2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC525
Submitter : Ms. Linda O'Meara-Tyson Date & Time: 09/09/2005 06:09:26
Organization : Ms. Linda O'Meara-Tyson
Category : Individual Consumer
Issue Areas/Comments
Dear FDA:

I 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). 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:

Additionally, there are millions of us who sufer from gluten allergies, intolerances, and disease, and a mainstream labeling program would enable us to live healthier, longer, more enjoyable lives. We need mainstream food manufacturers and restaurant owners to label their products. It would be excellent marketing for them -we would flock to their products by the thousands,if not millions, and would hopefully encourage the development of even more, and better gluten-free food products. A gluten-free diet is difficult and challenging to maintain, and we need restaurants and mainstream food manufacturers to let us know when their foods are gluten-free. Thank you.


Linda Tyson