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Need Help Understanding Labeling Guidlines!

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Hello everyone,

I'm still fairly new to this and still have a bajillion questions...

I baught rice bars from my grocery store's "gluten free" area. Now, I did not look at the label closely enough because they are labeled "wheat free" not "gluten free".. arg!

The ingredients list does list "natural flavor" as the second last ingredient... I emailed the company and asked them if these bars contained gluten.. here is the reply I got:

Hello, Erica. Thank you for contacting us with your question. The batch of

Krispy Rice Bars that you have is almost gluten free. It just falls shy of

the accepted gluten free guidelines. I would think it's safe based on this

however would leave it up to you to decide. The batches made after that are

labeled gluten free.


Best regards,


Now, I understand that the testing standards are 200 ppm... what exactally does that mean!! I need some help in understanding this.

How much gluten is that? If something is labeled "gluten free" and falls below the guildine with 199 and I eat 2 servings does this take me into a danger zone? And how much gluten is 200 ppm.. how much gluten will really cause a reaction??

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I find the answer totally unhelpful. What does "just short of gluten free" mean? Does it mean that they used barley malt, but only a little, so they think that it just has very little gluten, and is hence ok? (Which it wouldn't be.) Does it mean that they had contamination on the lines that caused there to be gluten?

I would *guess* from the response that they are testing, and were working out bugs in the formula or production so that it would test gluten free. In this case, I wouldn't eat it, and - if I were to try something from the company again - would wait for the other one.

(200ppm is the old European standard; there currently is not yet any standard for "GLUTEN FREE" in the US, but it looks like it's going to be set at 20ppm. That doesn't mean that you'll know when something tests as 1ppm or 10ppm, because the tests have a limit to how low they can detect. Under 20ppm (or whatever the test *actually* tests to), is just "undetectable.)

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Here is some additional information:


Celiac.com 01/25/2007 - Under an FDA proposal published yesterday, food companies will have to meet new standards before labeling their products as gluten-free. It also provided a new definition for gluten-free which will give individuals with celiac disease greater confidence that specially labeled foods are in fact, safe for them to eat, according to the American Celiac Disease Alliance (ACDA).

The Food Allergen Labeling and Consumer Protection Act (FALCPA) passed by Congress in 2004, requires food manufacturers to clearly state if a product contains any of the eight major food allergens: milk, eggs, peanuts, tree nuts, fish, shellfish, wheat, and soy. It also required the FDA to develop and implement rules for using the term ‘gluten-free’ on food packaging.

Adhering to the gluten-free diet is the only course of treatment for celiac disease, a genetic digestive disorder. The condition, triggered by eating the protein gluten which is found in the grains wheat, rye, and barley, and hybrids of these grains affects an estimated 2 to 3 million Americans.

There is no single, world-wide accepted definition of gluten-free labeling. The levels of acceptable gluten vary from country to country, as do the symbols and terminology, permissible in the labeling. Research establishing a safe threshold of gluten consumption for those with celiac disease was recently published in the American Journal of Clinical Nutrition. The study, conducted by members of the ACDA at the University of Maryland and referenced by the FDA, concludes that celiacs can safely tolerate up to 20 parts per million (ppm) of gluten a day.

“The FDA listened to patients, food manufacturers, and members of the scientific community and came up with a well thought out proposal,” said Andrea Levario, Executive Director of the ACDA.

There is so little research about the gluten-free diet and safe consumption levels that the agency is seeking comments on a number of related issues including:

The appropriateness of 20 ppm gluten as the proposed threshold level as determined using an ELISA based testing method;

The effect that adoption of a lower threshold level would have on individuals with celiac disease and on industry;

Whether a lower threshold level might effect (limit availability of) commercially available foods labeled gluten-free in the United States;

Whether a reduced availability would have a negative impact individuals with celiac disease; and

Whether oats should be included in the definition of prohibited grains.

In the absence of federal rules, food companies have been using a variety of standards in manufacturing gluten-free products. This creates confusion and skepticism among individuals whose health depends on clear, accurate labeling. With only 90,000 out of an estimated 2 million celiacs diagnosed, manufacturers know that uniformity and consistency will benefit them as well consumers, said Levario.

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