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Do you find gluten-free labels and the various wording on gluten-free products confusing? Would you love to understand the complex concept of gluten-free labeling requirements so that you can know more about what you’re buying at the store?
I’m right there with you on all of these points. I get questions about gluten-free labeling all of the time and realized from my own research to create this Guide that it was even more confusing than I had initially thought. Sadly, the public has very little understanding of how products end up labeled and if they can even trust any labels that they see.
** This article has been updated as of 1/3/14 to reflect all new information currently available on this topic.
Gluten-Free Labeling Requirements: What You Need to Know
To get some straight answers, I spoke with Cynthia Kupper, RD who is the Executive Director of GIG (aka. Gluten Intolerance Group).
Please bare in mind that I do not work in the gluten-free labeling industry nor am I associated with any certifying body. Gluten-Free Labeling regulations go into affect in the US in August 2014 which will require all gluten-free products to test below 20ppm. It is not a mandatory process for food manufacturers, nor does it require them to seek a certification to label their products as such. If you are interested in learning more about the issues and problems with this legislation, please check out this article here.
What constitutes a product being labeled gluten-free?
Generally speaking, products marked gluten-free mean that gluten levels should fall under a certain testable threshold of 20 ppm. A product simply stating that it’s gluten-free is not the same as those which are certified and contain an official label such as the image to the right.
Should a product just contain a statement such as “gluten-free”, you may want to contact that company and inquire about their handling, manufacturing, and testing practices are before assuming it’s safe.
Who is in charge of certifying a product as gluten-free?
There are three main organizations who currently certify products in the US as gluten-free: Gluten Intolerance Group (GIG), National Foundation for Celiac Awareness (NFCA) and the Celiac Sprue Association. GIG and the NFCA require testing under 10 ppm, where as the Celiac Sprue Association requires testing under 5 ppm and no use whatsoever of oats in certified products.
Currently, gluten-free certifications “are all voluntary” states Cynthia. The FDA has defined “gluten-free” to mean that the food must test below 20 ppm of gluten in order to qualify for use of the label.
What does 20 or 5 ppm mean?
The numbers that you may hear or see thrown out there in relation to products being described as gluten-free are discussed in terms of PPM or parts per million. It has to do with a very minute level of gluten found in products. Generally speaking, products do not test to a specific amount. Rather they are tested to insure that their levels come below a specific threshold such as 20 ppm or 5 ppm.
Currently, testing below 20 ppm is generally regarded at the threshold for which a product can be labeled as gluten-free which has been officially set by the FDA.
Can you still react to a product if a product tests under the 20 or 5 ppm threshold?
The jury is still out on that one. Some people say that they do react, while certain medical experts such as Dr. Alessio Fasano say you can’t if the amount is below 10 ppm.
Food for thought — often folks who have celiac or gluten sensitivity can have other food sensitivities which are not known and can experience the same symptoms of feeling glutened should they come into contact with them. I’m not saying that anyone is wrong in their experience, but you may want to investigate if other potential allergens could be an issue for you such as soy, dairy, eggs, etc.
Can a product test for zero or no gluten?
No. Cynthia states that “there is no test that can measure Zero. It is impossible. The most consistently reliable tests can measure to 5 ppm. We have heard that people react to 5 ppm, but there is really no way to prove that. Many times, when I am told [someone] reacted to a product and they think is over 5ppm, product testing often shows that the product tests below the level they say they are reacting to.”
If a product says that is made in a facility that also produces wheat, should I worry?
Have you ever picked up a product and seen written on the label that the product was produced in the same facility as wheat?
It’s natural to panic, but these statements are completely voluntary and intended for the company to be completely transparent about the environment in which products are produced. However if a company is certified to be gluten-free, then it must undergo strict testing as discussed below. The facility will probably also take extra precautions to keep gluten-free products’ raw ingredients separate from those where wheat may be.
Additionally, you can’t assume that a company’s practices have changed if their packaging now contains this statement. Just because a company’s product may not have contained a statement such as this on a previous product you purchased, but they’ve now added it to the label doesn’t mean that anything in the production or ingredient sourcing of their product has changed. Though it could signify a change, it’s a way for companies to be more transparent with their consumers. Your best bet would be to reach out to the company directly to inquire about the change before assuming that the product is no longer gluten-free.
Are companies required to tell me if gluten is in a product?
Since the “Food Allergen Labeling and Consumer Protection Act” (FALCPA) passed in 2004, the top 8 allergens are required to be clearly identified on product labels. Wheat is included in this list. According to documentation from GIG, “This means that derivatives of wheat such as “modified food starch” must clearly indicate that “wheat” is the source. “Wheat” can either appear in parentheses in the ingredient list or in a separate “contains” statement.”
Here’s the caveat — wheat isn’t the only place where gluten hides. Other gluten-bearing grains are not included on this list which is why scanning the ingredient label and assuming it’s fine might not be safe. There are so many derivatives out there made from gluten-bearing ingredients and any of those can cause you problems. That’s why looking for the Certified Gluten-Free label is key.
Is there one specific gluten-free label you can trust?
Gluten-free certification programs “in North America can all be trusted. Some have slightly different standards and requirements to be certified. I firmly believe that GFCO (Gluten Free Certification Organization) sets the strictest standards for testing and inspections. It really doesn’t matter if the agency standard is 5 or 10ppm – most GF products that are certified test at a very safe level and many under detectible levels,” states Cynthia.
What kind of testing do companies who use the Certified Gluten-Free label undergo?
According to Cynthia, “each certification organization has different ways of monitoring compliance with their program. For instance, GFCO requires a minimum of an annual inspection and regular finished product testing. Equipment and raw materials may also be required to be tested. These results must be turned into GFCO each quarter. If they are not, a company could be held in non-compliance and their certification cancelled. GFCO also does random product testing. Any results outside of our standard are investigated for appropriate corrective actions.”
If there are test results outside of the approved range, “the company or FDA can issue a recall. GFCO can require a ‘pull back’ of products (essentially the same thing as a recall).”
Are there companies who place the Certified Gluten-Free label on their website and products without really being certified?
Yes. You can view an updated list of companies here who have been found to be using the official logo without authorization.
Does the FDA ruling for “gluten-free” also apply to restaurants, cafeterias and buffets?
Yes, all of these establishments must comply with the FDA ruling by August 2014 if they choose to voluntarily use the label “gluten-free” to describe any food served on the premises. Local agencies who are tasked with restaurant oversight will be responsible for ensuring that this is handled correctly in public eateries.
Still have questions?
Contact the Gluten Intolerance Group (GIG) by email: customerservice@gluten.net or call 253-833-6655. Questions will be forwarded to the appropriate people.
That is really bad that companies place the Certified Gluten-Free label on their website and products without really being certified. It is hard enough to find stuff and read labels but now we have to know the ones who are not telling the truth! Why doesn’t someone stop them?
Donna, there aren’t any current regulations… there’s no official standard. It’s horribly wrong that this happens, but that’s why you as a consumer always have to do your homework. It stinks that the burden is on us, but ultimately we are responsible for what we put in our mouths. Sorry to the bearer of that news, but that’s why I really try to stick with whole foods (like veggies, fruits, etc) that are naturally GF rather than depending heavily on companies and products.
I believe the strictest standard is GFS Laboratories International, they have a standard that is approved by ANSI for 3ppm. I don’t believe that GFCO has a verified standard of any kind, I believe its their own statement that its their standard. Besides GFS Labs is a laboratory and certifier whereas the GFCO only certifies. I know for myself GFS Lab products are the only ones I’ll consume.
Hi Sarah, I have never seen this label at all anywhere. I’m not familiar with any company that actually uses this lab and they do not certify to 3ppm… they certify down to 5ppm which the Celiac Sprue Association does as well. Thank you for sharing that resource though.