Celiac Disease vs Food Allergies

Sources of Gluten

What Does “Gluten Free” Mean?

Is Gluten an “Allergen” Under FALCPA?

Unlike many other countries, the United States does NOT require the disclosure of all gluten containing grains. At this time, the United States Food Allergen Labeling Consumer Protection Act only requires Wheat to be declared in food labels. No requirements exist for labeling barley or rye.

A note about malt and gluten free labeling rules. Any grain may go through the malting process. In the United States, if the word “malt” exists in an ingredient list, without any additional disclaimers, the FDA says this is malt from barley. If the ingredient list says malted corn, malted sorghum, etc. then the malt in question IS gluten free.

Does the FDA Require Testing Before Using a Gluten Free Claim?

The following statement is found in the United States Guidance for Industry Gluten-Free Labeling of Foods. (PDF) “The (FALCPA) rule DOES NOT require you to test for the presence of gluten in your starting ingredients or finished foods labeled “gluten-free.” (emphasis mine)

“We encourage you to use effective measures to ensure that any foods labeled as “gluten-free” comply with our requirements; such measures may include: •1) testing the ingredients to determine their gluten content; 2) requesting certificates of gluten analysis from ingredient suppliers; or 3) participating in a third-party gluten-free certification program.”

Is Gluten Free Certification Required?

What are the Requirements for Labeling Gluten And Food Allergens in the United States?

Allergens Must Be Plainly Stated in the Ingredient list

Food allergens must be labeled in plain English. For example, “wheat is a group of wild and domesticated grasses of the genus Triticum.” (Wikipedia) Food producers can’t simply use the term “Triticum’ on a food label. They must use the word wheat.

Sub Ingredients Must Be Listed

What are sub ingredients? They are ingredients within a larger ingredient. For example, wheat is often an ingredient in soy sauce. If a packaged food contains soy sauce, it must list all the ingredients used to create that soy sauce. Sub ingredients are usually listed within parentheses of a larger ingredient, although not always.

In the example above, the Enriched Wheat Flour includes the added vitamins in brackets.

Do Allergens Need to Be Bolded in an Ingredient List?

No, gluten free and food allergen labeling rules do NOT require allergens to be printed in bold lettering. The sole requirement for food allergen labeling is that that all ingredients must be listed in either the ingredients list or Contains statement. If a Contains statement is used, all major allergens must be declared even if declared in the ingredients list. See more about this below.

A Note about “Contains” Statements

“Contains” Statements Are Not Required

Some companies may include a CONTAINS statement at the end of an ingredient list to highlight food allergens in their product. This is often very helpful. However, is it not required. Do not assume that just because wheat is not highlighted in a contains statement that the product is gluten free.

The One Important Caveat of Contains Statements

If a company chooses to include a “Contains” statement at the end of the ingredient list, they must list ALL food allergens contained in the product.

For example, if a chocolate bar contains tree nuts and milk, and they choose to use a contains statement, both the milk and the tree nuts have to be included in the “Contains” statement. If they only included the milk in the contains statement, but left out the tree nuts, that product would be considered to be misbranded and should be reported to the FDA.

What about “May Contain” Statements?

“May Contains” statements are neither required nor regulated by the FDA. In fact, they tend to cause more confusion than comfort. Gluten Free Watchdog has tested multiple products with “may contain” statements and many have tested under 20 ppm.

Can something be labeled gluten free and contain wheat?

What I am about to say is very important for those who have a wheat allergy, NOT Celiac Disease. Per United States Gluten Free and Food Allergen Labeling Rules, products labeled gluten free CAN contain sources of highly refined wheat starch.

Companies outside the United States (mostly Europe) have used gluten free wheat starch in their flours and baked goods for many years. An example is the popular Caputo Fioreglut flour blend.

Some companies in the United States are now integrating some of these same practices. These brands include Schar [Croissants and Pain au Chocolat], King Arthur Baking [Gluten Free Pizza Flour and Gluten Free Bread Flour] and Capello’s [New Dinner Rolls and Pizzas.]

Gluten Free “Wheat” sources

• Gluten Free Wheat Starch
  • Gluten free wheat starch is made by essentially “washing” the gluten containing protein from the grain and leaving the starch behind.
• Glucose Syrup
  • “Glucose syrup is a concentrated sugar solution made by breaking down starches (usually from corn, wheat, or potatoes) into smaller sugar molecules. This process creates a thick, sweet syrup. ” Quote from Pastry Class
  • “The production of glucose syrup involves treating starches with water and enzymes. Enzymes are natural substances that speed up chemical reactions. In this case, they break down the long chains of starch into smaller sugar units, resulting in the syrupy liquid.” Quote from Pastry Class
  • “Glucose syrup is considered safe even when derived from wheat, barley or rye. That is because the process used to produce glucose syrup renders the starting material to contain less than 20 parts per million of gluten.” National Celiac Assoc.
• Wheat Grass
  • From the National Celiac Association – Wheat grass or barley grass (and their juices) are the young (gluten-free) grasses of the wheat or barley plant. They are different from the wheat grain or barley grain that grow on the same plant and DO contain gluten.”
  • “The Food and Drug Administration will allow wheat or barley grass as an ingredient in a labeled gluten-free product, including supplements, as long as the final product contains <20 parts per million (ppm) gluten”

FDA Labeling Requirements of Wheat in Gluten Free Products

If a packaged food that is labeled gluten free contains wheat starch, it is required to include an asterisk and the following statement: “The wheat has been processed to allow this food to meet the Food and Drug Administration requirements for gluten-free foods“. Read the quote below from the FDA regulations on gluten free labeling of food to learn more.

A food that bears the term “wheat” in the ingredient list or in a separate “Contains wheat” statement in its labeling, as required by 21 U.S.C. 343(w)(1)(A), and also bears the claim “gluten-free” or a claim identified in paragraph (b)(2) of this section will be deemed misbranded unless the word “wheat” in the ingredient list or in the “Contains wheat” statement is followed immediately by an asterisk (or other symbol) that refers to another asterisk (or other symbol) in close proximity to the ingredient statement that immediately precedes the following: “The wheat has been processed to allow this food to meet the Food and Drug Administration (FDA) requirements for gluten-free foods.”

Wheat Protein vs Starch

Wheat grains contains protein and starch. People with Celiac Disease experience an autoimmune reaction to the PROTEIN in wheat, not the starch. This is why highly refined wheat starch can be labeled gluten free.

This Family’s Story Highlights the Need for Better Gluten Free and Food Allergen Labeling Rules

Hi, I’ve followed you for years. My son, he’s almost 9 now, but was diagnosed with an anaphylactic wheat allergy at 10 months. Over those years we’ve had one exposure at day care and one at a restaurant. Last night though, was the first time we had an issue at home that resulted in a hospital visit (he’s good now).

I’m reaching out to you because you’re more active / knowledgeable in the gluten space than I am. What happened was we made enchiladas and the sauce (La Preferida red Chile enchilada sauce) doesn’t have the warning ‘Contains: Wheat’ but looking closer at the ingredients it contains ‘Wheat Flour’.

I’ve used this sauce before, but, I must’ve had the organic variant which is certified GF. Tough lesson but I’m trying to understand how something can contain ‘Wheat Flour’ and not have the warning.

What Else Do You Need To Know About Eating a Gluten Free Diet?

I do want to make sure to say this – IT DOES GET EASIER. If you recently received a Celiac Disease diagnosis, this can be very overwhelming. Trust me when I say you will find your new normal, and it will be all right.

In addition, many people on the internet make a living by making you scared and afraid. Be careful about which voices you listen to. I trust these USA bloggers to give factual info.

We can control what happens in our own kitchens. When we eat out, we need to ask more questions. (Luckily, I have a handy guide for that!) If you live in Michigan, check out my list of restaurants with great gluten free options that I recommend. It includes a sub list of Michigan restaurants that maintain a 100% gluten free kitchen.

Have any additional questions? Drop me a message in the comment section below! Did you find this post to be incredibly helpful? Please share it with others who need it.

Sincerely,

Margaret Clegg aka MI Gluten Free Gal

The post United States Gluten Free and Food Allergen Labeling Rules appeared first on MI Gluten Free Gal.

A Very Scary Halloween

Halloween. When you live with a food allergy or food sensitivity, what frightens you more than costumes is candy. Does the candy in question contain your allergen? Did manufacturers produce this sweet on a shared line with an allergen? Does this candy contain undeclared gluten, which is found in wheat, barley, malt, and rye? What recently scares me most is faulty info based on the NIMA gluten sensor.

Halloween was unique for me in 2017. My husband and I drove a 20 foot Uhaul from Michigan to South Dakota, with our car in tow. (Confession – He drove. I “navigated.”) We chose to spend our vacation helping our friends move all their belongings 800+ miles away, due to a new job. No costumes for us. No decorated van passing out safe treats from our Teal Pumpkin Project – inspired stash of goodies. Therefore, I vicariously enjoyed Halloween through social media. From the comfort of the Uhaul (oxymoron?), I perused Instagram.

What is a NIMA Partners Gluten Sensor?

We were somewhere in the plains of Minnesota, between Rochester and Sioux Falls, when I noticed an Instagram post of a 100 Grand candy bar. What’s a 100 Grand Bar? Imagine a Nestle Crunch with a caramel layer inside. The post showed a 100 Grand being tested with a NIMA.

What’s NIMA?  It’s a portable electronic device that tests for gluten in food. How does it do this? In simple terms, you put in a pea-sized amount of the food you want to test in a capsule. The capsule contains a solution and you place the capsule in the triangular device, and it uses testing methods to detect the presence of gluten.

Not Everything You See Online is Accurate

So, what caught my eye was that results on the NIMA. The Instagram post showed a NIMA with a smiley face. This in theory means that the product is safe to eat. The person posting only had the small miniature 100 Grand Bar, but not the larger bag from which it came. While we plodded along I-90, I did a Google search for a 100 Grand Bar.

I was concerned because all the sites I saw (including Amazon)  stated that the bar contained crisped rice, which are made with “rice flour, sugar, BARLEY MALT, and salt.” For those that may not know, barley malt contains gluten. Therefore, the device should NOT have resulted in a “smiley face.”

I wondered “Did Nestle change their recipe?” My husband, who is completely a saint, agreed to pull off the freeway in Fairmont, Minnesota and let me stop at a grocery store to check. So I wandered into the store, and asked one of the incredibly helpful staff to help me locate one of these 100 Grand bars. Here’s what I found.

Nestle 100 Grand Bars Contain Barley Malt

Yep, barley malt. So I private messaged the owner of the Instagram account that posted the NIMA result. I shared this information. They updated their comments on their account, their blog post, and ultimately removed the image. (Why remove it? People were solely looking at the image of the “smiley faced NIMA” with the candy in question, and not the warning.)

But the question remained. How did this happen? Like any other technology, there can be limitations of use. Below is how NIMA responded (in 2017) as to how this could happen. (Names of other Twitter users blocked out to protect privacy.)

NIMA Sensors Cannot Test for the Presence of Barley Malt

So, there’s our answer. NIMA does not detect barley malt. So in theory, Kellogg’s Rice Krispies will come back with a smiley face.  This also means something with hydrolyzed wheat, such as soy sauce, could come back as being “safe.” This is something that definitely doesn’t bring a smile to MY face. 

What Other Limitations Do NIMA Testing Devices Have?

After a quick visit to the NIMA Partners website, their “gluten manual” states the following limitations

“NIMA Partners has not been validated on medication, cosmetics or non food items.” Therefore, be wary if you see an Instagram influencer use their NIMA to test medications, whether prescription or over the counter. Other NIMA limitations include:

Other Red Flags

In addition, their manual gives additional advice on how to test foods that are thick/ dense, dry/ powdery, and brightly colored. Foods in these categories may return inaccurate results. “Bright foods can interfere with the sensor’s ability to read the result. These foods should also be mixed with water to dilute the coloring.” This includes red foods, such as pizza sauce or marinara. 

Three Things to Remember

1. Ingredient Lists Aren’t Required on Mini Candy Bars

Here’s where the Instagram account that posted the original picture faltered. That person ONLY had one of the 100 Grand miniature candy bars. He / she did not have the larger bag from whence it came, nor did the mini candy bar have a complete ingredient list.

Mini bars, especially those passed out on holidays such has Halloween, do not always have a complete list of ingredients on the wrapper. If you question a food item, and the ingredients are not on the packaging, try to look it up online. ALSO – make sure to read comments on posts as well. Pictures and ratings can be deceptive.

2. Barley & Rye are Not Allergens Under FALCPA

The person who originally posted the image went by the “allergen warning” on the wrapper. The wrapper did not list barley as a potential allergen. Here’s the thing though. It doesn’t have to. Barley, as well as rye, are not one of the Top 9 allergens that must be declared under the FALCPA guidelines. (FALCPA = Food Allergen Labeling and Consumer Protection Act) The Top 9 include wheat, fish, shellfish, eggs, dairy, peanuts, tree nuts, soy and sesame. The person that originally posted the 100 Grand bar on Instagram relied on the fact that the allergen warning did NOT list wheat. They falsely concluded it therefore must be free of gluten. 

3. You are Smarter Than Technology

NIMA is a tool one can use to help make decisions about what we eat. However, it is nothing more than that. NIMA is not without its limitations. Results can have errors because a sample is too small, too large, or even because it is red. From above we can see that it can declare a food as “safe” when it is not. Cases have also shown that products can result in an “frown” even when a product is actually gluten-free. Read my thoughts on a restaurant study performed via NIMA testing, for more info. 

My Final Thoughts About the NIMA Partners Gluten Sensor

So here is where I voice my opinion. NIMA has become a controversial issue in the Celiac Disease community.  I try not to share my own opinion about the NIMA too often. Instead I attempt to share facts of how how it performs, and allow you to make your own educated decision. However, based on that evidence, I am not a fan of the device. I fear it leads to more anxiety about eating gluten free, not less. 

Safe Gluten Free Halloween Candy

Many sites exist that offer gluten free Halloween Candy lists. A few examples include- 

• Celiac Mama’s Gluten Free Halloween Candy List (updated Sept 2022)
• GF Jules Gluten Free Halloween Candy List
• Beyond Celiac Gluten Free Halloween Candy List

Do you own a NIMA? What do test with it? What holiday candies do you trust to be gluten-free?

The post NIMA Gluten Sensor and a Grand Halloween Mistake appeared first on MI Gluten Free Gal.