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Understanding gluten-free food requirements

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.

The Gluten Background

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, whereby, 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.

Common gluten-free foods

Gluten-free foods can be categorised into two (2) key groups:

  • Naturally gluten-free foods including fresh fruit and vegetables, fresh meats, eggs, nuts and legumes, milk, fats and oils, gluten-free grains (rice, corn).
  • Products that are gluten free by ingredient – this is when all the compound ingredients that make up your finished product are considered to be naturally gluten-free foods.

Food law

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 are different food laws internationally. It is important to know the laws not only in your country of manufacture but also in any country 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 has 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 UnionRegulation (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.

The problem with 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.

3rd Party Certification standards

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”.

Validating your gluten-free food status

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.

Verification activities

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.

Gluten Awareness Training

If your food business manufactures or handles gluten-free food or maintains 3rd party Gluten-Free Certification, you can access Gluten Awareness Training by clicking here.

Share your thoughts

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.

8 thoughts on “Understanding gluten-free food requirements”

  1. As a long time sufferer of Celiac disease I fall into the “super sensitive” category. For me and people like me, 20 ppm isn’t nearly good enough and I react to all foods that are between 10 and 20 ppm. and I react to many foods that are between 3 and 10 ppm depending on how much is eaten and how often. The HACCP guidelines do not guarantee that no reaction will occur as I have spoken with dozens of manufacturers of foods that I react to who use this protocol to declare gluten free status. What Celiac disease sufferers and manufacturers alike need to realize is that these trace levels of gluten are still doing significant damage to villi and causing body wide inflammation even if it’s sub-clinical and causes no overt symptoms. I long for the day when manufacturers are forced by law to declare on the label the presence of gluten or any other allergen within their facilities. Cross-contamination is unavoidable within a facility as gluten is sticky and light and can float large distances once airborne and is impossible to clean with 100% effectiveness from nooks and crannies of machines. Gluten free should only be declared when there is no gluten in the facility where the item is produced and packaged, period.

    1. Amanda Evans-Lara

      Thanks for sharing your experience Dan. I totally agree with you that gluten-free should only be declared when there is no gluten in the facility where the item is produced and packaged.

  2. Recently many of our customers requested to clarify if our products are Gluten-Free or not, so I take many samples from many products families which are not included any gluten to check gluten traces in the products. All analysis showing that the products contents of gluten traces were less than 20ppm “According to FDA It considered to be gluten free products” but is it enough to announce to our customers that our products are Gluten Free? absolutely we can’t. Gluten Free statement is not only a few words , It’s a structured program based on gluten contamination risk assessment (Determine the hazards, activities and resources that might contain gluten or can be a source for contamination by gluten) and risk management (corrective actions, verification plan and validation procedures to control the gluten contamination hazard). The program should focus on many factors starting by people” Employees”, factory activities and products, layout, controlling incoming raw materials, corrective and preventive actions against gluten contamination, robust documentation system, Sample analysis plan and procedures through production steps till the finished products, conduct third part audit and good communication with our customers. So It’s not only a Gluten Free statement but It a structured program to satisfy your customers and make your product safe from gluten contamination.
    Thank You
    Ahmed Hussein

  3. Actually, oats do not contain the protein gluten, they contain avenin. Avenin does not cause the inflammation that gluten does. Companies have started using methods which separate oat grains from the contaminating wheat, rye, or barley grains so they can guarantee a gluten-free oat product.

  4. The problem with 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.
    Do you have any good reference about oats as gluten free? Appreciate your help very much!

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