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KEY POINTS:

  • 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 to define 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 (meaning any species belonging to the genus Triticum, including common wheat, durum wheat, einkorn wheat, emmer wheat, Khorasan wheat, or spelt wheat)
        • barley (meaning any species belonging to the genus Hordeum)
        • rye (meaning any species belonging to the genus Secale), or cross-bred varieties of these grains, such as triticale.
      • Will not include an ingredient derived from these grains that has not been processed to remove gluten. Examples of these types of ingredients are:
      • Can include an ingredient derived from these grains as long as it had been processed to remove gluten and the final food product contains less than 20 parts per million (ppm) of gluten. Examples of these types of ingredients are:
        • modified food starch from wheat
        • wheat starch
        • dextrin from wheat

        Note: Other wheat starch hydrolysates, such as glucose syrup from wheat, caramel color from wheat, and maltodextrin from wheat, are considered gluten-free because they are so highly processed. If you see these ingredients in products NOT labeled gluten-free it is highly unlikely that they would cause a food product to contain 20 ppm or more gluten. For more information, see Ingredients You Don't Have to Worry About.

      • Will contain less than 20 ppm of gluten from ingredients and/or gluten that may be in a product unintentionally due to cross contact with wheat, barley, or rye. 

        For an explanation of 20 parts per million gluten, please see http://www.glutenfreedietitian.com/newsletter/dietcom-blog-gluten-is-it-ok-to-have-a-little-bit/

      The FDA also considers the claims “no gluten,” “free of gluten,” and “without gluten” to be synonymous with the term gluten-free when used on a food label. Products making any of these claims must comply with the FDA’s gluten-free labeling rule. 

      Note: Foods also may contain the claims “made with no gluten-containing ingredients” and “not made with gluten-containing ingredients.” Products making these claims do NOT need to comply with the gluten-free labeling rule.
    • Allergen labeling: 2 In 2004 the Food Allergen Labeling and Consumer Protection Act (FALCPA) became law. Under this law, if an ingredient in a food contains protein from wheat, the word "wheat" must be included on the food label either in the ingredients list or Contains statement. FALCPA does not cover barley or rye protein.
FALCPA also pertains to ingredients only. It does not cover wheat protein that may be in a product unintentionally due to cross contact.

Note: If a food labeled gluten-free includes the word wheat in either the ingredients list or the Contains statement, the gluten-free labeling rule stipulates that additional language must be included on the food label. Specifically, an asterisk must be included after the word wheat and the following statement must be made, “The wheat has been processed to allow this food to meet the FDA requirements for gluten-free food.”

    • If a food is labeled gluten-free the manufacturer has determined that it is gluten-free and it may be used as part of a gluten-free diet. 3 Manufacturers of labeled gluten-free foods take several steps to ensure that their products are truly gluten-free. 4 These steps may include:

      If you have any questions regarding the protocols followed by a manufacturer of labeled gluten-free foods, call and ask to speak with a quality assurance representative.

    • For foods regulated by the FDA not labeled gluten-free, you should read the ingredients list and, in the case of wheat, the Contains statement looking for these words and terms: 3,5
    • By definition, these ingredients contain protein and nothing about their normal processing removes the protein. 

      Foods containing these words and ingredients should not be eaten.

      Visit the FDA versus USDA Food Labeling page for information on allergen labeling of foods regulated by the USDA.

      Malt, malt flavoring, and malt extract mean barley malt, barley malt flavoring, and barley malt extract. 5If a source other than barley is used it will be stated in the ingredients list, such as "corn malt."

      Oats and products containing oats should only be eaten if they are labeled gluten-free and are or contain specially manufactured gluten-free oats. 3, 5 Oats should not be added to the diet until you get the okay from your dietitian or doctor. The amount eaten should initially be limited to 50 grams of dry oats a day which is about 1/2 cup of dry rolled oats or 1/4 cup of dry steel cut oats. Visit the section on Oats for more detailed information.

      Brewer's yeast, when used as an ingredient in a food product, may be spent brewer's yeast which is a by-product of beer brewing. As a result it may be contaminated with malt and grain. 5, 7 

      Yeast extract , when used as an ingredient in a food product, may be spent brewer’s yeast which is a by-product of beer brewing. As a result this ingredient may be contaminated with barley protein from malt.

      Naturally gluten-free grains, flours, and products made from them may be contaminated with wheat, barley, and/or rye. Whenever possible it is best to choose labeled gluten-free versions of these products.3 Visit the section on Cross Contamination of Gluten-Free Grains for more detailed information.

      As you can see from the chart below, millet, buckwheat, sorghum, and soy flour labeled gluten-free are testing far lower for gluten contamination than the same flours not labeled gluten-free 8 In the case of millet flour and soy flour NOT labeled gluten-free, two different brands were tested. Gluten contamination will obviously vary between brands.

    GLUTEN CONTENT LABELED/UNLABELED GLUTEN-FREE FLOURS
    Flour Mean ppm Gluten Labeled Gluten Free Mean ppm Gluten Not Labeled Gluten Free
    Millet 15.5 ppm 305 ppm, 327 ppm
    Buckwheat < 5 ppm 65 ppm
    Sorghum < 5 ppm 234 ppm
    Soy < 5 ppm 92 ppm, 2925 ppm

    References: Thompson, Lee, Grace, JADA. 2010:110;937-940; Gluten Free Watchdog, LLC www.glutenfreewatchdog.org

TAKE HOME MESSAGES:

  • To determine if a food product is appropriate for you to eat read the food label looking for the term "gluten-free." If a product is not gluten-free, read the ingredients list and Contains statement looking for the words "wheat," "barley," "rye," "malt," "oats," "brewer's yeast" and "yeast extract."
  • If the food product is a naturally gluten-free grain, naturally gluten-free flour, or product made from a naturally gluten-free grain or flour it is best to choose labeled gluten-free varieties.

RESOURCES FOR YOU:

Thompson T, Case S. Food Labeling in the United States and Canada. In Real Life with Celiac Disease: Troubleshooting and Thriving Gluten-Free . Eds. Dennis M, Leffler D. AGA Press. Bethesda, MD, 2010.

The Gluten-Free Dietitian. Gluten Free: 4 Food Labeling Questions. http://www.glutenfreedietitian.com/articles/BLOGFoodLabelingQuestionsBlog.5.pdf . Accessed October 17, 2011.

U.S. Food and Drug Administration. Federal Register Proposed Rule-72 FR 2759 January 23, 2007. Food Labeling: Gluten Free Labeling of Foods. http://www.fda.gov/Food/LabelingNutrition/FoodAllergensLabeling/GuidanceComplianceRegulatoryInformation
/ucm077926.htm. Accessed October 13, 2011.

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.

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. Celiac Disease Toolkit. American Dietetic Association. Chicago, IL, 2011.
  4. Gluten-Free Dietitian. Ensuring Your Food Is Gluten Free: 6 Questions. http://www.glutenfreedietitian.com/newsletter/ensuring-your-food-is-gluten-free-6-questions/ . Accessed October 17, 2011.
  5. Thompson, T. ADA Pocket Guide to Gluten-Free Strategies for Clients with Multiple Diet Restrictions. 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.
  7. Gluten-Free Dietitian. Is Marmite Gluten Free? http://www.glutenfreedietitian.com/newsletter/is-marmite-gluten-free/ . Accessed October 17, 2011.
  8. Thompson T, Lee AR, Grace T. Contamination of naturally gluten-free grains, seeds, and flours in the United States: a pilot study. J Am Diet Assoc. 2010;110:937-940.
  9. The Gluten Free Watchdog. www.glutenfreewatchdog.org .

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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