2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1258
Submitter : Mrs. Eveline Evans Date & Time: 09/20/2005 05:09:37
Organization : Mrs. Eveline Evans
Category : Individual Consumer
Issue Areas/Comments
GENERAL
GENERAL
We encourage you to adopt a regulation on the use of "gluten-free" on product labels that is in line with that which has been used in Europe and other countries (including the USA via the Codex Alimentarius) for many years--20 PPM for products that contain naturally gluten-free ingredients, and 200 PPM for products that have been rendered gluten-free such as those that may contain Codex Alimentarius quality wheat starch. The formal adoption of these existing regulations will allow for the continued importation of excellent, safe European products that are labeled "gluten-free."

It is very important that you do not adopt a "zero tolerance" regulation in this matter because doing so will cause many gluten-free food companies to discontinue their use of the term "gluten-free" on their labels out of fear of litigation--which is counterproductive for all people with this disease (most, if not all, gluten-free food companies do not grow, transport or mill the gluten-free grains that they use as ingredients--a fact that will make them vulnerable to litigation if a zero tolerance level is adopted).

Gluten Free labeling should also address processing and packaging materials - Chewing gum sticks or candy might be dusted with oat flour to keep then from sticking to the paper wrappers. Taco shells and French fries might be dusted with gluten-containing flours to prevent them from sticking together. Coatings and wrappings designed to protect quality of meats, fruits, vegetables can be derived from a variety of vegetable products including wheat gluten. Gluten-containing products might leave residues in/on the machinery later used for otherwise gluten-free items. Extruding machines and conveyor belts might be dusted with gluten-containing flours to keep the product moving. Items might be added incidentally during processing. THIS GLUTEN IS HIDDEN, because it is NOT DISCLOSED ON THE PRODUCT LABEL.

"Gluten Free" labeling would make my shopping for food 100% easier. I spend many hours a month reading labels in an effort to purchase foods I can eat without getting ill. I have to search labels the main offenders, wheat, oats, barley and rye. In addition I have to look for "modified food starch" which could be wheat, I have to look for monosodium glutamate, which is just pure poisen to me, I have to look for malt, durham, furina, spelt and a dozen other names that could mean hidden gluten in the product.

I look forward to being able to purchase "Gluten Free" products in the future.

Thank You.