2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC284
Submitter : Mr. Douglas Fischer Date & Time: 09/01/2005 05:09:38
Organization : Mr. Douglas Fischer
Category : Individual Consumer
Issue Areas/Comments

I have just relocated back to the US after 3 years in England. I was diagnosed as Coeliac in March of this year, so am still learning how to deal with the dietary requirements. But I can say that it is so much easier in England than it is in the US. My diet in England was much better than here - in the US so much food is processed in some way or another and one cannot tell whether wheat is involved or not. In England the stores have 'gluten free' sections, they have lists of gluten free products that they make available to customers, many products say 'gluten free' on the labels, and for those that do not the ingredients list is far more comprehensible. In the US it is nearly impossible - so I've lost weight since I returned to the US.

1) What should ?gluten-free? mean on a food label? Why?

I think gluten-free should mean a reasonably attainable level of gluten free - not absolutely gluten free - otherwise we greatly reduce the number of products to be listed as gluten free, so we gain little. I think that for the purely 100% gluten free we have a specialty market and the specialty providers will happily list that as a market differentiator - we simply need to give them a label to use, and a standard to reach.

2) How do you identify foods that do not contain gluten? Time spent identifying foods?

First I look for a gluten-free statement on the label, and hope to find that. If I do not, then I look at the ingredient list, and (if available) do an internet search on the ingredients (note: too many incomprehensible ingredients disqualifies a product). I will also contact manufacturers directly to ask about their product lines - some are very helpful, others do not respond. In summary, it takes a long time. I often stop shopping before my list is filled simply because I am out of time.

3) What percentage of foods and which types purchased are marked ?gluten-free??

In England, many - for a given need (e.g. pasta) we can usually find a product. In the US - it is rare. And as a result it is also very, very expensive. I can't figure out why gluten free foods in the US have to cost so much more than gluten free foods in England - other than perhaps some manufacturers have caught on to the dilemma of coeliacs and have marked up their prices as the competition is limited.

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.

Yes. I buy the one marked gluten free. Because I trust the summary statement more than I trust a list of ingredients.

5) Would you consider a two or more level definition of gluten-free helpful?

Yes. I know some people need purely gluten free diets, whereas I need a more pragmatic level of gluten free. I don't want purely gluten free to be adopted, as that would severely limit the number of products that would qualify as gluten free. Similarly I do not want a more pragmatic level to dominate, as that would mean the most sensitive coeliacs were not being served. So I would adopt a two level system: 'Purely gluten-free' (meaning absolutely no trace of gluten) and 'gluten free' (meaning some acceptable trace gluten - tbd by your nutritional and health experts - but nothing more than that).

thanks for letting me voice my opinion. It would make my life hugely simpler - and that of my wife and children, and the people I go to visit, and so on - if we could please label food with a meaningful 'gluten free' tag. In the meantime, I'll do the best I can.

Douglas Fischer