I think it's ridiculous, Surely gluten-free has to be 100 % gluten free all this low and 20 ppm or 3 ppm just confuses me :S
What specially produced Gluten Free Products do you consume ??
Have you ever asked any manufacturer of Gluten Free products what level do the test to ??
Where the New Gluten Free level is <20PPM means an upper limit, in actual fact most of the Gluten Free products test to between 3PPM and 10PPM, the <20PPM was set to accomodate a small level of error in checking!
If it were possible to get 100% Gluten Free (it's not possible to check to such small amounts, 3PPM is the smallest at the moment that render reliable results)
The costs involved would mean that NO COMPANIES
would produce Gluten Free products, for fear of litagation.
Even if it were possible then the average loaf of Gluten Free bread would cost in excess of $30 each.
We have to strike a happy midpoint where Gluten Free products are available and as safe as is possible comercially.
If you want to be 100% gluten Free then restrict yourself to a diet of meat, fish and well washed vegetables.
Cross Contamination is possible on everything else whether processed or raw (think about crop spraying, feed, nutrients etc)