Level 2

KEY POINTS:

• You must read the labels of all packaged food products to determine if they are appropriate to include in a gluten-free diet.
• There are two types of labeling that can help you determine whether a food is appropriate for you to eat - gluten-free labeling and allergen labeling.
  • Gluten-free labeling: ¹ The Food and Drug Administration (FDA) has a rule that defines the use of voluntary gluten-free claims on food labels. Under this rule a food labeled gluten-free:
    • Will not include as an ingredient the grains wheat, barley, rye, or cross-bred
    • Will not include an ingredient derived from wheat, barley, rye, or cross-bred varieties of these grains that has not been processed to remove gluten (e.g., wheat flour).
    • Can include an ingredient derived from wheat, barley, rye, or cross-bred varieties of these grains as long as it had been processed to remove gluten (e.g., wheat starch) and the final food product contains less than 20 parts per million (ppm) of gluten.
    • Will contain less than 20 ppm of gluten.

Parts per million or ppm also means milligrams per kilogram (there are 1 million milligrams in 1 kilogram). It is simply how we measure gluten content. You can look at it this way: if you purchased a bag of 1 million blue M&Ms and when you got it home you discovered that it actually contained 999,980 blue candies and 20 RED candies, you could say that your blue M&Ms were contaminated with 20 ppm red M&Ms.

Another way to imagine 20ppm: If you could cut a regular slice of bread (1 ounce) into 7,030 tiny pieces, 1 tiny piece would contain as much gluten as a whole slice of gluten-free bread (1 ounce) that contains 20ppm gluten. 
To read more: http://www.glutenfreedietitian.com/newsletter/dietcom-blog-gluten-is-it-ok-to-have-a-little-bit/

For a more detailed explanation of ppm, please see How Much Gluten is 20 Parts per Million? Available at http://www.glutenfreedietitian.com/newsletter/how-much-gluten-is-20-parts-per-million/.

• Crustacean shellfish
• Eggs
• Fish
• Milk
• Peanuts
• Soy
• Tree nuts
• Wheat 
  
  Allergens may be included in either the ingredients list or Contains statement immediately following the ingredients list.
• Sample label ³

• Ingredients: Enriched flour (wheat flour, malted barley, niacin, reduced iron, thiamin mononitrate, riboflavin, folic acid), sugar, partially hydrogenated soybean oil, and/or cottonseed oil, high fructose corn syrup, whey (milk), eggs, vanilla, natural and artificial flavoring) salt, leavening (sodium acid pyrophosphate, monocalcium phosphate), lecithin (soy), mono-and diglycerides (emulsifier)

  OR

  Contains Wheat, Milk, Egg, and Soy

• If a food is labeled gluten-free the manufacturer has determined that it is gluten-free and may be used as part of a gluten-free diet.
• If a food is not labeled gluten-free you must read the ingredients list and, in the case of wheat, the Contains statement looking for these words or terms: ^4,5
  • "wheat"
  • "barley"
  • "rye"
  • "oats" (See Tier 2 and Oats section for more details)
  • "malt"
  • "brewer's yeast"
  • “yeast extract”⁶ (Avoid unless you have contacted the manufacturer and have been told the source of the yeast is NOT spent yeast from beer manufacturing). Visit level 3 for more information on yeast extracts.

  If you do not see any of these words on the label of an FDA-regulated food then the product is unlikely to include any gluten-containing ingredients.

When choosing naturally gluten-free grains (e.g., millet grain) and flours (e.g., sorghum flour), and products made from them (e.g., rice crackers, corn-based cereal), it is highly recommended that you choose only labeled gluten-free products even if you do not see any gluten-containing ingredients on the food label. ^{4, 5}

This recommendation is due to the high risk of cross contact of gluten-free grains with wheat, barley, and rye. ^{4. 5} Visit the section on Cross Contamination of Gluten-Free Grains for detailed information.

TAKE HOME MESSAGES:

• Always read food labels.
• Look for the gluten-free label.
• If a food is not labeled gluten-free look for the words and terms, "wheat," "barley," "rye," "oats," "malt," "brewer's yeast" and "yeast extract" in the ingredients list and, in the case of "wheat," in the Contains statement.
• When buying naturally gluten-free grains, flours, and products made from them, choose varieties that are labeled gluten-free.

RESOURCES FOR YOU:

Food Allergen Labeling And Consumer Protection Act of 2004 Questions and Answers: Information for Consumers. Food and Drug Administration. http://www.fda.gov/Food/LabelingNutrition/FoodAllergensLabeling/GuidanceComplianceRegulatoryInformation/ucm106890.htm. Accessed November 5, 2011. 

FDA Gluten-Free Labeling. Gluten-Free Dietitian. http://www.glutenfreedietitian.com/newsletter/fda-gluten-free-labeling/

Food Allergen Labeling and Consumer Protection Act. Gluten-Free Dietitian.http://www.glutenfreedietitian.com/newsletter/food-allergen-labeling-and-consumer-protection-act/

How to Tell if a Food is Gluten Free. Gluten Free Dietitian. http://www.glutenfreedietitian.com/newsletter/dietcom-blog-how-to-tell-if-a-food-is-gluten-free/

References:

1. U.S. Food and Drug Administration. Federal Register Proposed Rule—78 FR 150 August 5, 2013. Food Labeling: Gluten Free Labeling of Foods. http://www.gpo.gov/fdsys/pkg/FR-2013-08-05/pdf/2013-18813.pdf. Accessed November 19, 2013.
2. 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.
3. US Food and Drug Administration. Food Allergen Labeling And Consumer Protection Act of 2004 Questions and Answers: Information for Consumers. December 12, 2005; Updated July 18, 2006. http://www.fda.gov/Food/LabelingNutrition/FoodAllergensLabeling/GuidanceComplianceRegulatoryInformation/ucm106890.htm. Accessed October 14, 2012
4. Thompson, T. ADA Pocket Guide to Gluten-Free Strategies for Clients with Multiple Diet Restrictions . American Dietetic Association. Chicago, IL, 2011.
5. Celiac Disease Toolkit. American Dietetic Association. Chicago, IL, 2011.
6. 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.

Revision Date: 12-4-13 
Author: Tricia Thompson, MS, RD 
Editors: Melinda Dennis, MS, RD, LDN and Daniel Leffler, MD, MS

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