2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC93
Submitter : Mr. Scott Adams Date & Time: 08/19/2005 08:08:37
Organization : The Gluten-Free Mall
Category : Food Industry
Issue Areas/Comments
GENERAL
GENERAL
We encourage you to adopt a rule 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 fear litigation, and discontinue the use "gluten-free" on their labels--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 substitutions--thus opening them up to a litigation risk if a zero tolerance level is adopted). Last, the inclusion of these trace levels of gluten in the diets of those with celiac disease have been shown to be completely safe in many studies, for more details please see:
http://www.celiac.com/st_main.html?p_catid=15