2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC452
Submitter : Mrs. Lori LaPoff Date & Time: 09/09/2005 06:09:21
Organization : Mrs. Lori LaPoff
Category : Individual Consumer
Issue Areas/Comments
Dear FDA:

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). Last, the inclusion of
trace levels of gluten in the diets of those with celiac disease have been shown to be safe
in many scientific studies, for more details please see:

Thank you,
Lori LaPoff