2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC430
Submitter : Mrs. Shannon Robbins Date & Time: 09/09/2005 06:09:28
Organization : Mrs. Shannon Robbins
Category : Individual Consumer
Issue Areas/Comments
Dear FDA:

Our 3-year old daughter was diagnosed with an extreme case of Celiac Disease two months ago in July 2005. After several months of unexplained symptoms that could not be cured, we were relieved to know that she does have Celiac Disease and it can be controlled simply through a gluten- free diet. We were relieved because with all of her many symptoms, it could have been much worse. Our struggle now is to maintain a gluten-free diet with her so that she can lead a healthy, happy life. We are just now starting to see our beautiful 3-year old for who she really is and it is truly wonderful to see her flourishing, happy and healthy! We ask for your help and support when it comes to food labels, it is the only way to continue this lifestyle and to make it easier to those with a gluten intolerance. Please note that Celiac Disease is not an allergy, it is an intollerance that needs to be kept under control to be able to lead a healthy life.

We encourage you to adopt a regulation on the use of "gluten-free" on product labels that is in line with that which has been used in Europe and other countries (including the USA via the Codex Alimentarius) for many years--20 PPM for products that contain naturally gluten-free ingredients, and 200 PPM for products that have been rendered gluten-free such as those that may contain Codex Alimentarius quality wheat starch. The formal adoption of these existing regulations will allow for the continued importation of excellent, safe European products that are labeled "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 litigation--which is counterproductive for all people with this disease (most, if not all, gluten-free food companies do not 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 tolerance level is adopted).

Thank you,
Scott and Shannon Robbins