Do All Wheat Mentions on Food Labels Mean Not Gluten-Free?
Published April, 2021
4 Main Takeaways:
1. Wheat is considered one of the top eight allergens in the U.S., and the FDA requires that wheat be clearly identified on food ingredient labels.
2. May Contain Wheat statements on food labels are voluntarily placed on labels by manufacturers, are not regulated, and are there to warn wheat-allergic consumers, not gluten-free consumers.
3. GFCO-certified products with both the GFCO gluten-free certification mark and May Contain Wheat-type statements on the labels contain 10 ppm of gluten or less so are safely gluten-free.
4. Wheat-derived ingredients can be highly processed to remove gluten and be present in gluten-free products, however, they may still be problematic for wheat-allergic consumers.
Can a food label say both “Wheat” and “Gluten-Free?”
Let’s be honest: any mention of “wheat” on a food label is sure to send panic through the hearts of anyone living gluten-free, especially someone diagnosed with celiac disease.
Not all mentions of “wheat” on a food label mean the same thing. Below, we break down the “Contains: wheat”, and “May contain wheat” and “Processed on shared equipment / in shared facilities with wheat” statements to explain what they mean so you can make more informed food decisions.
Different Wheat Statements
As wheat is considered one of the top eight allergens in the U.S., the FDA requires that wheat be clearly identified on food ingredient labels for wheat-allergic consumers whenever it is intentionally added to a product. Note that barley and rye are not allergens so are not given the same considerations or treatment on ingredient labels.
Wheat, when present in some form in a packaged food product, may be mentioned on a food label in one of two ways:
1. with a “Contains wheat” statement immediately after or next to the ingredient list;
2. by including the word “wheat” in parenthesis after the ingredient which contains it in the ingredient list, [e.g., “Enriched flour (wheat flour)”].
“Contains wheat” or “wheat” in an ingredient list are statements required on any FDA regulated product intentionally containing wheat to alert wheat-allergic consumers. According to the FDA, the word “Contains” with a capital “C” must be the first word used to begin a “Contains” statement. (The use of bolded text and punctuation within a “Contains” statement is optional.)
Gluten-Free PLUS “Contains: Wheat” on a Label Means What?
A gluten-free claim may appear on the same label as a “Contains: wheat” statement or when “wheat” is listed on an ingredient list only if the ingredient derived from wheat has been processed to remove gluten to a level that complies with the FDA definition of gluten-free (less than 20 ppm of gluten).
The “Contains: wheat” statement can also apply to specially processed wheat starch (processed to remove gluten) or an ingredient made with wheat starch. In this case, the FDA also requires including the statement: “The wheat has been processed to allow this food to meet the Food and Drug Administration (FDA) requirements for gluten-free foods.”
Now the confusing part. Not all wheat starch is gluten-free. Wheat starch must be processed specifically to reduce gluten to less than 20 ppm to qualify as gluten-free product per the FDA, or 10 ppm or less to be certified by GFCO.
Wheat starch used in a product that is not certified or labeled gluten-free is a concern and should be avoided.
Breaking down those “May contain” wheat statements
“May contain”-type statements include “made in a facility that also processes…” and “made on shared equipment with…” These are voluntary statements that are not required or regulated by the FDA. They are different from “Contains wheat” statements or “wheat” listed in parenthesis on an ingredient list.
When you see a “May contain”-type statement, it could refer to the possibility of wheat being present in a product that was processed on shared equipment with gluten-containing products or other cross-contact risks including agricultural commingling. A “May contain” statement may also be used by a manufacturer to be completely transparent about their manufacturing process.
Gluten-Free PLUS “May Contain” on a Label Means What?
If you see a product with one of the “May contain”-type statements along with a gluten-free statement, it should be safely gluten-free because the manufacturer should be following FDA guidelines. If you see a product with one of the “May contain”-type statements on a GFCO-certified product, rest assured it is safely gluten-free. GFCO requires that a product tests at or below 10ppm, more stringent than the FDA.
NOTE: If you have a wheat allergy and see a product with one of the “May contain”-type statements, avoid this product regardless of the gluten-free claim.
To sum it all up, wheat must be mentioned on the food labels of FDA-regulated products as “Contains: wheat” or as “wheat” in parenthesis if wheat is in the ingredients in some form.* If wheat isn’t an ingredient but could get into the food in some other way, such as cross-contact, a voluntary “May contain” statement can be placed on a food label to call this out.
IMPORTANT: If you see a mention of gluten-free on the same label as a “May contain” statement, that means that regardless of possible cross-contact, the product should meet the FDA definition of gluten-free, but this claim is not third-party verified.
A third-party gluten-free certification mark on the same label that also mentions wheat should mean the product is safely gluten-free. We can only vouch for the safety of GFCO-certified products.
Every product with a GFCO gluten-free certification mark has met 80 requirements before they qualify for our certification. Not every product that applies qualifies or earns our certification mark. Any manufacturer of a GFCO-certified product who uses shared equipment must ensure the cleaning methods are effective and must provide evidence to GFCO on a regular basis to maintain their certification.
As always, consult your healthcare team when considering any information about foods that are safe for you to eat based on your current health and health conditions.
* The majority of packaged foods are FDA-regulated and comply with the Federal Food, Drug, and Cosmetic Act (FALCPA). Packaged meats are regulated by the USDA, and most, but not all, also comply with FALCPA. Learn more in our article: 3 Tips for Gluten-Free Label Reading.
Quick Reference Guide to Wheat Mentions on Food Labels
We’ve made this handy quick reference guide to help you better interpret statements, phrases, and words used on food labels related to wheat.
|IF YOU SEE THIS…||IT MEANS THIS…|
|A “Contains wheat” statement or “wheat” in parenthesis after an ingredient like “Enriched flour (wheat flour)”||Required by the FDA to alert wheat-allergic consumers (the FDA considers wheat to be one of the top 8 allergens in foods).
|A gluten-free claim as per the FDA along with a “Contains: wheat” or “wheat” in parenthesis on an ingredient list||The product contains an ingredient derived from wheat. The wheat starch or other wheat-derived ingredient went through a process to reduce the gluten content to safe levels.
The FDA requires this additional statement be on the label: “The wheat has been processed to allow this food to meet the Food and Drug Administration (FDA) requirements for gluten-free foods.”
Not all wheat starch is processed to be gluten-free. If it isn’t, you will not see a gluten-free claim or certification mark on a product containing it.
|A “May contain” wheat statement or a call out about shared equipment or potential cross-contact.
|Not required by the FDA and may be voluntarily used by a manufacturer to be transparent about their manufacturing process and to alert wheat-allergic consumers.
|No certified mark or FDA-compliant gluten-free mention on the label for a product with a “Contains wheat” statement.
|This is a concern and the product should be avoided.
|No certified mark or FDA-compliant gluten-free mention on the label for a product with a “May contain” wheat statement.
|It’s somewhat risky, and you’re better off avoiding it.|
|A certified mark or FDA-compliant gluten-free mention on the label for a product with either a “May contain” wheat or “Contains wheat” statement.
|It should be safe if it follows FDA gluten-free guidelines or is third-party certified. We can only vouch for GFCO-certified products.
Disclaimer: The information on this website is for educational purposes only. Consult your healthcare team when considering this information. Be Aware: Gluten can be introduced into products at any stage of production, transporting, and storing. Even if labeled or certified gluten-free, gluten can be introduced once the product is opened and served in your home or through a food service, including restaurants.
© 2021 Gluten Intolerance Group. All Rights Reserved