Back in 2006 when the FALCPA (Food Allergen Labeling Consumer Protection Act) was passed, there was a directive that rules be established for the use of the term “gluten free” on product labels by the end of 2008.
We’re still waiting, but we may be getting close.
After years of discussion and on-again/off-again work to define what is indeed “gluten free,” the FDA has proposed rules that have been sent to The Hill for possible legislation. It has taken a long time – in part because not everyone agreed on the definition.
From where things stand right now, it appears that that the FDA rule will allow a product to be defined as “gluten free” if it does not contain wheat, rye, or barley, (the three grains that contain gluten) or any hybrid of these grains; ingredients that have not been processed to remove gluten; or any item made up of more than 20 parts per million of gluten. Twenty parts per million is the level at which most doctors agree that a celiac can still safely consume the product.
This is all very good news. Progress is progress, and I support all initiatives that help us understand what is in our food. Nevertheless, the result could be confusion for families with wheat allergies.
The FALCPA ensures that the common name of the top food allergens be clearly listed as an ingredient on food labels. For example, “wheat” must be listed if the product indeed contains wheat. Unlike the FALCPA, the gluten free rule will not require “gluten” to be listed as an ingredient if the food contains gluten. Conversely, it will define when a product can use the words “gluten free” on the package. (Of course, gluten isn’t an ingredient per se, just like fat isn’t an ingredient.)
So if a product meets the rules to be labeled “gluten free,” will it then be safe for those with wheat allergies? Not necessarily. The product may still contain wheat that has been modified to have the gluten removed (such products exist in the UK). And since the rule is 20 parts per million, there could still be minute traces of wheat. What this means is that those with wheat allergies may find the gluten free designation helpful as a starting point, but will still need to read the entire list of ingredients to make sure that the product is safe for them.
A larger concern for the food allergy community could be the trend towards food that has been modified. How would you feel about cow’s milk that has had the casein proteins removed or modified? Or what about hypoallergenic soy? Of course, these don’t exist… yet. Would you embrace them if they did? I’m not sure I could get on board.
Another interesting consideration for families like ours could be the acceptance of a “parts per million” approach for top food allergens. While I wouldn’t be in favor of replacing the FALCPA (I still want to know if even a tiny amount of a food allergen was intended to be in the product), establishing measurements and thresholds for safety could be more helpful than the usually-less-than-clear optional advisory labels (e.g. processed in a facility that also processes…).
What do you think?