2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1391
Submitter : Mr. David Thompson Date & Time: 09/20/2005 06:09:30
Organization : Mr. David Thompson
Category : Individual Consumer
Issue Areas/Comments
I was diagnosed with Celiac Disease in 1992, which I have necessarily treated by adhering to a strict gluten-free diet during the past thirteen years. In my experience, the success of this treatment absolutely depends on obtaining accurate and reliable product information. Food and ingredient labeling are the primary sources through which I obtain such information. I purchase products marked 'gluten-free', and do so with the assumption that these products contain no gluten. To this end, a 'gluten-free' label is only useful to me when an absence of gluten in or on the product can be assured. This assurance should cover not only the product's ingredients, but also the processes and facilities used to manufacture the product.

For sake of context, I recently purchased a product that was marked 'gluten-free', but which also contained the following disclaimer:

'This product is packaged on equipment that also packages products that contain wheat and soybeans'.

As you probably know, wheat contains gluten. I immediately disposed of this product because such mixed messaging offered me insufficient assurance that the product was actually free of gluten. Similar experiences have forced me to more critically assess the products I purchase that are marked 'gluten-free' under the current labeling system. Until the 'gluten-free' label uses the narrowest definition of the word 'free', it will not be a wholly effective aid for managing my treatment.

I generally rely most on the list of ingredients provided on product packaging when determining which products to consume. I also use the Gluten- Free product guide that is published by the Celiac Sprue Association for reference. When I go to the grocery store, I check the ingredients of every food product that I purchase unless I am certain that the manufacturer only produces gluten-free products. I estimate that perhaps thirty to forty percent of the products I purchase have the 'gluten-free' label. The products with the gluten-free label that I purchase most are generally cereals, breads, pastas, crackers, and cookies. I would benefit substantially if more dairy and meat manufacturers used a 'gluten-free' label when appropriate. Likewise, it would also be very helpful to me if more beverages such as juices, coffees, and soft drinks were labeled. I find that these types of products are often difficult to assess because many of their ingredients have non-descriptive or vague names (e.g. modified food starch).

If I could not differentiate between two products using their list of ingredients, I would likely buy whichever product was marked 'gluten-free'. The presence of this label implicitly suggests that the product's manufacturer has some familiarity with gluten-free diets. I would also assume then that this familiarity would likely lead to a safer product for me to consume. However, the example I provided above shows that this is not always the case. A tiered definition of gluten-free might be more helpful for me. However, its usefulness presumes that the medical community could establish and effectively communicate which levels would be most consistent with my treatment. To date, my physicians have always recommended that I avoid gluten entirely. Unless told otherwise by my doctor, I would likely never purchase a product that contained trace amounts of gluten. However, such tiered labeling would be useful in terms of helping me identify which products to avoid.