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Gluten-Free Labeling Regulations Worldwide: Not All Definitions are Equal!
by Kim Koeller and Robert La France

We have seen great improvement on a global basis over the past five years with regard to food labeling. These advances have been welcomed by the growing community of individuals impacted by celiac, food allergies, intolerances and specialized diets worldwide. When traveling at home and abroad, one must always be aware of the local labeling regulations. We have outlined some of the major global movements below to help you in your gluten-free travels around the world.

In 2002, the Food Standards Australia New Zealand (formerly the Australia New Zealand Food Authority) declared that "all food labels will show the declarations of the presence of potential allergens in foods such as gluten, peanuts and other nuts, seafood, milk, wheat, eggs and soybeans. In addition, all foods containing genetically modified materials must be labeled as such."

In 2005, the European Union Directive on product labeling required manufacturers to identify 12 common food allergens including: celery, dairy, eggs, fish, gluten, mustard, peanuts, sesame seeds, shellfish, soy, tree nuts and wheat, and their derivatives.

As of 1/1/2006, the US Food Allergen Labeling and Consumer Protection Act (FALCPA) went into effect. The presence of eight allergens including: dairy, eggs, fish, peanuts, shellfish, soy, tree nuts and wheat are now declared on ingredient lists. However, those of us following a gluten-free diet in the U.S., have not had all of our concerns sufficiently addressed since wheat, and not gluten, is included in the current allergen labeling. The Food and Drug Administration (FDA) is currently developing a definition for the term "gluten-free," as there is currently no approved legislature for U.S. food manufacturers or consumers. Once approved, this will help U.S. consumers managing a gluten-free diet safely navigate grocery store aisles in search of safe foods, as well as restaurants and those in the hospitality industry understand and identify gluten-free ingredients.

Outside of the U.S., there are also differences in the definition of the term "gluten-free", and which foods are considered gluten-free. According to The Coeliac Society of Australia, "there are two types of foods suitable for those requiring a gluten-free diet:

  1. Foods labeled gluten-free
  2. Foods made for the general market which are gluten free by ingredient

To be labeled gluten-free in Australia and New Zealand, a food must contain "No Detectable Gluten’ by the most sensitive universally accepted test method. At the time of the printing of the Ingredient List, 7th Edition, testing can achieve a detection level of 0.0005 (5 parts per million). If gluten is not detected then the food can be labeled gluten free."

What makes matters more complex is that, "some ingredients (i.e. glucose syrup, dextrose and caramel colour) are so highly processed that when tested, the results have always shown ‘no detectable gluten,’ even if derived from wheat," according to The Coeliac Society of Australia. Therefore, these common ingredients derived from wheat are rendered gluten-free, even though gluten is declared on the product label. So, you can buy a product that indicates that it is gluten-free and also states on the label that ingredients included in the product are derived from gluten-containing grains. While in Australia and New Zealand, The Coeliac Society of Australia advises that, "the label gluten-free overrides the product’s ingredient listing, and products with statements such as "may contain wheat or gluten" should be avoided."

The European Union follows a different standard and is guided by the Codex Alimentarius, which is managed by the Food and Agriculture Organization of the United Nations (FAO) and the World Health Organization (WHO). The standard "allows products to be labelled gluten-free that contain an ingredient called "Codex wheat starch," which contains 200 parts per million of gluten. Coeliac UK makes the following statement in their Gluten Free Food and Drink Directory about other ingredients derived from gluten containing grains:

"Some ingredients can be derived from wheat or barley, but are safe for people with coeliac disease. This is because they are highly processed and the gluten content is negligible e.g. glucose syrups derived from barley or wheat. Some ingredients may have a low level of gluten, but still be within the Codex standard e.g. Codex wheat starch and malt extract. When malt extract is used in large amounts, as in some malted breakfast cereal products, the gluten level is not within the Codex standard. These products are not suitable on a gluten-free diet."

Coeliac UK also makes the following statement concerning the safety of Codex wheat starch:

"Whilst the majority of people with coeliac disease can tolerate Codex wheat starch, there are those who are more sensitive and suffer symptoms and gut damage if they eat Codex wheat starch."

According to the Canadian Celiac Association, "gluten-free in Canada means that the food does not contain wheat, spelt, kamut, rye, barley, oats or triticale, or any parts thereof. In Canada, wheat starch is not permitted in a gluten-free diet."

Here in the U.S., the FDA is proposing to, "define the food labeling term "gluten-free" to mean that a food bearing this claim does not contain any of the following:

• An ingredient that is a "prohibited grain", which refers to any species of wheat (durum, wheat, spelt wheat, or kamut), rye, barley or their crossbred hybrids

• An ingredient that is derived from a "prohibited grain" and that has not been processed to remove gluten

• An ingredient that is derived from a "prohibited grain" that has been processed to remove gluten, if the use of that ingredient results in the presence of 20 micrograms or more gluten per gram of food

• An ingredient containing 20 micrograms or more gluten per gram of food"

By establishing a US definition for the term "gluten-free" and uniform conditions for its use in the labeling of foods, the FDA believes that this will ensure that persons purchasing US products are not misled and are provided with accurate information.

Your input in the process is important, so if you haven’t had the opportunity to voice your concerns or support of this proposition, now is the time to do so. The proposed rule has a 90-day public comment period, which ends on April 23, 2007. Interested persons can submit comments electronically or in writing as per instructions provided in Docket No. 2005N-0279, available via the following web-link:

http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/E7-843.htm

For more information on the proposed US definition, please read the document titled "Questions and Answers on the Gluten-Free Labeling Proposed Rule", which is posted on the FDA’s Center for Food Safety and Applied Nutrition website via the following link:

http://www.cfsan.fda.gov/~dms/glutqa.html

Remember, until there is a universal consensus on acceptable levels of gluten and standardization of definitions, product labeling of gluten-free and gluten-containing ingredients will continue to vary from country to country. As always, be sure to understand country-specific labeling and read product labels diligently wherever you might be, around the corner from your home or around the world, to ensure safe eating anywhere!

Product Guides and Directories

To help you find safe gluten-free foods during your travels, there are a number of resources available from various organizations around the world. The following information provides an overview of the guides and directories detailing country specific product names, ingredient definitions and manufacturer/brand listings currently available. To purchase these guides or to obtain more information, contact each of the organizations directly:

Australia

The Coeliac Society of Australia
Ingredient List, 7th Edition: An essential guide for those requiring a gluten-free diet - Published in English
http://www.coeliacsociety.com.au

Canada

Canadian Celiac Association
Pocket Dictionary of Ingredients-–Acceptability of Foods and Food Ingredients for the Gluten-Free Diet - Published in English and French
http://www.celiac.ca

France

Association Française des Intolérants au Gluten
Liste des Produits Autorisés - Published in French
http://www.afdiag.org/

Ireland

The Coeliac Society of Ireland
A List of Gluten-Free Manufactured Products - Published in English
http://www.coeliac.ie

Italy

Associazione Italiana Celichia
Il Prontuario on Internet - Published in English and Italian
http://www.celiachia.it

Netherlands

Vodeinscentrum
Lijst van Glutenvrije Merkatikelin - Published in Dutch
http://www.coeliakievereniging.nl

New Zealand

Manufactured Foods Database
On-line listing available in English
http://mfd.co.nz

Spain

Federación de Asociaciones de Celíacos de España
La Lista de Alimentos Sin Gluten - Published in Spanish
http://www.celiacos.org

United Kingdom

Coeliac UK
Gluten Free Food and Drink Directory - Published in English
http://www.coeliac.co.uk

United States

Celiac Sprue Association
The CSA Gluten-Free Product Listing - Published in English
http://www.csaceliacs.org

Clan Thompson™
Clan Thompson™ Celiac SmartLists and Pocket Guides - Available in English
http://www.clanthompson.com

Kim Koeller and Robert La France are President and Executive Vice President of GlutenFree Passport®. They are the award-winning co-authors of the Let’s Eat Out! Your Passport to Living Gluten and Allergy Free book series, winner of the USABooknews.com Best Language Guide and finalist for Best Health/Diet Book 2006; as well as, the 2006 Benjamin Franklin Award finalist for Best Health Book and Best First Book Non-fiction. For more information and free educational materials, please visit http://www.glutenfreepassport.com.


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