2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC103
Submitter : Mrs. Karen Dudley Date & Time: 08/19/2005 09:08:05
Organization : Mrs. Karen Dudley
Category : Individual Consumer
Issue Areas/Comments
GENERAL
GENERAL
1. What should the words "gluten-free" mean on a label?

Gluten-free should mean that the product does not contain anything ingredients that contain or were processed with or processed in the same area as a gluten containing product. For the rest of my comments my definition of ?gluten-free? is any of the proteins in the grains such as wheat, barley, and rye, their related species (e.g., durum wheat, spelt, kamut) and crossbred hybrids (e.g., triticale), and oats.

2. How do you personally identify foods that do not contain gluten?

I have created a list of products that I know to be gluten-free from celiac.com and other sources. If I find a product on a shelf that I don?t know is gluten-free, I read the label. If it contains something that might not be gluten-free such as carmel color, I contact the manufacturer and verify that it is gluten free. If there is any doubt, I do not add it to my list and I do not purchase it.

3. How much time does it take you to identify "gluten-free" foods?

Initially, when I was diagnosed with ?celiac sprue?, it took me a long time. Thanks to being a organized person with my personal gluten-free product list, days and days at a time over three years of online research and a lot of phone calls, it doesn?t take so long to identify products as gluten-free. Since products labeled ?Gluten-Free? are not necessarily gluten-free, are processed with products containing gluten, or processed in the same production area as other gluten containing products, I do not take it for granted that the product is truly gluten-free. I still read the label thoroughly and contact the manufacturer before I purchase the product.

4. What percentage of the foods you buy are marked "gluten-free?"

Less that 10% of the products I buy are labeled gluten-free. Since products labeled ?Gluten-Free? are not necessarily gluten-free, are processed with products containing gluten, or processed in the same production area as other gluten containing products, I do not take it for granted that the product is truly gluten-free. I still read the label thoroughly and contact the manufacturer before I purchase the product.

5. What foods do you buy (e.g, breads, cereals, pasta, cookies, etc.) that are marked "gluten-free?"

All of my bean flour is labeled gluten-free, while my rice, tapioca, and sorghum flours as well as cornstarch are not labeled gluten-free. I make all of my bread, cakes, pies, puddings and cookies from a combination of any of these flours and cornstarch. All of my bean flour pasta is labeled gluten-free. Less than once every four to six months, I buy cereals and cookies that are labeled gluten-free. I have found that there are a lot of mainstream products that are gluten-free, but are not labeled as such.

6. To what extent do the words "gluten-free" on a label influence your buying decision when faced with two items with the same ingredients?

It brings my attention to the product, but it doesn?t influence my buying decision at all since a product labeled ?Gluten-Free? under the current labeling guidelines does not mean the product is truly gluten-free. Products currently labeled ?Gluten-Free? may not have gluten containing ingredients, they may have been processed with products containing gluten, or processed in the same production area as other gluten containing products.