2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1411
Submitter : Mr. Paul Graven Date & Time: 09/20/2005 06:09:56
Organization : Mr. Paul Graven
Category : Food Industry
Issue Areas/Comments
1) What should ?gluten-free? mean on a food label? Why?

Gluten-Free should mean that the food contains no gluten or such a small amount that there is no chance of reaction even if the person does not have a varied diet. To mandate 100% or 0 parts per million gluten-free is cost prohibitive, impossible to determine with today's tests and would chase many quality vendors from the market, harming the celiac community.

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

We have spent considerable amounts of time - probably up to several person weeks as we have contacted manufacturers and gotten certifications.

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


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.

Yes, it does influence the purchase, as the manufacturer is assumed to have taken due care in avoiding possible cross-contamination or suspect ingredients.


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

Example: If Level A meant the absence of any wheat, barley, rye, oats and any of their derivatives and level B meant the presence of trace amounts, less than 'X' parts per million, of wheat, barley, rye, oats and any of their derivatives and level C meant the presence of small amounts, less than 'Y' parts per million, wheat, barley, rye, oats and any of their derivatives. (Using 'X' and 'Y' to identify quantities to be determined by the FDA.)

That sounds like what is done in Europe and that would be helpful, however, Level 'A' should have some standard as that is lacking. Many companies mark as gluten-free but have not taken time to test and determine if there is cross-contamination in milling, shipping, or storage. Even though there is no ingredient containing gluten, that does not rule out cross-contamination and I think that it would be a dangerous practice for celiacs.