2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1315
Submitter : Ms. Andrea Jaekel Date & Time: 09/20/2005 05:09:57
Organization : Ms. Andrea Jaekel
Category : Individual Consumer
Issue Areas/Comments
1. The term 'glutenfree' should strictly be used for products that are per se glutenfree, i.e. rice, corn etc. and that have been produced in a glutenfree environment. Possible cross contamination is not acceptable for celiac patients. The label and the logo 'glutenfree' is international standard meaning exactly that.

There are companies such as Trader Joe's and Whole Foods that provide lists with supposedly glutenfree products but can not give details about the source of the ingredients. This is not acceptable and very misleading. There are products on the market that are described on the package in bold letters to be glutenfree. When you read the very small printed additional information on the back side you are notified that they might contain gluten due to being processed in a factory which produces gluten-containing flours. This is absolutely unacceptable. Examples are Blue Diamond Nut Thins and Brown Rice Crackers.

Glutenfree from a celiac's point of view must also exclude the presence of the following ingredients: barley, rye and oat.

2. We carefully read the list of ingredients. We have spent more time in the beginning when we had to become glutenfree. I still have to make phone calls and ask specific questions. If I have to make an inquiry by phone, I would estimate that I spend 15 minutes in total on the phone.

3. The minority of the products is labeled glutenfree. It is the exception. As seen under 1., you can't trust the label glutenfree which is very unsatisfactory. I consider this to be very problematic. Our goal is to be 100 % glutenfree.

4. Yes, it absolutely does. I don't buy products that are not confirmed glutenfree. I also want to stress that the labeling 'no gluten added' or 'made with glutenfree ingredients' thus implying that the product was produced in an environment that is not glutenfree is not acceptable.