2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC128
Submitter : Mr. Eric Oemig Date & Time: 08/22/2005 01:08:19
Organization : FindPurity.com
Category : Private Industry
Issue Areas/Comments
Dear Reader,

Accurate food labeling is critically important. Everyday consumers make health and wellness food buying decisions based on ingredient lists. For someone with a food allergy this decision is ever more important. For brevity, I will assume you know what celiac disease and cross contamination are.

Gluten in minute amounts can cause great suffering to a celiac. An unambiguous label will greatly speed buying decisions and reassure consumers. Please define "gluten-free" and encourage manufacturers to use the label.

To define what is "gluten-free", I recommend AT LEAST a guarantee of less than 200 ppm. I urge you NOT to allow <500 ppm to be called GF. That would throw doubt onto the "gluten-free" label and may do more harm than good.

I further suggest considering a label of the form "GF###" where "###" indicates the maximum ppm guaranteed by the manufacturer. GF500 means < 500 ppm. GF10 indicates < 10 ppm. In this way, consumers can get helpful, unambiguous ingredient information.

I own www.findpurity.com. That is a web service that helps people find gluten free foods. Today people use my service, they purchase lists, they search the internet, they call manufacturers. A lot of time and money is wasted by both consumers and manufacturers to determine which products are safe.

Like many people, I am reluctant to try new products that don't carry a "gluten-free" label. When faced with similar products, I always buy the "gluten-free" labeled product. I vote with my dollars to reward the considerate company.

Because of my unwillingness to purchase unmarked products, only a small percentage of the packaged products that I buy are not labeled "gluten free". The selection of ?gluten-free? products available to me is small, but growing. I must shop in multiple stores to find trusted brands. When I travel to less gluten-friendly cities, my ability to find "gluten-free" product is significantly diminished.

Speaking for myself and on behalf of all celiacs, I urge you to provide strong ?gluten-free? guidance. I urge you to require ?may contain gluten? if cross contamination is a likely risk and to define ?GF###? style labeling.

One day I can see a word where egg, dairy, casein, nut, wheat, gluten and other common allergens will be clearly noted. As more ingredient suppliers mark their products, more manufacturers will have confidence about marking their finished products.

Eric Oemig, Owner