|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|
| 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: