2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC893
Submitter : Mr. Jason Mueller Date & Time: 09/14/2005 05:09:10
Organization : Mr. Jason Mueller
Category : Individual Consumer
Issue Areas/Comments
1. The term "gluten-free" should conform to the common international understanding that the product should contain less than 20 parts per million of gluten containing grains (wheat, barley, rye, or oats). This would ensure that food producers take more precautions when processing foods, and would result in fewer incidents of cross-contamination.

2. In choosing foods that do not contain gluten, I often choose fresh fruits, vegetables, beans, nuts, and meats. I avoid almost entirely processed foods, as there are few rules with regard to protecting foods from cross-contamination. When choosing rice, corn, and other gluten free flours for home baking, I rely on very high-priced specialty companies (such as Bob's Red Mill or Amazing Grains), as they perform a greater level of testing than competitors in ensuring their product is gluten-free. By establishing a gluten-free standard, there is the potential for greater competition and therefore reduction in price in gluten-free foods. It would also reduce the risk of contamination and increase the general level of food safety for those of us diagnosed with celiac disease. If you do not choose a food product from a company that specializes in gluten-free products, there is a significant amount of time involved in determining if a product is gluten-free. In the end there is often a very ambiguous answer regarding a product's gluten-free status, which means that the consumer is left to try the food and hope they do not have an allergic reaction.

3. Almost no products we purchase are marked gluten-free. I would estimate that approximately 10% of our products are marked this way.

4. If two products containing the same ingredients are offered and one is marked "gluten-free", then I would be much more likely to purchase the gluten-free product, even at a higher cost. Even if the ingredient list is the same, the product marked "gluten-free" is more likely to have been processed in a manner to prevent cross-contamination, and is more likely to have testing to ensure it is gluten-free.

5. I think having multiple levels defined for "gluten-free" would be confusing and ultimately not useful. If the point is to protect consumers who are allergic to gluten from becoming contaminated, then there is no point in labeling a product with a moderate level of gluten as "gluten-free", as it will most likely cause a reaction in a significant portion of the public that suffers from celiac disease. To me, this feels like a question that was a result from push back by a portion of the food industry that want to put "gluten-free" on a label without actually making any effort to ensure their product is safe for consumption by those with gluten intolerance. This type of structuring would make me less likely to trust the label, because as governmental regulations grow in complexity, so too increases the likelihood of mistakes being made by industries trying to conform to those rules.