2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC570
Submitter : Ms. Esther Bowring Date & Time: 09/12/2005 06:09:17
Organization : Ms. Esther Bowring
Category : Individual Consumer
Issue Areas/Comments
Dear FDA:

It is hard to describe how much adoption of gluten-free labeling requirements will mean for people with celiac. For those who don't have to think twice about shopping and food preparation, it is inconceivable to imagine the difficulties encountered by those with celiac disease when engaged in these everyday activities. I applaud your efforts to simplify life for those with celiac disease, while improving their long-term health and reducing our nation's health care costs.

Although a worthy goal is to ensure that food labelled gluten-free is indeed free of gluten, a 100 percent compliance requirement is not only unrealistic, but unattainable. Establishing such a standard would actually reduce choices for celiacs, rather than expand them, and make life more difficult. Therefore, I encourage you to adopt a regulation on the use of 'gluten-free' on product labels that is in line with what is used in Europe and other countries (including the USA via the Codex Alimentarius) --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.'

Thank you,
Esther Bowring