Label reading for gluten-free consumers has become easier in recent years. Thanks to the USA FDA gluten-free labeling regulation, passed in 2013, when a product is labeled “gluten-free” this means it should comply with the established definition of containing less than 20 ppm gluten.
Another component of food labeling, however, remains confusing: the “allergen advisory statement.” Allergen advisory statements are statements such as “made in a facility which processes wheat.” Allergen advisory statements are voluntary and are not defined by any USA federal regulation (although the FDA does state that these statements must be “truthful and not misleading”).
How should a gluten-free consumer interpret voluntary allergen advisory statements? Do these statements provide information which is relevant to the gluten-free status of a product?
In order to begin to address this question, researchers in a recent study compiled data on 101 products which had previously been analyzed for gluten content. (1) Labels were reviewed for allergen statements for wheat, gluten, or both. The products reviewed were not labeled gluten-free, but appeared to be gluten-free based on ingredient lists.
Eighty-seven of the 101 products tested did not include an allergen advisory statement. The other 14 products did include one. Among the products which did not include an advisory statement, 5% (4 products) tested at or above 20 ppm of gluten. (15 % of the products contained gluten at or above 5 ppm.) Among the 14 products which did contain an advisory statement, only one (7%) contained gluten at or above 20 ppm. Products containing quantifiable gluten (5 ppm to > 84 ppm) included spices, lentils, oats, seasoning mixes and a snack food. Only the snack food included an allergen advisory statement for wheat.
The researchers found that in this database of products, the presence of an allergen advisory statement for wheat or gluten (on products not labeled gluten-free but which appeared to be gluten-free based on ingredients) was not a useful predictor of gluten content. For example, one brand of a single ingredient product which did have precautionary labeling for wheat tested below 5 ppm gluten. On the other hand, another brand of this same item without this type of labeling tested above 84 ppm of gluten.
As noted by the researchers, there are limitations to this study, including its small size, and more work is needed on this topic. In the meanwhile, however, this research supports GIG’s long-standing recommendation that allergen advisory statements not be utilized in determining a food’s gluten-free status. The authors of this study also recommend that these types of allergen advisory statements be regulated and standardized so that they can be helpful to consumers.
*Regulation applies to USA FDA-regulated products, which constitute the vast majority of packaged food products.
**The FALCPA requirement that the presence of allergens be clearly labeled applies only to ingredients, and does not apply to presence which may be due to cross-contamination. On the other hand, the USA FDA gluten-free labeling regulation does take into account cross-contamination: i.e. a product labeled “gluten-free” must contain less than 20 ppm gluten from any source: ingredients or cross-contamination.
1. Thompson T, Lyons TB, Jones A. Allergen advisory statements for wheat: do they help US consumers with celiac disease make safe food choices? Eur J Clin Nutr. 2016 Sep 14. doi: 10.1038/ejcn.2016.155. [Epub ahead of print]