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New Fda Gluten Free Label Law Questions
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Hi Everyone,

I had asked a couple of questions regarding the new US FDA Labeling Laws in another post, and one of the wonderful moderators mentioned that a lot of people have questions about it, and suggested I should start a new topic to open the subject up for discussion.

My questions were:

When will the new law for gluten free food labeling go in to effect?

What exactly will the new law mean as far as testing for gluten in the finished product goes?

Will manufacturers have to disclose if the facility or equipment is shared under the new law? (From what I understand, this is voluntary right now)

From what I could find online, it looks like the "Rule" (they are not calling it a law), went in to effect in August of 2013, but they gave manufacturers a year to meet the deadline for compliance, which is August of 2014 (very soon!).

It also appears that the FDA is not requiring manufacturers to test their finished products before labeling them gluten free. The FDA would have the authority to monitor a product that has been reported as possibly containing gluten. It looks like it will be very important for us to report products that we believe are in violation of this rule to make it work for us.

I didn't see any information regarding whether or not a manufacturer will be required to disclose if their facility or equipment is shared under the new rule. This is very important information and it would do us a great service if they were required to state their equipment was shared. Does anyone know if that will be happening?

If anyone has any additional information or questions they would like to share, please do.

I know some of you go to seminars, etc, and have a much better understanding of the new rule than myself.

Here are some helpful links I was able to find regarding the rule:

http://www.fda.gov/food/guidanceregulation/guidancedocumentsregulatoryinformation/allergens/ucm362880.htm

http://celiac.org/blog/2013/10/14/fda-gluten-free-food-labeling-information-page/

http://health.usnews.com/health-news/blogs/eat-run/2013/08/06/making-sense-of-the-fdas-new-gluten-free-labeling-law

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If you like reading FDA documents here is a link to more on this subject (I work in an FDA-regulated industry and am used to reading their rules).

http://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/Allergens/ucm362510.htm

To answer some specific questions:

Manufacturers do not have to test their products - they can use other methods to ensure they are below 20ppm gluten (using naturally gluten-free ingredients, using ingredients that suppliers have tested, etc)

Manufacturers do NOT have to disclose that they have shared facilities or shared equipment.

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My questions were:

When will the new law for gluten free food labeling go in to effect?

What exactly will the new law mean as far as testing for gluten in the finished product goes?

Will manufacturers have to disclose if the facility or equipment is shared under the new law? (From what I understand, this is voluntary right now)

 

 

 

I believe August of this year.

 

They are not required to test anything.

 

Shared equipment is and will remain voluntary.

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What is the status of "no gluten ingredients" claims? I seem to be finding conflicting information about that phrasing. At first I read the rules to mean that any form of a "no gluten" claim had to meet the new guidelines of less than 20ppm. But upon further reading it started to sound like "no gluten ingredients used" could still be used - as long as the claim is truthful - without being expected to meet the 20ppm standard unless the label also makes a "gluten free" claim. For instance, the two links below (same links as in other posters' comments) seem to contradict each other. Or am I just reading it wrong? 

 

http://www.fda.gov/Food/ResourcesForYou/Consumers/ucm367654.htm

 

Compare to question #21 of this FAQ link:

http://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/Allergens/ucm362880.htm

 

Many Trader Joe's products, for instance, have no gluten ingredients but are made on shared equipment. I understand that the law does not require shared equipment to be disclosed, but if these products make a "no gluten ingredients" claim but are not labeled "gluten free", will they be held to the 20ppm standard (after August)? 

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