2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC879
Submitter : Mr. Robert Wilson Date & Time: 09/14/2005 05:09:56
Organization : Mr. Robert Wilson
Category : Individual Consumer
Issue Areas/Comments
GENERAL
GENERAL
1) What should ?gluten-free? mean on a food label? Why?

Gluten free should mean there are no trace elements of wheat, rye, oats or barley in the product.

2) How do you identify foods that do not contain gluten? Time spent identifying foods?

The steps in identifying gluten free foods are, consult gluten free products listings prepared by Celiac Sprue Association (CSA), buy from special gluten free suppliers, read labels, identify suspisious items, consult food additive definitions provided by CSA, contact producer. Time varies depending on product, between 1/2 - 1 hour.

3) What percentage of foods and which types purchased are marked ?gluten-free??

1% of items are marked gluten free. These are items from the health food stores and specialty suppliers. These are staples; breads, pasta, as well as treats like cookies and cakes.


4) Does ?gluten-free? printed on a product label influence your decision to purchase products having the same ingredients? To what extent? Example:Two cans of tomato sauce on the shelf both contain only tomatoes and salt and only one is marked gluten-free.

Yes, gluten-free shortens the purchasing process. It eliminates the additional steps of researching product contents. It does not mean we will not try the other products, but the gluten free label usually makes it our first choice.


5) Would you consider a two or more level definition of gluten-free helpful?

Example: If Level A meant the absence of any wheat, barley, rye, oats and any of their derivatives and level B meant the presence of trace amounts, less than "X" parts per million, of wheat, barley, rye, oats and any of their derivatives and level C meant the presence of small amounts, less than "Y" parts per million, wheat, barley, rye, oats and any of their derivatives. (Using "X" and "Y" to identify quantities to be determined by the FDA.)

No! If a product is gluten free it should have no wheat, rye, oats, or barley. A "low gluten" or "reduced gluten" label could be used for your other examples, but "gluten free" should mean the absence of any wheat, barley, rye, oats and any of their derivatives.