Understanding Labels

Producers Bringing Clarity

Bringing clarity to food manufacturers' voluntary advisory statements.

By Laura Allred

When consumers with celiac disease or non-celiac gluten sensitivity (NCGS) examine a food package at the store, they may find information about the product’s gluten content presented in several different ways. They can, of course, read the ingredient list. The manufacturer may also include a gluten-free claim on the packaging or include the certification mark of a third-party organization that is either certifying that the product is gluten-free or just that the food manufacturer’s management system meets certain gluten-free standards.

In addition to these potential gluten-free indications, a food manufacturer may also choose to include a voluntary advisory statement on its product packaging. Unfortunately, these advisory statements can be a source of confusion for consumers. For example, a consumer may understandably become alarmed if the package contains a third-party gluten-free certification logo and the voluntary advisory statement “May Contain Wheat.”

Because wheat is an allergen, food manufacturers must identify it by name whenever any amount is present in food in order to comply with the Food Allergen Labeling and Consumer Protection Act of 2004. Wheat must be identified even if the product is labeled gluten-free because it contains no gluten or the amount of gluten is less than the FDA limit of 20 ppm gluten.

To attain certification by the Gluten Intolerance Group’s Gluten-Free Certification Organization (GFCO), the product must contain no more than 10ppm gluten. Products that contain the GFCO logo may also contain one of several common voluntary advisory statements, each of which should be used by manufacturers and interpreted by consumers differently.

Voluntary Advisory Statements

Producers Bringing Clarity2

If the product is labeled “Contains Wheat,” it should be an indication that wheat has intentionally been added to the product. On a GFCO-certified product, this would mean that the product contains wheat starch, wheat grass or some other gluten-free component of wheat. Products labeled gluten-free that also have “Contains Wheat” statement are required to have an additional explanatory label, such as “This product contains wheat starch that has been processed to remove gluten to less than 10 ppm.”

If the GFCO-certified product is labeled “Processed on Shared Equipment with Wheat,” it is an indication that the product was made in a facility that also manufactures products containing wheat. However, to receive GFCO certification, the facility must use extremely stringent controls, cleaning protocols, as well as equipment and product-testing requirements to ensure that gluten remains below 10ppm in their gluten-free finished products.

Finally, if a manufacturer includes the advisory statement “May Contain Wheat” on a GFCO-certified product, it means that the company handles wheat in their facility but keeps it segregated from gluten-free production in order to ensure that all finished products contain less than 10ppm gluten.

Consumers with celiac disease and NCGS look to food manufacturers and the information they choose to place on their product packaging for clear guidance about whether the product is safe for them to eat. For that reason, manufacturers should be as clear as possible when making voluntary advisory statements so that consumers will not become confused or mislead by the product label.

Laura Allred is the regulatory and standards manager for the nonprofit Gluten Intolerance Group (GIG). Allred’s experience includes a background in immunology and eight years of directing a food testing laboratory and test kit manufacturing operation. GIG’s food safety certification programs, the Gluten-Free Certification Organization (GFCO) and Gluten-Free Food Services (GFFS), have been recognized leaders in the gluten-free community for more than 20 years. The GFCO certification logo is the symbol of trust for the gluten-free community, with more than 50,000 products certified worldwide. For more information, visit www.gluten.org.


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