September 2017

Labeling of Gluten-Free Foods

When shopping for packaged foods it is necessary to read labels carefully to determine if an item is
gluten-free.

Several types of information concerning the product’s gluten-free status can be found on the food
packaging. Examples include:
1) A certification mark (“logo”) indicating that a product has been certified gluten-free by GIG’s
GFCO program, as shown here:
2) Claims that a product is “gluten-free”.
3) Ingredient lists.
4) Voluntary advisory statements.

1) If an item carries the GFCO logo, it has met the standard of containing 10 ppm gluten or less in
both raw materials and finished goods. Every product is manufactured in a facility that
undergoes regular audits by GFCO’s trained auditors to make sure that the product’s
ingredients and the company’s processes will result in a gluten-free finished product. Any
product certified by GFCO is safe for those with celiac disease or any other gluten-related
disorder.

2) If an item is not certified gluten-free but is labeled “gluten-free” (or “no gluten”, “without gluten”
or “free of gluten”) and is an FDA regulated product *, it is required to have complied with the
FDA regulation for gluten-free labeling, and must contain less than 20 ppm gluten.

3) If the product is neither certified nor labeled gluten-free, it is necessary to read the ingredient
list.

 If any of the following are on an ingredient list, the item is not gluten-free: wheat, rye,
barley, oats (unless the oats are certified gluten-free1), malt2, and brewer’s yeast.

For additional details on reading ingredient lists, see the GIG educational bulletin “Label
Reading” (https://www.gluten.org/wp-content/uploads/2016/01/Label-reading-magazine.pdf.)

4) In the interest of transparency, some manufacturers use voluntary advisory statements to let
consumers know that allergens are handled in the same facility where an allergen- or gluten-
free product is made, and they can do this through the use of statements like “may contain
wheat.” Voluntary statements are not required or regulated by the FDA, other than the general
FDA requirement that all labeling be truthful.

31214 124th Ave SE Auburn, WA 98092 | P: (253) 833-6655 | F: (253) 833-6675 | www.gluten.org
Gluten Intolerance Group of North America® is a 501c3 nonprofit Washington State corporation. Tax ID 91-1458226.
HOW TO INTERPRET VOLUNTARY ADVISORY STATEMENTS AND ALLERGEN
STATEMENTS ON GFCO CERTIFIED PRODUCTS

 “May Contain Wheat”: This statement may be used by companies that handle wheat in
their facility, but keep it segregated from gluten-free production. Plants that produce GFCO
certified products and also handle wheat take additional precautions to ensure that all
ingredients and the certified finished product contain <10 ppm gluten.

 “Processed on Shared Equipment with Wheat”: Some GFCO certified products are
made in facilities that also manufacture products that contain wheat, but these facilities have
very strict controls, cleaning protocols, and equipment and product testing requirements to
ensure that gluten remains below 10 ppm in their gluten-free finished products.

 “Contains Wheat”: Should only be used if wheat has been intentionally added to a
product. On a GFCO-certified product this would indicate that the product contains wheat
starch, wheat grass, or some other gluten-free component of wheat. If a product is GFCO
certified you can feel safe in knowing that the product contains less than 10 ppm gluten,
which is twice as strict as the FDA labeling requirement for gluten-free labeled products. In
addition, a food whose labeling includes the term “wheat” in the ingredient list or in a
separate “Contains wheat” statement as required by a section of the Federal Food, Drug,
and Cosmetic Act (the FD&C Act) and also bears the claim “gluten-free” will be deemed to
be misbranded by the FDA unless its labeling also bears additional language clarifying that
the wheat has been processed to allow the food to meet FDA requirements for a “gluten-
free” claim.

There have been some instances of manufacturers incorrectly using a “Contains” statement in
place of a “May Contain” or “Shared Equipment” voluntary statement. If you see any labeling that
makes you question the certification status of a product, contact GIG customer service at
customerservice@gluten.org or (253) 833-6655.

1 Oats are inherently gluten-free,however since they are typically grown and processed in close proximity to wheat, they can easily
become cross-contaminated with gluten. However, some growers/manufacturers are now selling certified gluten-free oats.
2 ”Malt” includes ingredients using malt, such as malt vinegar and barley malt extract. However if you see the word “malt” used in a
compound word such as “maltodextrin,” this does not indicate the presence of malt and the product is safe to consume.

*FDA AND USDA

The FDA gluten-free labeling regulation applies to the majority of packaged food products, those regulated by the FDA. However,
products regulated by the USDA are not required to comply with FALCPA. The USDA regulates meat, poultry and egg products, and
mixed food products that generally contain more than three percent raw meat or two percent or more cooked meat or poultry (e.g.
soups, chilis, frozen entrees).Even though USDA products are not required to comply with FALCPA, it’s estimated that 80 to 90 % of
these products voluntarily comply.

31214 124th Ave SE Auburn, WA 98092 | P: (253) 833-6655 | F: (253) 833-6675 | www.gluten.org
Gluten Intolerance Group of North America® is a 501c3 nonprofit Washington State corporation. Tax ID 91-1458226.