2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1442
Submitter : Mrs. Karen Crum Date & Time: 09/20/2005 06:09:31
Organization : Mrs. Karen Crum
Category : Individual Consumer
Issue Areas/Comments
"Gluten-free" should indicate that the product contains no wheat, barley, rye, spelt, triticale or other known gluten-containing grains. In addition, to be truly GF the product should not have been exposed to cross-contamination with gluten during the packaging/manufacturing process. A system of labeling which indicates different levels of possible gluten content (x/million) would be helpful for me, as I understand that 100% GF cannot always be guaranteed.

I personally spend approximately 20-30 minutes/week checking labels to assure the GF status of processed products that I purchase. When uncertain (foods that list modified food starch w/o stating its origin, for example) I consult the CSA Gluten-Free Product Listing that I bought from CSA/USA. If the product is not listed, I then have to contact the manufacturer directly, usually by email. While this process has proven informative, it is quite time consuming.

I estimate that 10-15% of the foods I purchase are currently marked as "gluten-free." These include specialty pastas, specialty baking mixes, breakfast cereals, salad dressings, seasoning/soup packets, tortillas, and frozen meals.

I don't recall having encountered a situation where there were two products with identical ingredients, one labeled GF and the other not; however, I probably would be more confident in purchasing the GF item should the situation arise. The unknown of manufacturing conditions, and whether or not cross-contamination between GF and gluten-containing ingredients has occurred, makes me biased toward the product with the gluten-free claim. This labelling would not effect my decision to purchase unprocessed products, such as fresh fruit and vegetables, but would definitely sway my decision concerning canned/packaged goods.