Gluten free food has been in the spotlight over the past few weeks. With the popularity and health associations attached to gluten free food consumption, any wonder food manufacturing sales teams want to get on board. In this post, we drill down on what producing gluten free food really means for food manufacturers.
To get a good understanding of gluten free, it is first important to know the gluten story. Gluten is a protein found in foods like wheat (including spelt), rye, barley and oats. Gluten is an issue for people who have coeliac / celiac disease, where by, their immune system reacts abnormally to gluten. This reaction causes small bowel damage resulting in inflammation, gastrointestinal symptoms and nutrient absorption issues.
Coeliac disease affects 1% of healthy, average Americans (about 3 million people), 1 in 70 Australians and approximately 1 in 100 people in the UK. People may also have a wheat allergy.
Gluten free foods can be categorised into two (2) key groups:
Gluten free food labelling is the most common method legislated for defining what food is and what food is not considered to be gluten free. There is differing food laws internationally. It is important to know the laws not only in your country of manufacture, but also in any countries that you export to.
Codex – the International CODEX standard, defines ‘foods containing less than 20ppm of gluten’ as safe and suitable for a coeliac diet based on the recommendations of their consultant Gastroenterologists.
USA – Gluten free food labelling requirements can be found in Title 21, Chapter I, Subchapter B, part 101, Subpart F, §101.91 Gluten-free labeling of food.
The FDA defines “gluten-free” as meaning that the food either is inherently gluten free; or does not contain an ingredient that is: 1) a gluten-containing grain (e.g., spelt wheat); 2) derived from a gluten-containing grain that has not been processed to remove gluten (e.g., wheat flour); or 3) derived from a gluten-containing grain that has been processed to remove gluten (e.g., wheat starch), if the use of that ingredient results in the presence of 20 parts per million (ppm) or more gluten in the food. Also, any unavoidable presence of gluten in the food must be less than 20 ppm.
The USFDA have a helpful fact sheet on Gluten free food labelling which you can access here.
Australia – Gluten-free food labelling requirements can be found in Standard 1.2.7 – Nutritional, health and related claims. Foods labelled as gluten free must not contain detectable gluten; or oats or oat products; or cereals containing *gluten that have been malted, or products of such cereals.
European Union – Regulation (EU) No 828/2014 outlines the rules for using gluten free and very low gluten statements. The statement ‘gluten-free’ may only be made where the food as sold to the final consumer contains no more than 20 mg/kg of gluten. There are also additional requirements for foods containing oats.
There are various international positions, both scientific and legislative, on the inclusion of oats under the gluten free status. To find out if this effects your country of manufacture or export please refer to the legislation links provided above.
If you would like to have any of your food products or manufacturing sites certified as gluten free, there are various 3rd party schemes on offer. Like any of the GFSI recognised schemes, manufacturing processes, product information are audited against a set criteria. To find Gluten free certification programs in your country of manufacture, just google “Gluten free food certification”.
Obtaining validation information is simple considering the documented legislation discussed previously. Legislation should be your primary source of theoretical validation for foods labelled as gluten free. There are also risk assessments published by different governments that can be accessed here and here.
All gluten free food claims should be regularly verified. This means, you need to be checking that your finished product, raw materials and manufacturing environment maintains the allowable limits. Cross contamination can be a major issue in manufacturing sites that handle both gluten containing and gluten free food. Your allergen management program should include control measures to mitigate this risk.
Is your food business capable of manufacturing gluten free food? Do you have both gluten containing and gluten free food products in your business? Share your best practice strategies with the HACCP Mentor community by leaving a comment below.