2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1466
Submitter : Ms. Ivy Fishbein Date & Time: 09/20/2005 06:09:40
Organization : Ms. Ivy Fishbein
Category : Individual Consumer
Issue Areas/Comments
Gluten-free on a label should mean that there is no gluten - no wheat, barley rye or oats, or other ingredients that are derived from these sources, or trace amounts, or acceptable levels. There are too many children with celiac depending on these labels and their accuracy for manufacturers and the government to be playing games with terms like "trace" and "acceptable levels." Our children's health and growth depend on this accuracy.

At present I depend on reading inanely minute print to determine the ingredients that are in the products that I buy for my child to eat. I spend a ridiculous amount of time reading the same ingredients each week on the same foods, because manufacturers can change their ingredients at will. Each visit to the supermarket is frustrating, never knowing if the salad dressing I bought last week has the same ingredients this week.

In the supermarket, only about 1% of foods are labeled gluten-free. I shop for gluten-free breads, pastas, and baking ingredients in a health food store where these products are labeled accurately, but are extraordinarily expensive (for no good reason that I can see, except that manufacturers seem to be adept at taking advantage of people who have no other options).

I have learned to read label ingredients, only to be thwarted by manufacturers who hide ingredients by not indicating what source certain foods come from. For instance, any product with vinegar in it is a product that has to be researched. Vinegar can be derived from wheat, apple cider, wine, etc. A celiac must know the source of this vinegar before consuming it. The inconsistency in labeling makes this a very frustrating process. Mustard is made with vinegar. First, you must make sure that the source of vinegar is a gluten-free source and then you have to hope that they don't change that source of vinegar a month later.

It is my hope that the FDA leaves no room for second guessing. Gluten-free needs to mean that a celiac maintaining a strict, life-long gluten-free diet for their health and well-being can depend on that label and that the product it represents will not get them sick.