2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1430
Submitter : Mrs. Susan Bustamante Date & Time: 09/20/2005 06:09:47
Organization : Mrs. Susan Bustamante
Category : Individual Consumer
Issue Areas/Comments
Dear FDA:
We encourage you to adopt a regulation on thr use of "gluten-free" on product labels that is in line with that which hs been used in Europe and other countries (including the USA via the Codex Alimentarius) for many years--20 PPM for product that contain naturally gluten-free ingredients, and 200 PPM for products that have benn rendered gluten-free such as those that may contain
Codex Alimentarius quality wheat starch. The formal adoption of these existing regulatons will allow for the continued importation of excellant European products that are labeled "gluten-free".
It is very important that you do not adopt a "zero tolerance" regulation in this matter because doing so will cause many gluten-free food companies to discontinue their use of the term "gluten-free" on their labels out of fear of litagation-which is counterproductive for all people with this disease (most, if not all, gluten-free food companies do not grow, transport or mill the gluten-free grains that they use as ingrdients-a fact that will make them vulnerble to litagation if a zero tolerance level is adopted). last, the inclusion of trace levels of gluten in the diets of those with celiac disease have been shown to be safe in many scientific studies, for more details please see: http://www.celiac.com/st_main.html?p_catid=15
Thank you,
Susan Bustamante