2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1400
Submitter : Mr. Tim Hawley Date & Time: 09/20/2005 06:09:40
Organization : Mr. Tim Hawley
Category : Individual Consumer
Issue Areas/Comments
GENERAL
GENERAL
Please adopt a regulation specifying "Naturally Gluten-Free" on product labels that contain only naturally gluten-free ingredients and less than 20 PPM gluten. "Gluten Reduced" could be used for products that have been rendered gluten-free and contain less than 100 or 200 PPM Gluten. Such labelling would be similar to the Codex Alimentarius standard.

Please do not adopt a "zero tolerance" regulation because doing so may cause 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). There is some evidence that trace levels of gluten (<100 PPM) in a celiac's diet are not harmful. Please see:
http://www.celiac.com/st_prod.html?p_prodid=994&p_catid=15&sid=91hH9H1FZJzREMn-26105002335.e3

Thank you.