2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1279
Submitter : Ms. Debora Hanson Date & Time: 09/20/2005 05:09:32
Organization : Ms. Debora Hanson
Category : Individual Consumer
Issue Areas/Comments
Dear FDA:

Please adopt a regulation on the use of "gluten-free" on product labels that would be in line with those being 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 discontinue their use of the term "gluten-free" on their labels out of fear of litigation--which is hurts everyone 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).

This is crucial to me and others like me that suffer from Celiac Disease. It is difficult enough to purchase food, please make things easier for us to live with this disease by adopting the above regulations.
Thank you,
Debora Hanson