic  products.  In  addition  to  the  EU  Organic  Logo,  the  EU  supports  other 
certification  schemes,  such  as  geographical  indications,  which,  together  with 
related  instruments  like  certain  fair-trade  or  other  labels,  further  contribute  to 
sustainable agriculture and rural development. 

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Annex V – Additional graphics  

1.1  Summary graphic: benefits of algae-containing feed 

as a replacement for fish-containing feeds 

Figure 13 – Algae as a replacement for fish-based feed ingredients 

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Annex VI – Summary of recommendations including summarised rationale 

1.1  Summary of recommendations including summarised rationale 

Topic 

Theoretical 
optimal inclusion 
levels of algae 

Table 22 – Summary of recommendations including summarised rationale 

Summary of recommendations and rationale 

Recommendation 1 

Algae meal and oil together could account for 10-15% of the total feed for salmon and trout and approximately 20-25% for seabass and 
seabream (The upper value would equal approximately the replacement of all whole forage fish ingredients used in these feeds). However, economic 
factors would be limiting for a long time, especially for lower priced fish species. A more practical approach may involve a combination of algae, 
other alternative ingredients, and sustainably sourced fish-based ingredients, in particular trimmings and offal from aquaculture production; 

Reasoning: 

•  Based on both the interviews and literature review, the overall results indicated that an inclusion of 3% or more algal ingredients would maintain 

performance comparable to fish-based ingredients in terms of FCR (feed conversion ratio) and SGR (specific growth rate). While algae-containing 
feeds can present economic challenges and certain environmental impacts, depending on the production setup, they also offer significant advantages, 
including contaminant reduction, price stability and reduced pressure on wild fish stocks. Algae-containing feed has proven to be beneficial overall 
compared to feeds without algae. 

•  A total fish oil and fishmeal replacement would be possible, but it not necessarily feasible or needed, also depending on the fish species.  

A significant amount of fish oil and meal is obtained from by-products, which are in most cases a more sustainable source. The focus should be on 
replacing that obtained from whole wild caught fish. 

•  The recommendation is a long-term goal. During interviews, it has been predicted that the use of algal ingredients could rise to as high as 5% within 

the next five years. 

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Topic 

Minimum blend 
in targets for 
non-fish-derived 
EPA and DHA 

Summary of recommendations and rationale 

Recommendation 2 

A minimum of 25% of the required EPA+DHA can be set as a target for non-fish-derived EPA+DHA.  
It is also recommended to re-evaluate the minimum targets for non-fish-derived sources as this market evolves. 

Reasoning: 

Why not a higher amount? 

• By-products can be a good option to supply parts of the EPA and DHA.  
• It should be considered that the algae feed market could not immediately cover for such a high demand, and the prices are still a hurdle. 
• Novel oils from alternative sources are already accounting for a significant portion of aquafeed. 

Why not a lower amount? 

• From a nutritional standpoint, the replacement is possible, the performance of feed containing algae has been shown to be comparable to, and in 

several aspects even superior to options without algae, such as the price stability, reduced contaminants, and the decreased dependency on wild fish. 
• Only a small amount of algae oil needs to be incorporated to achieve the same levels of EPA and DHA in feed compared to fish oil. (25% could mean 

a total inclusion of 1.5-2% algae oil in the total feed) 

• Financial incentives should be considered in combination with these targets. 
• Moreover, the algae oil market is projected to continue growing, which should facilitate higher inclusion rates in the future as availability increases and 

prices are likely to decrease. 

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Topic 

FFDR (forage fish 
dependency ratio) 

Current average 
FFDR values  
(IFFO 2020): 

Atlantic salmon: 

0.68 

Other salmonids: 

0.67 

Marine finfish 
(e.g. European 
seabass and 
gilthead 
seabream): 0.53 

FFDRo: 1.5 

FFDRm: 0.5  

for Norwegian 
salmon (2020) 

Recommendation 3 

Summary of recommendations and rationale 

An FFDR (possibly individually considered as FFDRm and FFDRo) around the current average values should be encouraged. Additionally, a 
significantly lower FFDR could be rewarded with incentives to promote the use of by-products and alternative ingredients. It is recommended to 
simultaneously integrate these targets with other indicators such as LCAs and certifications, which can provide a more holistic approach. As the 
aquaculture sector grows, the average FFDR values will decrease further, due to forage fish being a limited resource. Therefore, the targets should not 
be static but re-evaluated and potentially lowered accordingly in regular time frames, for example every five years. 

Reasoning: 

• The FFDR aims to indicate pressure on wild fish and with this sustainability, but it is not necessary the most ideal tool to assess sustainability. All fish-
ingredients in a feed may come from sustainably managed fisheries, leading to a high FFDR, but still maintain a sustainable production. At the same 
time, it is evident, that most forage fisheries are at their limit (about 50%) and a large number is overfished (about 30%). Therefore, the FFDR can be 
a valuable indicator for (indirectly) assessing potential impacts on biodiversity, overfishing, and ecosystem health. 

• The current FFDR is an average, so there will still be many feeds showing a worse FFDR. The goal is to set (also for those much worse feeds) a 

realistic target for improvement, which can be more motivating for producers who may struggle to meet overly ambitious goals. 

• Furthermore, the idea is to promote and reward a significantly lower-than-average FFDR with incentives, to promote further improvement also for 

those who are already meeting the current or a slightly lower average. (see also financial incentives section) 

• While the FFDR alone does not provide information about the state of the wild fish populations – such as whether they are overfished or not – used for 
the fish-based ingredients in the specific feed, it is important to consider this context. It could be combined with relevant certifications of the remaining 
fish-based ingredients, ensuring that if wild fish is used, that it is obtained in a sustainable way. 

The FFDR will decrease over the years, as alternative ingredients will be used more frequently, and the aquaculture sector increases while the available 
forage fish will remain at similar levels. Additionally, the mentioned approach further promotes the lowering of the FFDR. Therefore, the recommendation 
was given to not have a static value but re-evaluate the value and lower it regularly. This should create realistic but continuous improvement.  

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Annex to the Final Report 

Topic 

ALARA (as low 
as reasonably 
achievable) 
principle for 
contaminants 

Lowering 
contaminants in 
fish feed 

Recommendation 4 

Summary of recommendations and rationale 

It is recommended, to include the ALARA principle also for feed in Directive 2002/32/EC (Directive on undesirable substances in animal feed), when 
it is evaluated next, to contribute to keeping contaminants like PCBs, dioxins and others as low as possible in feed, and in turn also in food. 

Reasoning: 

•  The feed and food hygiene regulation follows this principle: “When feeding food-producing animals, farmers shall take measures and adopt 

procedures to keep the risk of biological, chemical and physical contamination of feed, animals and animal products as low as reasonably achievable.” 

•  The hygiene regulation sets this principle specifically for feeding food-producing animals, but it does not directly concern the feed production itself. 
•  Embedding this principle into the feed contaminants regulation should lead to a lower contaminant content in feed. 
•  In this study, reviewed fish oil samples show a much lower contamination than the allowed maximum for dioxins, dioxin-like PCBs and non-dioxin-like 

PCBs. Additionally, in the report it was shown, that there are many different techniques or sourcing options to reduce contamination levels in 
aquafeed. Therefore, the max. levels are set much higher than necessary and would only exclude the most contaminated fish oil from the market. The 
current values seem not to be in accordance with the ALARA principle. 

Recommendation 5 

The lowering of the current limit values according to the feed contaminant regulation (Directive 2002/32/EC) for dioxins and the sum of dioxins and 
dioxin-like PCBs is recommended. A lowering of non-dioxin-like PCBs should also be feasible. Additionally, the action threshold for dioxins and 
dioxin-like PCBs is suggested to be lowered. 

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Annex to the Final Report 

Topic 

Summary of recommendations and rationale 

Reasoning: 

• Different techniques and sources are viable options to lower those contaminants significantly. 
• The conducted interviews as well as several studies revealed that the replacement with algae oil or a combination of algae and plant oil achieved a 

reduction in PCBs and dioxins. 

• Since 04/2012, the limit values for these contaminants in fish oil and aquafeeds in Directive 2002/32/EC have not been lowered. During the past 13 
years the composition of aquafeeds has changed drastically. The inclusion levels of fish oil these days are much lower than what it was in 2012. 
With fish oil being the main source of dioxins and PCBs, the allowed values in aquafeeds should have been lowered accordingly. 

•  In recognition of the ongoing advancements in feed formulation and contaminant mitigation, the EC has notified to the World Trade Organisation 

(WTO) in 2023 the intention to lower certain limit values for dioxins and the sum of dioxins. 

•  The EC notification does not include a recommendation for lowering of the limits for non-dioxin-like PCBs. However, a lowering of these values in 
fish oil and especially also in the compound feed for fish seems feasible for the reasons discussed above. Nonetheless, it is advisable to establish 
the specific amounts for non-dioxin-like PCBs following a more comprehensive evaluation. (see below) 
•  Along with those values, the action thresholds for dioxins and dioxin-like PCBs should be lowered as well. 

Contaminant 

Feed & feed material 

Current value → lowered value 

Dioxins - Maximum content in ng WHO-PCDD/F-TEQ/kg (ppt) relative to a 
feed with a moisture content of 12% 

Sum  of  dioxins  and  dioxin-like  PCBs  -  Maximum  content  in  ng  WHO 
PCDD/F-PCB-TEQ/kg (ppt) relative to a feed with a moisture content of 12% 

Non-dioxin-like PCBs - Maximum content in μg/kg (ppb) relative to a feed 
with a moisture content of 12% 

Fish oil 

5.0 → 3.5 (notified by EC to the WTO) 

Compound feed for fish 

1.75 → 1.0 (notified by EC to the WTO) 

Fish oil 

20.0 → 12.0 (notified by EC to the WTO) 

Compound feed for fish 

5.5 → 2.0 (notified by EC to the WTO) 

Fish oil 

175 → lowering possible, not specified 

Compound feed for fish 

40 → lowering possible, not specified 

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Annex to the Final Report 

Topic 

Summary of recommendations and rationale 

Standards 

Recommendation 6 

Currently: 
Several official 
CEN (European 
Committee for 
Standardization) 
standards on 
algae and algae 
products (CEN 
454) exist 
already. 

The development of (official) standards for the following fields is suggested: 

1)  Claims (e.g. nutritional, environmental, health) for algae and algae-containing 
2)  Labelling of the origin of algae biomass, covering also appropriate methods for checking the origin 
3)  Standardisation for analytical detection methods for contaminants in algae, also including an overview of all known algae contaminants 
4)  Guidelines for the reuse of water and measurements of water consumption in algae cultivation 
5)  Recommended preservation methods and storage for algae for various end purposes 

Reasoning: 

•  The above-mentioned topics that are recommended for standards align with the requirements outlined in relevant regulations. However, especially 

these aspects allow for some interpretation, and the standards could play a crucial role in guiding the industry in this regard. 

•  The above-mentioned topics have been chosen under consideration to not duplicate already existing standards or those that are being drafted and 

about to be published 

Framework 

Recommendation 7 

Currently: There 
is no framework 
promoting the 
production and 
use of algae-
containing feed 

Develop a comprehensive framework for algae-based fish feed. 

Reasoning: 

•  A holistic and integrated framework can promote the adoption of algae-based fish feed in aquaculture 
•  This framework must address the entire value chain, from algae production and feed formulation to fish farming and consumer markets 
•  Combining regulatory, financial, and market-based instruments can both incentivise stakeholders to adopt sustainable practices and support the 

growth of the algae feed sector. 

Furthermore, it is recommended that this framework to includes the aspects covered in Recommendations 7.1 to 7.6. 

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Annex to the Final Report 

Topic 

Summary of recommendations and rationale 

Recommendation 7.1 

Establish an enabling regulatory and policy environment, including policies, enhanced certification schemes, and technical support 

Reasoning: 

•  A stable and effective regulatory environment is essential to attract investment and foster innovation in algae-based fish feed 
•  Key actions include introducing policies that secure tenure and access rights for fish farmers who adopt sustainable practices (incl. algae-containing 

feeds) 

•  Strengthen existing certification schemes, such as the Aquaculture Stewardship Council (ASC) and the EU Organic Logo, to include specific criteria 

for algae-containing feeds 

•  Provide technical support to feed and fish producers and fish farmers through training programmes, knowledge-sharing platforms, and access to R&D 

resources. 

Recommendation 7.2 

Correct market distortions through fiscal measures, phasing out subsidies for unsustainable fish feeds and providing tax incentives for more 
sustainable options 

Reasoning: 

•  Fiscal measures can play a pivotal role in aligning economic incentives with environmental goals. Reforming fiscal policies has a great potential to 

discourage harmful practices and encourage more sustainable methods and technologies. 

Recommendation 7.3 

Integrate sustainable aquaculture into the EU Taxonomy 

Reasoning: 

•  Activities assessed as environmentally sustainable would become more attractive to investors 
•  This could create a strong incentive for fish farmers and feed producers to adopt sustainable practices, as they would gain access to green financing 

opportunities. 

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Annex to the Final Report 

Topic 

Summary of recommendations and rationale 

Recommendation 7.5 

Introduce innovative financing mechanisms, including blue bonds, loans, and guarantees 

Reasoning: 

•  New financing tools and access to capital markets are needed to incentivise sustainable aquaculture activities 
•  Blue/Green bonds can attract private capital and support the growth of the algae feed sector 
•  Blended finance models can be used to combine public and private funding for algae feed projects to reduce investment risks and make sustainable 

aquaculture more attractive to private investors. 

Recommendation 7.6 

Strengthen data infrastructure and transparency 

Reasoning: 

•  Improved data infrastructure and transparency are critical for attracting investment and ensuring the effective allocation of resources 
•  Robust monitoring and reporting systems will help investors make informed decisions and support the development of robust business plans 
•  Monitoring systems should be implemented to track the environmental performance of aquaculture operations to increase consumer confidence in 

sustainably farmed fish and create market incentives for producers. 

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