2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC290
Submitter : Mrs. Nancy Zimmer Date & Time: 09/01/2005 05:09:44
Organization : Mrs. Nancy Zimmer
Category : Federal Government
Issue Areas/Comments
Dear FDA:
We encourage you to adopt a regulation on the use of gluten-free on product labels that is in lline with that which has been used in Europe and other countries (including the USA via the Codex Alimentariou) for many years-20 PPM for products that contain naturally gluten-free such as those that may contain Codex Alimentarius quality wheat starch. The formal adoptiohn of these exinting regulations will allow for the continued importation of excellent, safe European products that are lableded "gluten-free."

It is very important that you DO NOT adopt a "zero tolerance" regulation in this matter because doing so will cause many gluten-free food companies to discontinue their use of the term "gluten free" on their labels out of fear of litgation-which is counterproductive for all people with this disease (most, if not all, gluten-free food companies donot grow, transport or mill the gluten-free grains that they use as ingredients-a fact that will make them vulnerable to litigation if a zero tolerancelevel is adopted). Last, the inclusion of trace levels of gluten in the diets fo tose with celiac disease have been shown to be safe in many scientific studies, for more details please see: http://www.celiac.com/st_main.html?p_catid=15

Thank you,
Nancy Zimmer