2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC140
Submitter : Ms. Jennifer Wellnitz Date & Time: 08/22/2005 01:08:44
Organization : Ms. Jennifer Wellnitz
Category : Individual Consumer
Issue Areas/Comments
I would like to suggest that "gluten-free" labelling of food be done in a manner similar to that of organic food. In particular I would like to propose that there be a distinction in terminology between
(a) food that is gluten free ie. free of any basic ingredient, flavoring or additive derived from wheat, barley or rye that may contain gluten and
(b) food that is gluten free as defined above AND which is also prepared on a dedicated line so that there is no possibility of cross-contamination.

This is because even when a product itself is gluten free there still remains the possibility of cross contamination if the product has not been manufactured on a line dedicated to gluten free products. If there were to be a distinction in labelling it would greatly assist those who are extremely sensitive to gluten to determine which products would be safe for them to consume.

As a mother of a young son who is gluten intolerant I spend an inordinate amount of time reading the list of ingredients on food labels trying to determine whether it is safe for him to consume. It is extremely frustrating that despite the most careful reading of labels it is often necessary to make phone calls to the companies manufacturing the item to determine whether the vague generic terms in the labels (eg. natural flavors, modified food starch, caramel color) indicate the presence of hidden sources of gluten.

It is doubly frustrating that even after I have verified that a product actually is gluten free I cannot be certain that the same product will remain gluten free. Manufacturers do adjust the formulation of their products from time to time. Hence even when I am purchasing an item that I have previously bought, it is still necessary to read the entire list of ingredients to ensure that nothing has changed. It would greatly simplify matters if I could tell with a quick glance at the label whether the item was gluten free.

At present very few foods are labelled gluten free and most of these can only be purchased at a health food store which seem to take this to be a licence to charge an arm and a leg for the products.

Having learnt through repeated phone calls to various manufaturers that there are in fact many goods available in an ordinary grocery store that are gluten free it would seem like good marketing practice for the manufacturers to label their products as such. It would certainly encourage consumers who are gluten intolerant to buy their products rather than other products which have the same ingredients but which are not labelled "gluten free".

In conclusion I would just like to note that the labelling of the top eight allergens in products has been a mixed blessing to those who are gluten intolerant. Although it has been helpful in determining when wheat is present in a product, it has been no help at all when the products contain other sources of gluten.

On the contrary, in these instances the fact that wheat does not appear on the label as an allergen can actually be misleading. It may lead one to assume that the product is safe when in fact it contains gluten from barley or rye that are hidden under such vague terms as natural flavor or caramel color.

Some manufaturers, eg. Kraft, do now specifically list anything containing gluten on their list of ingredients. However many others limit their labelling to the top eight allergens and keep other non-wheat sources of gluten hidden under vague generic terms in their labels. It would be very helpful if there could be consistency among manufaturers in their labelling practices so that the presence or absence of gluten in their products can be determined without the need of repeated phone calls.

Thank you.