​by Joesph Millman

​

In Part I of this article, I explain the current difficulties facing individuals with Celiac Sprue disease, gluten intolerance, or other gluten sensitivites who reside in the United States. I illuminate the different approaches that the United States and other countries have taken to standardize “Gluten-Free” labels. I conclude part one by arguing that the U.S. should institute stronger regulations—similar to those in the EU or Canada.  In Part II, I offer some resources: guidelines for labels that can be trusted, websites for help in determining the amount of gluten present in different brands, and an Appendix listing sources of gluten. For those interested in taking action, I  note the existence of different interest groups and ways of lobbying the FDA.

 

Issues in Gluten Free Labeling:   Part I

 

 

​WHERE THE U.S. IS RIGHT NOW:  The Label “Gluten Free” is not Trustworthy
 

 

The battle for gluten-free food labels has marked the most recent skirmish in the crusade for better and clearly food regulations. In 2004, Congress passed a bill, which, at the time, was heralded as the solution to the labeling issue. The Food Allergen Labeling Consumer Protection Act (FALCPA) mandated that the Food and Drug Administration (FDA) finalize standards for gluten-free labeling by 2008. However, the FDA has currently not adhered to the parameters set out in the bill. It has neglected to impose any standards on gluten-free labeling, although the organization has promised to do so multiple times.  Rather, the FDA  has continued to extend the deadline, most recently, to October 1, 2012.

 

Because of this delay, many of the labels on foods cannot be trusted—they hold no weight as they are not backed by any FDA sanctions. In fact, many companies label their food as gluten-free when their food actually contains gluten, sometimes more than in an unlabeled product. “Some ‘gluten-free’ products may indeed be free of wheat gluten, but not of rye or barley gluten,” says Pam King, director of operations and development at the Center for Celiac Research at the University of Maryland. [1] This is more than just irresponsible, it is also dangerous. Eighteen million Americans may suffer from gluten sensitivity, which is triggered by rye, barley, and wheat gluten, and some 1.8 million Americans may suffer from Celiac disease. [2]



Clearly, It is not safe to buy foods based on their label when so many foods are labeled with the words, “gluten free”, yet contain gluten products, [3] and when trace amounts of gluten are permissible. Many countries allow gluten-free labels on amounts of 20 ppm or less, which is not enough to trigger most reactions. [4] The 20 ppm definition stems from the Codex Alimentarius, a report released by the Geneva-based World Health Organization. [5] However, some countries, the U.S. included, still haven’t enacted the standards put forth in the Codex on the national level.



In contrast to the soft regulations put forth by the U.S., many countries, including our neighbor Canada and the countries in the European Union (EU), have instituted measures for accountability of labeling. Health Canada -the Canadian counterpart to the FDA- has already put forth a definition of “Gluten Free” as follows: “no ingredients with any gluten proteins from prohibited grains; must not contain ingredients with modified or hydrolyzed proteins from those grains that have been added deliberately to the product; and must test at less than the 20ppm standard considered ‘gluten-free.’” [6]



In much of the rest of the developed world, there are standardized restrictions on gluten free products. In the EU there are two categories for gluten labeling. “1. Foods labeled ‘very low gluten’ are foods that contain one or more ingredients made from wheat, barley, rye, oats, or crossbred varieties (e.g., triticale) that have been processed to reduce gluten with a gluten level not more than 100 parts per million of gluten (100 milligrams/kilogram) in the final food product as sold to the consumer. 2. Foods labeled ‘gluten-free’ are foods that contain no more than 20 parts per million of gluten (20 milligrams/kilogram) in the final food product as sold to the consumer.” [7]  The countries with the best regulations are New Zealand and Australia; [8] these countries require that the gluten is under 3ppm in different products. This is in sharp contrast to Canada and the EU, which have restrictions of 20 ppm, and the U.S., which has no restrictions. There are few other developed countries without gluten-free restrictions (Russia, China, for instance,) so the U.S. would do well to join the growing ranks of those countries that do.

 

PART II:

Resources for How to Avoid Gluten in the Marketplace
     

 

Given the lack of standards in the status quo, it can be difficult to discern which brands are healthy and which are not. There are a few ways to remedy this.
 

First, look for the label that guarantees brands to be free of gluten at less than 10 ppm.

Currently, several organizations certify different brands to be free of gluten at less than 10 ppm (lower than even the national standards in Canada and the EU). The first body which does so is the Gluten Free Certification Organization by means of the GFCO label shown above. [9]  GFCO also maintains a list of all of the Gluten Free companies and brands available.  Other organizations are the Gluten Intolerance Group and the Celiac Sprue Association. These organizations function the same way as the GFCO, by updating a list of gluten free brands. It’s best to use these lists for two reasons. First, as discussed above, many companies have wheat and other gluten products in foods, but get away with labeling their foods as gluten-free because of the lax regulations, often making it difficult to detect whether these products are actually gluten-free, or just claim to be. Second, artificial flavors or additives might have gluten, which can make it even harder to detect whether a food product contains gluten or not. Thus, right now, the best way to shop for gluten free products is either to rely on the GFCO label, or to read ingredients closely while consulting the GFCO list or the Celiac Sprue Association’s guidelines.  Generally, avoiding processed foods and eating a diet of whole foods prepared at home is the only reliable means for completely avoiding gluten.
​
While the above measures can be helpful when shopping for gluten-free foods, there are other products that can contain gluten, specifically, pharmaceuticals and vitamins. Unlike the case with food regulation, until the FDA finally standardizes a process for obtaining a gluten-free lable, there are no entities evaluating the gluten level of pharmaceuticals. However, the gluten level can be inferred by consulting the list of ingredients, [10] or by asking a physician.

It is wise be on the safe side as many Americans who do not have Celiac disease may still be gluten sensitive, as a recent study in the American Journal of Gastroenterology showed. (See our companion article on Celiac Sprue and Gluten Intolerance). So, it is advisable to get tested for gluten sensitivity, just to err on the side of caution.

While the solutions recommended here are helpful, they are merely temporary. The FDA still does not hold different companies accountable for the gluten labeling processes, and this incentivizes companies to cut corners by mislabeling items.  The FDA offers their version of the situation on their consumer update page.



​WHAT WE CAN DO TO MAKE A DIFFERENCE!

*There are many petitions and interest groups working to expedite the FDA's process. For those interested, the organization  “1in133.org”’s petition can be found here. [11]

* An additional petition sponsored by celiac.com is posted on the White House web page.

​*Please join the alumni of the Theta Lambda Chapter of the Eta Sigma Alpha National Home School Honor Society in seeking clarity on our food labels by signing the petitions!

​*Be aware of the issues for those with gluten intolerance and sensitivity who approach local Food Banks and Soup Kitchens, or receive aid in the wake of local events like Hurricane Sandy.

​*When donating food items to community outreach organizations, make a special effort to include gluten free products.

​*Annually, the Alumni of Theta Lambda prepare a special St. Valentine’s Day Food Drive, coordinating Gluten Free Donations in New Jersey.   Find out more details on our website.​

 

​
Appendix: List of possible gluten containing foods and ingredients

These lists are prepared by Scott Adams of Celiac.com. [12]

 

Abyssinian Hard (Wheat triticum durum)
Alcohol (Spirits – Specific Types)
Amp-Isostearoyl Hydrolyzed Wheat Protein
Atta Flour
Barley Grass (can contain seeds)
Barley Hordeum vulgare
Barley Malt Beer (most contain barley or wheat)
Bleached Flour
Bran Bread Flour
Brewer’s Yeast
Brown Flour
Bulgur (Bulgar Wheat/Nuts)
Bulgur Wheat
Cereal Binding
Chilton Club Wheat (Triticum aestivum subspecies compactum)
Common Wheat (Triticum aestivum)
Cookie Crumbs
Cookie Dough
Cookie Dough Pieces
Couscous
Criped Rice
Dinkle (Spelt)
Disodium Wheatgermamido Peg-2 Sulfosuccinate
Durum wheat (Triticum durum)
Edible Coatings
Edible Films
Edible Starch Einkorn (Triticum monococcum)
Emmer (Triticum dicoccon)
Enriched Bleached Flour
Enriched Bleached Wheat Flour
Enriched Flour
Farina
Farina Graham
Farro Filler Flour (normally this is wheat)
Fu (dried wheat gluten)
Germ
Graham Flour
Granary Flour Groats (barley, wheat)
Hard Wheat
Heeng Hing Hordeum Vulgare Extract
Hydrolyzed Wheat Gluten
Hydrolyzed Wheat Protein
Hydrolyzed Wheat Protein Pg-Propyl Silanetriol
Hydrolyzed Wheat Starch
Hydroxypropyltrimonium
Hydrolyzed Wheat Protein
Kamut (Pasta wheat)
Kecap Manis (Soy Sauce)
Ketjap Manis (Soy Sauce)
Kluski Pasta
Maida (Indian wheat flour)
Malt Malted Barley Flour
Malted Milk
Malt Extract Malt Syrup
Malt Flavoring
Malt Vinegar
Macha Wheat (Triticum aestivum)
Matza
Matzah
Matzo
Matzo Semolina
Meringue
Meripro 711
Mir Nishasta
Oriental Wheat (Triticum turanicum)
Orzo Pasta
Pasta
Pearl Barley
Persian Wheat (Triticum carthlicum)
Perungayam
Poulard Wheat (Triticum turgidum)
Polish Wheat (Triticum polonicum)
Rice Malt (if barley or Koji are used)
Roux
Rusk
Rye
Seitan
Semolina
Semolina Triticum
Shot Wheat (Triticum aestivum)
Small Spelt Spirits (Specific Types)
Spelt (Triticum spelta)
Sprouted Wheat or Barley
Stearyldimoniumhydroxypropyl Hydrolyzed Wheat Protein
Strong Flour Suet in Packets
Tabbouleh
Tabouli
Teriyaki Sauce
Timopheevi Wheat (Triticum timopheevii)
Triticale X triticosecale
Triticum Vulgare (Wheat) Flour Lipids
Triticum Vulgare (Wheat) Germ Extract
Triticum Vulgare (Wheat) Germ Oil
Udon (wheat noodles)
Unbleached Flour
Vavilovi Wheat (Triticum aestivum)
Vital Wheat Gluten
Wheat, Abyssinian Hard triticum durum
Wheat amino acids
Wheat Bran Extract
Wheat, Bulgur
Wheat Durum Triticum
Wheat Germ Extract
Wheat Germ Glycerides
Wheat Germ Oil
Wheat Germamidopropyldimonium Hydroxypropyl Hydrolyzed Wheat Protein
Wheat Grass (can contain seeds)
Wheat Nuts
Wheat Protein
Wheat Triticum aestivum
Wheat Triticum Monococcum
Wheat (Triticum Vulgare) Bran Extract
Whole-Meal Flour
Wild Einkorn (Triticum boeotictim)
Wild Emmer (Triticum dicoccoides)

The following items may or may not contain gluten depending on where and how they are made, and it is sometimes necessary to check with the manufacturer to find out:
Artificial Color(4), Baking Powder (4) ,Caramel Color (1) (3), Caramel Flavoring (1) (3), Clarifying Agents (4), Coloring (4), Dextrins (1) (7), Dextrimaltose (1) (7), Dry Roasted Nuts (4), Emulsifiers (4), enzymes (4), Fat Replacer (4), Flavoring (6), Food Starch (1) (4), Food Starch Modified (1) (4),  Glucose Syrup (4), Gravy Cubes (4), Ground Spices (4), HPP4 HVP (4), Hydrolyzed Plant Protein (4), Hydrolyzed Protein (4), Hydrolyzed Vegetable Protein (4), Hydrogenated Starch Hydrolysate (4), Hydroxypropylated Starch (4), Maltose (4), Miso (4), Mixed Tocopherols (4), Modified Food Starch (1) (4), Modified Starch (1) (4), Natural Flavoring (6), Natural Flavors (6), Natural Juices (4), Non-dairy Creamer (4), Pregelatinized Starch (4), Protein Hydrolysates (4), Seafood Analogs (4), Seasonings (4), Sirimi (4), Smoke Flavoring (4), Soba Noodles (4), Soy Sauce (4), Soy Sauce Solids (4), Sphingolipids (4), Stabilizers (4), Starch (1) (4), Stock Cubes (4), Suet (4), Tocopherols (4), Vegetable Broth (4), Vegetable Gum (4), Vegetable Protein (4), Vegetable Starch (4), Vitamins (4), Wheat Starch (5),

​

Additional details:
 

1) If made in America, this is likely to be gluten-free.
3) The problem with caramel color is it may or may not contain gluten depending on how it is manufactured. In the USA caramel color must conform with the FDA standard  of identity from 21CFR CH.1. This statute says: the color additive caramel is the dark-brown liquid or solid material resulting from the carefully      controlled heat treatment of the following food-grade carbohydrates: Dextrose (corn sugar), invert sugar, lactose (milk sugar), malt syrup (usually from barley malt), molasses (from cane), starch hydrolysates and fractions thereof (can include wheat), sucrose (cane or beet). Also, acids, alkalis and salts are listed as additives which may be employed to assist the caramelization process.

4) Can utilize a gluten-containing grain or by-product in the manufacturing process, or as an ingredient.

5) Most celiac organizations in the USA and Canada do not believe that wheat starch is safe for celiacs. In Europe, however, Codex Alimentarius Quality wheat starch is considered acceptable in the celiac diet by most doctors and celiac organizations. This is a higher quality of wheat starch than is generally available in the USA or Canada.

6) According to 21 C.F.R. S 101,22(a)(3): [t]he terns natural flavor or natural flavoring means the essential oil, oleoresin, essence or extractive, protein hydrolysate, distillate, or any product of roasting, heating or enzymolysis, which contains the flavoring constituents derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, seafood, poultry, eggs, dairy products, or fermentation products thereof. Whose significant functionin food is flavoring rather than nutritional.
7) Dextrin is an incompletely hydrolyzed starch. It is prepared by dry heating corn, waxy maize, waxy milo, potato, arrowroot, WHEAT, rice, tapioca, or sago starches, or by dry heating the starches after: (1) Treatment with safe and suitable alkalis, acids, or pH control agents and (2) drying the acid or alkali treated starch. (1) Therefore, unless you know the source, you must avoid dextrin.”



Sources Cited:



[1] http://www.rodale.com/gluten-free-food
[2] http://www.huffingtonpost.com/2011/08/23/gluten-free-food-fda_n_930898.html
[3] http://www.huffingtonpost.com/2011/08/23/gluten-free-food-fda_n_930898.html
[4] http://www.triumphdining.com/blog/2010/09/03/gluten-free-standards-not-standard/
[5] http://www.celiac.com/categories/Gluten%252dFree/
[6] http://celiacdisease.about.com/od/glutenfreefoodshoppin1/a/Canadas-Gluten-Label-Rules.htm
[7] http://www.glutenfreedietitian.com/newsletter/european-union-gluten-free-regulation/
[8] http://celiacdisease.about.com/od/copingwiththediet/a/What-Is-Gluten-Free-Foods-With-Gluten-Free-Label-Still-May-Contain-Some-Gluten.htm
[9] http://www.gfco.org/
[10] http://www.celiac.com/articles/182/1/Unsafe-Gluten-Free-Food-List-Unsafe-Ingredients/Page1.html, Included at bottom
[11] http://www.1in133.org/you/
[12] http://www.celiac.com/articles/182/1/Unsafe-Gluten-Free-Food-List-Unsafe-Ingredients/Page1.html
[13] http://www.celiac.com/articles/182/1/Unsafe-Gluten-Free-Food-List-Unsafe-Ingredients/Page1.html

​
Joseph Millman is currently attending Swarthmore College as a member of the class of 2017. 

Is a Gluten-Free Label Trustworthy?