| At the core of any celiac shoppers shopping list is | | | | even further in its labelling recommendation of |
| buying products that are gluten free. But what | | | | classing foods as gluten free ONLY if they contain |
| exactly does that mean? Do you buy foods that | | | | under 3 ppm - The CODEX COMMISSION remains |
| have no ingredients that could possibly contain | | | | resolutely behind the 20 ppm specification due to |
| gluten grains, or are you willing to risk buying | | | | the quality control that can reasonably be |
| foods that are classed as gluten free, because | | | | expected from manufacturers. As it is, they may |
| they contain an amount of gluten that 'someone' | | | | have until 2012 to abide by the FSA 20 ppm |
| has assessed as safe? | | | | ruling! |
| It would appear that the more experienced celiac | | | | AUSTRALIA |
| shopper knows what ingredients to look out for, | | | | Australia has one of the most mature physical |
| however some very experienced gluten free | | | | and online gluten free markets in the world. Along |
| shoppers still report feeling sick from | | | | with this comes one of the most stringent gluten |
| manufactured foods purporting to be gluten free. | | | | free labeling standards in the world: |
| As the information below will show, it all appears | | | | QUOTE from Food Standards Australia New |
| to be in the acceptable level that countries are | | | | Zealand: "To be labeled gluten-free in Australia and |
| willing to legislate. | | | | New Zealand, a food must contain No Detectable |
| The three most progressive legislation regions | | | | Gluten' by the most sensitive universally accepted |
| appear to be the US, Europe and Australia. These | | | | test method. At the time of the printing of the |
| areas will be discussed in this order. | | | | Ingredient List, 7th Edition, testing can (readily) |
| EUROPE LEGISLATION | | | | achieve a detection level of 0.0005 (5 parts per |
| Previous GFP research suggests that Europe | | | | million). If gluten is not detected then the food can |
| maybe one of the most gluten free aware | | | | be labeled gluten free. |
| regions on earth, however they have very low | | | | The Coeliac Society of Australia notes that some |
| online search habits. This may of course be due | | | | ingredients (i.e. glucose syrup, dextrose and |
| to low rates of celiac disease and/ or high | | | | caramel colour) are highly processed so the |
| availability of gluten free food in the general | | | | results have shown 'no detectable gluten,' even if |
| community. | | | | derived from wheat, Therefore, these common |
| Regarding the labeling requirements: "In Europe, | | | | ingredients derived from wheat are rendered |
| the Codex Commission approved 20ppm as an | | | | gluten-free, even though gluten is declared on the |
| accepted threshold for gluten in 'gluten-free' | | | | product label. Hence the qualification: the label |
| products in 2008, in the first update to guidelines | | | | gluten-free overrides the product's ingredient |
| since 1983. The limit was massively cut from | | | | listing, and products with statements such as |
| 200ppm to 20ppm - and it claims this level is | | | | "may contain wheat or gluten" should be avoided. |
| considered to pose no risk to celiac sufferers. The | | | | While The FSANZ quote suggests that Australia's |
| reason for the change is that low levels are more | | | | gluten free labeling standard is likely to become |
| easily attainable than 25 years ago due to | | | | 'law', a 2007 survey conducted by the NSWFA |
| technological advances allowing for more accurate | | | | suggests that the association has very few |
| detection of minute gluten traces." | | | | powers to enforce it. In 2007 the NSWFA |
| USA LABELING | | | | undertook a survey of foods labeled "gluten-free" |
| The US is one of the largest physical and online | | | | and found that of the 211 foods labeled as "GF" in |
| demand gluten free markets in the world. With its | | | | retail outlets that 4.7% did NOT qualify. Ten |
| progressive technological and health advances you | | | | samples were found to contain gluten, with gluten |
| may expect that it also leads global labelling laws. | | | | content ranging from 4 ppm to 160 ppm. The |
| However gluten free products appear to be an | | | | highest foods were found to be prawn crackers |
| exception. While the Food and Drug Administration | | | | (160 ppm) followed by Self- raising flour (30-45 |
| (FDA) introduced the Food Allergen Labeling | | | | ppm). Following international guidelines at the time, |
| & Consumer Protection Act (FALCPA) in | | | | foods over 20 ppm were requested to be |
| 2006, this was for the following eight food | | | | withdrawn voluntarily by the manufacturer. |
| allergens "Milk, egg, wheat, soy, peanut, tree nuts, | | | | CONCLUSION |
| fish, and crustacean shellfish." By 2007 the FDA | | | | Australia has 'potentially' one of the most stringent |
| PROPOSED that gluten SHOULD be labeled at | | | | gluten free labeling laws in the world. If the 'no |
| anything over 20mg per kg (20ppm) - but this | | | | detectable gluten' clause is taken at its word and |
| has yet to be ratified. | | | | kits can test between 3 and 5 ppm gluten, then |
| Thus while many manufacturers are voluntarily | | | | this SHOULD be the upper limit of allowable gluten |
| following this guideline "Journal of Allergy and | | | | in gluten free Australian manufactured foods. |
| Clinical Immunology found 25 different types of | | | | However from previous surveys, it appears that |
| advisory term including 'may contain', 'shared | | | | offenders of this law, are often given a voluntary |
| equipment' and 'within plant'. Additionally, they | | | | request to withdraw products and no fines or |
| found that 65 percent of products listed | | | | penalties are issued, no media notification is |
| non-specific terms, such as 'natural flavours' and | | | | required for 'small' infractions. |
| 'spices', and that 83 percent of those were not | | | | Europe and America have both settled on an |
| linked to any specific ingredients." This suggests | | | | upper limit of 20 ppm, yet this is not law in the |
| that gluten could potentially be hiding among the | | | | US yet. The Celiac Sprue Association (USA) is |
| non-specific terms. | | | | pushing for gluten free limits to be dropped to 3 |
| Remarkably while standard foods are covered by | | | | ppm however some US manufacturing groups |
| the FSA 20 mg ruling, it created a unique labeling | | | | believe that this will prove too difficult to attain in |
| category just for CEREALS. Those that have | | | | reality. Note that the Australian gluten free survey |
| been processed to reduce gluten to levels below | | | | used Biokits Gluten Assay Kits manufactured by |
| 100 parts per million must carry a label such as | | | | Tepnel Biosystems. The kits are an accredited |
| 'gluten-reduced,' or 'very-low GF foods that are | | | | AOAC Official method and measure gluten both |
| naturally gluten-free and acceptable for a | | | | qualitatively and quantitatively, with a limit of |
| gluten-free diet cannot be labeled as 'gluten-free,' | | | | reporting of 3 ppm (mg/kg). |
| or 'special-diet,' but may say that they are | | | | US research shows that many of its own |
| 'naturally gluten-free. | | | | country's products contain labelling terms such as |
| The FSA also mandates that quantitative | | | | as 'natural flavours' and 'spices' which may or may |
| determination of gluten in foods and ingredients be | | | | not include gluten. If this is the case on such a |
| based on an immunologic method or other | | | | progressive country it is strongly suggested that |
| method providing at least equal sensitivity and | | | | eating food from other countries that don't abide |
| specificity, and that all testing done on equipment | | | | by gluten free legislation IS a high risk venture. |
| sensitive to gluten at 10 mg gluten/kg or below. | | | | This raises the question of how much do you |
| The rules cite the enzyme-linked Immunoassay | | | | trust your local manufacturer not to allow cross |
| (ELISA) R5 Mendez method as the officially | | | | contamination in the manufacture of 'gluten free' |
| sanctioned qualitative analysis method for | | | | foods, and where exactly does your favourite |
| determining gluten presence in food. | | | | gluten free restaurant source its ingredients? |
| Curiously The Celiac Sprue Association has gone | | | | |