Gluten-free Labeling: What you need to know during the pandemic and beyond

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Published June 1, 2020

For those of us who need to be gluten-free, reading food labels is one of the most basic approaches to making sure that the foods we eat are safely gluten-free. In addition to being basic and necessary, reading labels can also be tricky and confusing, even under normal circumstances.

During the Pandemic

Now, due to the COVID-19 pandemic, the FDA is allowing manufacturers to make minor changes in packaged food ingredients without updating ingredient lists to reflect these changes.

While there is understandable rationale behind this move (e.g. supply chain disruptions, length of time it takes manufacturers to change labels), it does present potential concerns for those who need to follow a strict gluten-free diet.

This FDA guidance states that such substitutions should only be done when the ingredient being substituted does “not cause any adverse health effect”, with “gluten” being specifically noted as an example of an ingredient that should not be substituted in.

Importantly, this information which has been issued by the FDA is “guidance” and the wording utilized is that manufacturers “should” not substitute in gluten-containing ingredients.  This leaves room for error.

The possibility exists that companies could inadvertently substitute in gluten-containing ingredients that would not be noted in the ingredient list. GIG’s GFCO certification program works with thousands of food manufacturers routinely, and we know that manufacturers are not always aware of what ingredients contain gluten and which ones don’t.

For example,

What if a manufacturer were to substitute malt syrup for corn syrup, for example? The product would now contain gluten, but the ingredient list would still appear to be safely gluten-free. Another example of a problematic ingredient substitution would be from use of certified gluten-free oats in a product to commodity oats, which could contain gluten due to cross-contact. Note: The safest oat products are those that have been certified gluten-free. While products labeled gluten-free should comply with the FDA definition of containing no more than 20 ppm of gluten, this is not third-party verified. GFCO’s standard for gluten-free is 10 ppm of gluten or less.

GIG Responds

In response to this situation, the Gluten Intolerance Group signed on to a letter, originated by Gluten-Free Watchdog and submitted to the FDA by numerous organizations which serve the celiac/gluten-free community, that urges the FDA to make a modification to the guidance. Read letter

GIG re-iterates that now more than ever, GFCO certified gluten-free products offer the safest options for gluten-free consumers. No ingredient change can ever be made in a certified gluten-free product without being reviewed by GFCO.

Additional information:

The video features:



Laura Allred, Ph.D.  |  Regulatory Manager










Lola O’Rourke, MS, RDN





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