Gluten free labelling laws are strict in AMERICA (20 ppm) - but are not the most strict in the world

"bottom-link">sanctioned qualitative analysis method for
Gluten Free labelling laws used to be very lax atdetermining gluten presence in food. Ref 3
200 ppm. This made many celiac’s sick.Curiously The Celiac Sprue Association has gone
Europe led the way in lowering permitted gluten ineven further in its labelling recommendation of
gluten free food to 20 ppm and the US is soon toclassing foods as gluten free ONLY if they contain
follow, but Australian authorities think that this isunder 3 ppm — The CODEX COMMISSION
still too high. This article looks at the intentionremains resolutely behind the 20 ppm specification
behind the current laws and what the realdue to the quality control that can reasonably be
threshold is believed to be (much less than 20expected from manufacturers. As it is, they may
ppm!)have until 2012 to abide by the FSA 20 ppm
At the core of any celiac shoppers shopping list isruling!
buying products that are gluten free. But whatAUSTRALIA
exactly does that mean? Do you buy foods thatAustralia has one of the most mature physical
have no ingredients that could possibly containand online gluten free markets in the world. Along
gluten grains, or are you willing to risk buyingwith this comes one of the most stringent gluten
foods that are classed as gluten free, becausefree labelling standards in the world:
they contain an amount of gluten thatQUOTE from Food Standards Australia New
‘someone’ has assessed as safe?Zealand: “To be labeled gluten-free in Australia
It would appear that the more experienced celiacand New Zealand, a food must contain "No
shopper knows what ingredients to look out for,Detectable Gluten’ by the most sensitive
however some very experienced gluten freeuniversally accepted test method. At the time of
shoppers still report feeling sick fromthe printing of the Ingredient List, 7th Edition,
manufactured foods purporting to be gluten free.testing can (readily) achieve a detection level of
As the information below will show, it all appears0.0005 (5 parts per million). If gluten is not
to be in the acceptable level that countries aredetected then the food can be labeled gluten
willing to legislate.free." Ref 2
The three most progressive legislation regionsThe Coeliac Society of Australia notes that
appear to be the US, Europe and Australia. These“some ingredients (i.e. glucose syrup, dextrose
areas will be discussed in this order.and caramel colour) are so highly processed that
EUROPE LEGISLATIONwhen tested, the results have always shown
Previous GFP research suggests that Europe‘no detectable gluten,’ even if derived
maybe one of the most gluten free awarefrom wheat," Therefore, these common
regions on earth, however they have very lowingredients derived from wheat are rendered
online search habits. This may of course be duegluten-free, even though gluten is declared on the
to low rates of celiac disease and/ or highproduct label.” Hence the qualification: "the label
availability of gluten free food in the generalgluten-free overrides the product’s
community.ingredient listing, and products with statements
Regarding the labelling requirements: “In Europe,such as "may contain wheat or gluten" should be
the Codex Commission approved 20ppm as anavoided." Ref 2
accepted threshold for gluten in 'gluten-free'While The FSANZ quote suggests that
products in 2008, in the first update to guidelinesAustralia’s gluten free labeling standard is
since 1983. The limit was massively cut fromlikely to become ‘law’, a 2007 survey
200ppm to 20ppm — and it claims thisconducted by the NSWFA suggests that the
level is considered to pose no risk to celiacassociation has very few powers to enforce it. In
sufferers. The reason for the change is that low2007 the NSWFA undertook a survey of foods
levels are more easily attainable than 25 yearslabeled “gluten-free” and found that of the
ago due to technological advances allowing for211 foods labeled as “gluten-free” in  retail
more accurate detection of minute glutenoutlets that 4.7% did NOT qualify. (Ref 3) In fact,
traces.” Ref 1ten samples were found to contain gluten, with
USA LABELINGgluten content ranging from 4 ppm to 160 ppm.
The US is one of the largest physical and onlineThe highest foods were found to be prawn
demand gluten free markets in the world. With itscrackers (160 ppm) followed by Self- raising flour
progressive technological and health advances you(30-45 ppm). Following international guidelines at
may expect that it also leads global labelling laws.the time, foods over 20 ppm were requested to
However gluten free products appear to be anbe withdrawn voluntarily by the manufacturer.
exception. While the Food and Drug AdministrationCONCLUSION
(FDA) introduced the Food Allergen Labeling &Australia has ‘potentially’ one of the
Consumer Protection Act (FALCPA) in 2006, thismost stringent gluten free labelling laws in the
was for the following eight food allegens “Milk,world. If the ‘no detectable gluten’
egg, wheat, soy, peanut, tree nuts, fish, andclause is taken at its word and kits can test
crustacean shellfish.” By 2007 the FDAbetween 3 and 5 ppm gluten, then this SHOULD
PROPOSED that gluten SHOULD be labeled atbe the upper limit of allowable gluten in gluten free
anything over 20mg per kg (20ppm) — butAustralian manufactured foods. However from
this has yet to be ratified.previous surveys, it appears that offenders of
Thus while many manufacturers are voluntarilythis law, are often given a voluntary request to
following this guideline “Journal of Allergy andwithdraw products and no fines or penalties are
Clinical Immunology found 25 different types ofissued, no media notification is required for
advisory term including ‘may contain’,‘small’ infractions.
‘shared equipment’ and ‘withinEurope and America have both settled on an
plant’. Additionally, they found that 65upper limit of 20 ppm, yet this is not law in the
percent of products listed non-specific terms, suchUS yet. The Celiac Sprue Association (USA) is
as ‘natural flavours’ and 'spices’,pushing for gluten free limits to be dropped to 3
and that 83 percent of those were not linked toppm however some US manufacturing groups
any specific ingredients.” Ref 1. This suggestsbelieve that this will prove too difficult to attain in
that gluten could potentially be hiding among thereality. Note that the Australian gluten free survey
non-specific terms.used Biokits Gluten Assay Kits manufactured by
Remarkably while standard foods are covered byTepnel Biosystems . The kits are an accredited
the FSA 20 mg ruling, it created a unique labelingAOAC Official method and measure gluten both
category just for CEREALS. Those that havequalitatively and quantitatively, with a limit of
been processed to reduce gluten to levels belowreporting of 3 ppm (mg/kg).
100 parts per million must carry a label such asUS research shows that many of its own
‘gluten-reduced,’ or ‘very-lowcountry’s products contain labelling terms
gluten.’ Foods that are naturally gluten-freesuch as as ‘natural flavours’ and
and acceptable for a gluten-free diet cannot be'spices’ which may or may not include
labeled as ‘gluten-free,’ orgluten. If this is the case on such a progressive
‘special-diet,’ but may say that they arecountry it is strongly suggested that eating food
‘naturally gluten-free.’ Ref 3from other countries that don’t abide by
The FSA also mandates that quantitativegluten free legislation IS a high risk venture. This
determination of gluten in foods and ingredients beraises the question of how much do you trust
based on an immunologic method or otheryour local manufacturer not to allow cross
method providing at least equal sensitivity andcontamination in the manufacture of ‘gluten
specificity, and that all testing done on equipmentfree’ foods, and where exactly does your
sensitive to gluten at 10 mg gluten/kg or below.favourite gluten free restaurant source its
The rules cite the enzyme-linked Immunoassayingredients?
(ELISA) R5 Mendez method as the officially