Level 3

KEY POINTS:

• Food labeling is under the jurisdiction of either the Food and Drug Administration (FDA) or the United States Department of Agriculture (USDA). The FDA regulates all foods with the exception of meat products, poultry products, and egg products (meaning any dried, frozen, or liquid eggs, with or without added ingredients).
• The Food Allergen Labeling and Consumer Protection Act (FALCPA) amended the Federal Food, Drug, and Cosmetic Act. ¹ Food labeling is regulated under this act. FALCPA did not amend the Federal Meat Inspection Act, Poultry Products Inspection Act, or the Egg Products Inspection Act under which the Food Safety and Inspection Service (FSIS) of the USDA regulates meat products, poultry products, and egg products. ² Visit the section on Simple Label Reading for more information on FALCPA.

Currently, under FSIS regulations all ingredients in a food product regulated by the USDA must be listed in the ingredients list by their "common or usual name." ² Common or usual names include modified food starch, dextrin, and starch. Unfortunately, common or usual names do not always indicate the source of the ingredient. While the USDA does not have mandatory allergen labeling at this time, the FSIS believes they have widespread voluntary compliance with allergen labeling among their manufacturers of approximately 80 to 90%. ²

• To determine whether a food product not labeled gluten-free includes gluten-containing ingredients, you should read the ingredients list and Contains statement (if one is included on the label) looking for these words or terms: ^3,4,5
  • "Wheat"
  • "Barley"
  • "Rye"
  • "Oats"
  • "Malt" (unless a gluten-free source is named)
  • "Brewer's yeast"
  • "Yeast extract" (Avoid yeast extract unless you have contacted the manufacturer and have been told the source of the yeast is NOT spent yeast from beer manufacturing. Spent yeast is likely contaminated with barley protein from malt)
  • For more information on yeast extract, visit: 
    http://www.glutenfreedietitian.com/newsletter/2013/02/07/update-on-gluten-free-status-of-yeast-extract/.
• For USDA-regulated food products not labeled gluten free and not voluntarily following FALCPA you also should look for these words and terms: ^3,4
  • Starch (unless a gluten-free source is named): In USDA-regulated foods only, the single word "starch" in the ingredients list can mean either corn starch or wheat starch.⁶ In FDA-regulated foods the single word "starch" means corn starch.
  • Modified food starch (unless a gluten-free source is named): In USDA-regulated foods modified food starch may be wheat starch and the word "wheat" might not be included on the food label. Keep in mind that if modified food starch is manufactured in the US it is likely corn starch. For FDA-regulated foods if the source of modified food starch is wheat, the word "wheat" will be included on the food label.
  • Dextrin : In USDA-regulated foods dextrin (an incompletely hydrolyzed starch) may be made from wheat starch and the word "wheat" might not be included on the food label. If dextrin is manufactured in the US it is likely made from corn. For FDA-regulated foods if the source of dextrin is wheat starch, the word "wheat" will be included on the food label.
  
  If you have any questions about the source of starch, modified food starch, or dextrin in a USDA-regulated food product, please contact the manufacturer.

TAKE HOME MESSAGES:

• FALCPA did not amend the Federal Meat Inspection Act, Poultry Products Inspection Act, or the Egg Products Inspection Act under which the Food Safety and Inspection Service (FSIS) of the USDA regulates meat products, poultry products, and egg products.
• Under FSIS regulations all ingredients in a food product regulated by the USDA must be listed in the ingredients list by their "common or usual name." Common or usual names include modified food starch, dextrin, and starch.
• For food products regulated by the USDA that are not labeled gluten-free and not voluntarily following FALCPA, you should look for the ingredients "starch," "modified food starch," and "dextrin" in addition to "wheat," "barley," "rye," "oats," "malt," and "brewer's yeast" and "yeast extract."
• Modified food starch, starch, and dextrin rarely may be derived from wheat starch and the word "wheat" may not be declared on the label of a USDA-regulated food.

RESOURCES FOR YOU:

Gluten-Free Dietitian. Starch in USDA-regulated Foods. http://www.glutenfreedietitian.com/newsletter/starch-in-usda-regulated-foods/ . Accessed October 19, 2011.

Thompson, T. ADA Pocket Guide to Gluten-Free Strategies for Clients with Multiple Diet Restrictions . American Dietetic Association. Chicago, IL, 2011.

References:

1. US Food and Drug Administration. Center for Safety and Applied Nutrition. Food Allergen Labeling and Consumer Protection Act of 2004 (Title II of Public Law 108-282). August 2004. http://www.fda.gov/food/labelingnutrition/FoodAllergensLabeling/GuidanceComplianceRegulatoryInformation/ucm106187.htm. Accessed October 13, 2011.
2. Gluten-Free Dietitian. Labeling of USDA-Regulated Foods.http://www.glutenfreedietitian.com/newsletter/labeling-of-usda-regulated-foods/ . Accessed October 18, 2011.
3. Thompson, T. ADA Pocket Guide to Gluten-Free Strategies for Clients with Multiple Diet Restrictions . American Dietetic Association. Chicago, IL, 2011.
4. Celiac Disease Toolkit. American Dietetic Association. Chicago, IL, 2011
5. Gluten-Free Dietitian. Update on gluten-free status of yeast extract.http://www.glutenfreedietitian.com/newsletter/2013/02/07/update-on-gluten-free-status-of-yeast-extract/ . Accessed December 4, 2013.
6. Gluten-Free Dietitian. Starch in USDA-regulated Foods. http://www.glutenfreedietitian.com/newsletter/starch-in-usda-regulated-foods/ . Accessed October 19, 2011.

Revision Date: 12-18-13 
Author: Tricia Thompson, MS, RD 
Editors: Melinda Dennis, MS, RD, LDN and Daniel Leffler, MD, MS

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