2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC910
Submitter : Mrs. Molly Spencer Parker Date & Time: 09/14/2005 05:09:59
Organization : Mrs. Molly Spencer Parker
Category : Individual Consumer
Issue Areas/Comments
1) What should ?gluten-free? mean on a food label? Why?
Ideally, gluten-free would mean that there is zero gluten in the product in terms of ingredients, and that there is no chance for cross-contamination during the processing of the food. However, my understanding is that a zero threshold is impossible to prove. Therefore, a ?gluten-free? label should mean no more than 10 PPM of gluten in the product as verified by testing, and should mean that there is no chance of cross-contamination during the processing of the food.

2) How do you identify foods that do not contain gluten? Time spent identifying foods?
I have learned to be a careful reader of labels. I often spend time making phone calls or website inquiries into foods to make sure they are gluten- free. I spend an average of 1.5 hours per week researching products. If I decided to eat more processed foods, I would need to spend more time researching products.

3) What percentage of foods and which types purchased are marked ?gluten-free??
I estimate that 10% of the food I buy is labeled gluten-free. Other products I know to be gluten-free because of their nature (e.g., fresh fruits and vegetables) or because of the research I have done. Types of gluten-free labeled food that I purchase are cereals, baking ingredients, snacks, crackers, cookies, pancake mix, lunch meats.

4) Does ?gluten-free? printed on a product label influence your decision to purchase products having the same ingredients? To what extent?
To some extent, the ?gluten-free? label on a food will influence me to buy a product. However, I have learned from the experience of getting sick from supposedly ?gluten-free? food that I can?t trust the gluten-free label implicitly, and must do my own research to be certain that the product is gluten-free. Food manufacturers need to understand that they can?t say something is gluten-free if the possibility exists that it has been cross- contaminated.

5) Would you consider a two or more level definition of gluten-free helpful?
This would not be helpful to me, because I would only buy a product that I was sure was gluten-free. If a product?s label indicated that it could contain trace amounts of gluten, I wouldn?t buy it.