2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1422
Submitter : Ms. Medha Narvekar Date & Time: 09/20/2005 06:09:14
Organization : Ms. Medha Narvekar
Category : Individual Consumer
Issue Areas/Comments
Dear FDA:

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 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 which 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 celiac 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. Last, the inclusion of trace levels of gluten in the diets of those with celiac disease have been shown to be safe in many scientific studies.

Thank you for your consideration.


Medha Narvekar
2047 Cherry Street
Philadelphia, PA 19103