U.S. Labeling Rules on Wheat in Vinegar and Alcohol

[glutenmaestro]

In the U.S., does wheat (as an allergen) need to be identified in the ingredient lists of foods containing ethanol (e.g. vanilla extract in candy etc.), or white vinegar, when distilled from wheat? Unlike Europe, Australia/New Zealand and possibly Canada, the FDA doesn’t mention any exemptions for wheat.

[Scott Adams]

The U.S. Food and Drug Administration (FDA) had specific regulations in place regarding the labeling of allergenic ingredients in packaged foods, including those derived from wheat. Under the Food Allergen Labeling and Consumer Protection Act (FALCPA), major food allergens must be clearly labeled on packaged foods. Wheat is one of the eight major food allergens covered by FALCPA.

In the context of ethanol, which is used in various food products like vanilla extract and vinegar, the FDA's guidance stated that if the ethanol is used as an ingredient and is sourced from a major food allergen like wheat, it should be declared on the label. This means that if wheat-derived ethanol is used in a food product, the label should mention it if it's present in a significant amount that could cause an allergic reaction.

[Blue-Sky]

Certain peptide sequences (chains of proteins) found within longer chains of proteins (which make up gluten) will trigger an immune response resulting in damage to the gut. Distilled vinegar in the US in normally made from corn. The heat though evaporates water and acetic acid. This then condenses to make distilled vinegar which doesn't have any protein.

The FDA say if an ingredient contains one of a list of allergens (including wheat) the common name for where that allergen came from has to be listed on the food.  May items contain vinegar and I haven't ever seen a warning on any of them that they contain wheat. I assume they are all made from distilled corn vinegar.

https://www.fda.gov/food/food-allergensgluten-free-guidance-documents-regulatory-information/food-allergen-labeling-and-consumer-protection-act-2004-falcpa