2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC165
Submitter : Mr. Adam Schroeder Date & Time: 08/24/2005 05:08:36
Organization : Mr. Adam Schroeder
Category : Individual Consumer
Issue Areas/Comments
1) What should ?gluten-free? mean on a food label? Why?
Gluten Free should mean the item is safe to eat for people with Celiac Disease. It can't get any simpler than that.

2) How do you identify foods that do not contain gluten? Time spent identifying foods? I try to eat organic foods with few ingredients that are all safe, or basic foods like steak and chicken. If I am eating a processed food then I must contact the manufacture and to find out if it is gluten free. This is often a time consuming and sometimes futile process as sometimes they will simply say they don't know. Or even if a product is GF it may not be if the manufacture changes suppliers for one of the ingredients.

3) What percentage of foods and which types purchased are marked ?gluten-free??
About 30% of what I buy is marked gluten free. Most of this is from the health food store and are items like bread, frozen meals, and other quick and easy snacks.

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.

Without any doubt I will purchase a product that is marked ?gluten-free? over a similar product that is not marked.

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.)

I don't now enough about how much gluten is to much for a Celiac, so I'm not sure how well this will work. I'm aslo concerned that many manufactures would simply use the loosiest definition just to be on the safe side, or to make it easier on them on not avoiding cross contamination.

However, I still believe this could be a good system if these concerns are addressed.

Thank you very much for taking the time to listen to my opinions.