2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1282
Submitter : Mrs. Terri Schreiber Date & Time: 09/20/2005 05:09:44
Organization : Celiac Sprue Association
Category : Consumer Group
Issue Areas/Comments
I am offering a response to the questions posed below in order to help the FDA to define gluten-free for food labels.

1) What should gluten-free mean on a food label? Why?

Gluten-free on a label should mean the product contains no wheat, barley, rye or oats or other ingredients derived from these. In addition, the product should not be produced on floured lines or contaminated by other products produced in the same plant that may contain gluten.

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

I identify foods that do not contain gluten primarily by reading the list of ingredients listed on the label. When there is doubt, such as ingredients like modified food starch which can be made from corn or wheat, I will call or write the manufacturer. I have to spend a lot of time looking up unfamiliar additives in celiac reference books to determine if they are safe. I also have to do this frequently as manufacturers do change the ingredients in their products from time to time.

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

A very small percentage of foods are marked gluten-free, but the number is slowly growing. Those most often clearly labeled are usually those found in the health food section.

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.

I am much more likely to purchase a product which is labeled gluten-free than one that has the same ingredients but is not labeled as gluten-free. I feel that it is a safer choice.

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

I would probably not find a two or more level definition of gluten-free helpful because I would choose only products that contain no gluten. I would avoid all products that had known trace amounts of wheat, barley, rye, oats and any of their derivatives.