New Gluten Free Labeling

Earlier this month,  U.S. Food and Drug Administration (FDA) finalized a standard definition of “gluten-free”.

So what does it mean, exactly, when a food product is labeled as ‘gluten-free” and what is the gluten free labeling requirements?  According to the National Foundation of Celiac Awareness (NFCA) ….

New Gluten Free Labeling

FDA Gluten-Free Labeling Rule

Under the new rule, if a food carries a gluten-free claim, it either:

  • Inherently does not contain gluten (i.e. a bag of raw carrots or bottle water)

OR meets the following criteria:

  • Does not contain an ingredient that is a whole, gluten-containing grain (i.e. wheat, barely, rye or crossbred hybrids of these grains)
  • Does not contain an ingredient that is derived from a gluten-containing grain and has not been processed to remove gluten (i.e. wheat flour)
  • May contain an ingredient that is derived from a gluten-containing grain that has been processed to remove gluten (i.e. wheat starch) as long as the food product contains less than 20 parts per million (ppm) of gluten


  • Any unavoidable gluten in the food due to cross-contact (commonly referred to as cross-contamination by the gluten-free community) or migration of gluten from packaging materials is less than 20 ppm gluten

The NFCA has put together a Follow Up Fact Sheet which I found to be very helpful.

Some of the interesting fact addressed in this report is as follows:

Q: Under the FDA’s final gluten-free labeling rule, oats are NOT considered a gluten-containing grain. Does this mean that oats are safe to consume on a gluten-free diet?

Q: Why is wheat starch allowed in products that are labeled gluten-free?

Q: It’s unclear to me whether I should still steer clear of products containing malt and hydrolyzed wheat protein. What does the FDA’s gluten-free labeling rule say about these ingredients? For example, can I eat soy sauce?

Q: While I understand that less than 20 ppm gluten is less than a crumb and, therefore, not visible to the eye, I still have several questions about this amount. Can you…

1.Help put this into context for me?
2.Clarify whether I should be concerned with cumulated gluten intake?
3.Explain how many servings of less than 20 ppm can a person with celiac disease safely consume in one day?

Q: What vinegar, if any, is safe to eat on a gluten-free diet?

Q: I know that you recommend purchasing naturally gluten-free grains and flours and grain and flour-based products that are labeled gluten-free. Are there other dry food products that might fall into this category? For example, what about seeds, beans and nuts?

Q: Does this ruling mean that the products labeled gluten-free now aren’t under 20 ppm?

Q: I know that we have to start somewhere, but I don’t understand the significance of the rule if it’s not mandatory and manufacturers aren’t required to test. How does this rule impact people on a medically necessary gluten-free diet as opposed to individuals “riding out the fad”?

Q: If a product is now labeled gluten-free but its label says that it is “processed in a facility that also processes
wheat,” is this product really gluten-free?

Download the entire document


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