A Complete Guide to Gluten Free Labeling and Certification

GLUTEN FREE LABELING

Gluten free labeling with certification gives the you (the consumer) assurance from someone with no skin in the game (a third party certifier) that the food you’re eating is truly gluten free. Why does this matter?

Believe it or not, FDA regulation does not require manufacturers to test for the presence of gluten in their starting ingredients or finished foods that are labeled gluten-free.

The FDA has no plans to authorize third-parties to inspect facilities of manufacturers that label foods gluten-free or to verify if such foods meet the regulatory definition of gluten-free. So you are risking your health to some degree unless you buy certified gluten free products.

Some companies will say their product is gluten free if you call and ask them, or will claim it’s gluten free somewhere other than the product label. BEWARE! The company does not have to comply with the FDA standard of 20 parts per million (ppm) or less of gluten if the food or supplement isn’t labeled gluten free.

Also, the FDA standard does not apply to items that are not foods or supplements, such as medication.

20 PARTS PER MILLION

This threshold was chosen in part because most celiacs can tolerate trace amounts of gluten, but it was also chosen for another reason. The FDA relies on analytical methods that are scientifically validated to detect gluten. There aren’t any scientifically validated analytical methods that reliably detect gluten at less than 20ppm.

Does this mean this is the magic number at which celiacs no longer get sick? NO. Many celiacs are more sensitive than this and react to foods labeled gluten free. You also have to consider the VOLUME of food (and thus the total volume of gluten) you’re eating.

You may not react to 20ppm (.002%) in a little bag of chips. But you may react to .002% gluten in a big meal due to the increased amount of gluten you’re consuming. Even though the ratio remains the same, the overall amount of gluten in a large meal could put you over the edge.

Also be mindful of the “less than” terminology. The FDA and third-party certifications verify a product is at or below a certain threshold. So two products may have the same certification, and you may be fine with one and react to another because one has more gluten than the other, though both are below the specified threshold.

NATIONAL CELIAC ASSOCIATION (NCA)

The NCA is a non-profit organization “dedicated to educating and advocating for individuals with celiac disease and non-celiac gluten sensitivities.” This gluten free labeling certification means a product tests at 5ppm of gluten or less and is for the product, processing, and packaging. If you are sensitive and need this stricter certification, you can look up what companies have this certification here.

GLUTEN FREE CERTIFICATION ORGANIZATION (GFCO)

The GFCO is a program of the Gluten Intolerance Group (GIG). The GIG is a non-profit association whose mission statement is to “empower the gluten-free community through consumer support, advocacy, and education.” This gluten free labeling certification means a product tests at 10ppm of gluten or less. Find their certified products here.

NATIONAL SANITATION FOUNDATION (NSF)

The NSF was founded in 1944 to “protect and improve global human health.” This gluten free labeling certification means a product tests at 15ppm of gluten or less. The image may vary a little–I’ve seen it in a couple different colors to include blue and black.

GLUTEN FREE CERTIFICATION PROGRAM (GFCP)

The GFCP is owned and operated by the Allergen Control Group (ACG). They operate from Toronto, Canada and claim to be “North America’s leading subject matter expert in the field of gluten free and allergen food safety compliance and marketing.”

The US uses the green trademark and Canada uses the blue one. That said, you may see either since Canada is our neighbor. This gluten free labeling certification means a product tests at 20ppm of gluten or less. Find their certified products here.

TRICKY LABELING

As I mentioned earlier, manufacturers don’t have to test for the presence of gluten at all–they can simply label their food “gluten free,” “free of gluten,” “no gluten,” or “without gluten.” These products should have less than 20ppm of gluten, but no one is required to verify this.

You would hope the brand ramifications of making an inaccurate claim would motivate companies to ensure their product labeling is accurate…but that’s not always the case.

In fact, many companies try to make their gluten free labeling look very similar to a certification. You will often see the letters “GF” in a circle or an image of wheat with a circle around it but absent the word certified.

CRAFTY WORDING

Labeling products “naturally gluten free” or “made with no gluten containing ingredients” is another marketing approach companies use. This combination of words does not require them to comply with the FDA standard since they’re technically not claiming the product is gluten free.

Why do companies do this? Some people simply have a gluten intolerance and are not affected by a little gluten. So this disctinction could be helpful to those individuals. But I believe marketing is a huge factor.

In 2016, gluten free retail sales amounted to $15.5 billion. The gluten free food market is significant and growing. This is great news for us, but it also means we need to be savvy consumers since some marketing techniques can be confusing or intentionally misleading.

ALWAYS CHECK LABELING!

Labeling changes! Don’t take it for granted that a food item is gluten free. I’ve eaten a number of products that were labeled gluten free and then later were NOT labeled gluten free. This happens sometimes due to changes in ingredient sourcing, production, packaging, etc. Make it second nature to check the label every single time before eating something packaged.