2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1431
Submitter : Mr. Daniel Benkert Date & Time: 09/20/2005 06:09:06
Organization : Mr. Daniel Benkert
Category : Individual Consumer
Issue Areas/Comments
Docket No. 2005N-0279

When I go food shopping for my 3 year old celiac daughter, it is usually an exercise in futility. What used to take 20-30 minutes, now can take up to two hours per trip to the supermarket. I spend countless hours every month poring over ingredient lists that are barely comprehensible to anyone who is not a chemist, nutritionist, or doctor. For the first two months of my daughter?s gluten-free diet I could not understand why she was not improving. Then, after calling one of the food producers, I was told that ?wheat? is not only called by several different names, but is symbolized by abbreviations and/or acronyms such as ?mir? and ?far?. Without clear labels, my daughter will never get better.

A ?gluten-free? food label will mean much less time spent in the stores, reading labels, calling companies, and researching all of the possible names and euphemisms that chemists and bioengineers use for wheat, rye, barley and oats. A ?gluten-free? label will mean much less time preparing foods from scratch. A ?gluten-free? label will mean much more money saved on specialty groceries, and much more time spent in the company of my sick daughter, rather than trying to read the mind of the person who compiled the list of ingredients. A ?gluten-free? label will mean freedom from the fear that I am feeding my daughter food that will one day destroy her intestines.

Currently, my food shopping is broken up into several trips per weeks to three or four different stores to find suitable foods that may or may not be gluten-free. Where I used to be able to make just one quick trip to the supermarket, now I have to frequent natural food markets up to 20 miles away from my house to find food labeled ?gluten-free?. When I exhaust those spots I return to the supermarket and begin reading the labels with my large dietary guidebooks in hand. (As I mentioned earlier, this can take up to two hours per trip.)

Up to 70% of the foods I purchase are labeled gluten-free and are made by foreign suppliers, chiefly from the U.K. and Australia. We trust manufacturers from these foreign countries because we know their labeling laws are more strict. We also trust them because we know that celiac disease is at least acknowledged there. When buying US-produced and labeled foods in the supermarket, the only way of finding is it is ?gluten- free? is by reading through the ingredients list and comparing each component to our checklist in our guidebooks - - a very laborious process.

When shopping, the ?gluten-free? label, when it appears, is THE deciding factor in what product to buy regardless of price, nation of origin, or even quality of product. SAFETY is my primary concern, and the gluten-free label tends to assuage our nerves.

For celiacs, something as simple as a label or even just a symbol indicating that the product is ?gluten-free? would help improve the quality of our lives immeasurably. We suffer not only from the disease itself, but from the knowledge that food is our only cure, and that products labeled gluten-free are not only much more expensive, but relatively scarce. These labels are absolutely necessary for this ignored and untapped market.