2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC981
Submitter : Mr. Sean Domineske Date & Time: 09/14/2005 06:09:51
Organization : Mr. Sean Domineske
Category : Individual Consumer
Issue Areas/Comments
I have two daughters with celiac disease.

1. 'Gluten-free' on a food label should indicate that the product a) does not contain wheat, oats, barley or rye or their derivatives, b) does not contain any products containing wheat, oats, barley and rye or their derivatives, c) is prepared and packaged to avoid gluten cross-contamination.

This is critical so I can choose products which are safe for my children and avoid products that will harm them.

2) I identify foods that do not contain gluten by a) reading the label, 2) consulting with gluten-free product lists and c) discussing product experiences with other celiacs through the Internet or celiac support groups. This is very time-consuming requiring anywhere from 5-15 hours per week. Since product recipes can change without notice, this is an ongoing requirement.

3) I would guess that about half of the products I buy are marked gluten-free which tend to be the traditionally wheat-based products such as pasta, breads, pancake mix, etc. This percentage is increasing as more companies are labeling mainstream products as gluten-free.

4) I would ALWAYS prefer to buy a product labeled gluten-free over a product not labeled gluten-free even if the ingredient list is the same. I am concerned, however, that the label may ONLY refer to ingredients and NOT to preparation or packaging.

5) I would consider the definition of levels of gluten-free helpful regarding trace amounts of gluten, if these levels were consistent with medical experts' views of safety. I would prefer this to zero-tolerance labeling if the result would be that a large percentage of products are marked 'may contain gluten.' Defensive labeling purely to avoid legal exposure is not helpful.

I would also prefer indications as to the level of 'certification' such as a) no gluten-containing ingredients, b) prepared and packaged on dedicated facility or line, c) tested for the presence of gluten, etc.