Gluten free labelling laws are strict in AMERICA (20 ppm) - but are not the most strict in the world

Jan 6 09:35 2010 Bruce Scott Dwyer Print This Article

Gluten Free labelling laws used to be very lax at 200 ppm. This made many celiac’s sick. Europe led the way in lowering permitted gluten in gluten free food to 20 ppm and the US is soon to follow, but Australian authorities think that this is still too high. This article looks at the intention behind the current laws and what the real threshold is believed to be (much less than 20 ppm!)

At the core of any celiac shoppers shopping list is buying products that are gluten free. But what exactly does that mean? Do you buy foods that have no ingredients that could possibly contain gluten grains,Guest Posting or are you willing to risk buying foods that are classed as gluten free, because they contain an amount of gluten that ‘someone’ has assessed as safe?

It would appear that the more experienced celiac shopper knows what ingredients to look out for, however some very experienced gluten free shoppers still report feeling sick from manufactured foods purporting to be gluten free. As the information below will show, it all appears to be in the acceptable level that countries are willing to legislate.

The three most progressive legislation regions appear to be the US, Europe and Australia. These areas will be discussed in this order.


Previous GFP research suggests that Europe maybe one of the most gluten free aware regions on earth, however they have very low online search habits. This may of course be due to low rates of celiac disease and/ or high availability of gluten free food in the general community.

Regarding the labelling requirements: “In Europe, the Codex Commission approved 20ppm as an accepted threshold for gluten in 'gluten-free' products in 2008, in the first update to guidelines since 1983. The limit was massively cut from 200ppm to 20ppm – and it claims this level is considered to pose no risk to celiac sufferers. The reason for the change is that low levels are more easily attainable than 25 years ago due to technological advances allowing for more accurate detection of minute gluten traces.” Ref 1


The US is one of the largest physical and online demand gluten free markets in the world. With its progressive technological and health advances you may expect that it also leads global labelling laws.

However gluten free products appear to be an exception. While the Food and Drug Administration (FDA) introduced the Food Allergen Labeling & Consumer Protection Act (FALCPA) in 2006, this was for the following eight food allegens “Milk, egg, wheat, soy, peanut, tree nuts, fish, and crustacean shellfish.” By 2007 the FDA PROPOSED that gluten SHOULD be labeled at anything over 20mg per kg (20ppm) – but this has yet to be ratified.

Thus while many manufacturers are voluntarily following this guideline “Journal of Allergy and Clinical Immunology found 25 different types of advisory term including ‘may contain’, ‘shared equipment’ and ‘within plant’. Additionally, they found that 65 percent of products listed non-specific terms, such as ‘natural flavours’ and 'spices’, and that 83 percent of those were not linked to any specific ingredients.” Ref 1. This suggests that gluten could potentially be hiding among the non-specific terms.

Remarkably while standard foods are covered by the FSA 20 mg ruling, it created a unique labeling category just for CEREALS. Those that have been processed to reduce gluten to levels below 100 parts per million must carry a label such as ‘gluten-reduced,’ or ‘very-low gluten.’ Foods that are naturally gluten-free and acceptable for a gluten-free diet cannot be labeled as ‘gluten-free,’ or ‘special-diet,’ but may say that they are ‘naturally gluten-free.’ Ref 3

The FSA also mandates that quantitative determination of gluten in foods and ingredients be based on an immunologic method or other method providing at least equal sensitivity and specificity, and that all testing done on equipment sensitive to gluten at 10 mg gluten/kg or below. The rules cite the enzyme-linked Immunoassay (ELISA) R5 Mendez method as the officially sanctioned qualitative analysis method for determining gluten presence in food. Ref 3

Curiously The Celiac Sprue Association has gone even further in its labelling recommendation of classing foods as gluten free ONLY if they contain under 3 ppm – The CODEX COMMISSION remains resolutely behind the 20 ppm specification due to the quality control that can reasonably be expected from manufacturers. As it is, they may have until 2012 to abide by the FSA 20 ppm ruling!


Australia has one of the most mature physical and online gluten free markets in the world. Along with this comes one of the most stringent gluten free labelling standards in the world:

QUOTE from Food Standards Australia New Zealand: “To be labeled gluten-free in Australia and New Zealand, a food must contain "No Detectable Gluten’ by the most sensitive universally accepted test method. At the time of the printing of the Ingredient List, 7th Edition, testing can (readily) achieve a detection level of 0.0005 (5 parts per million). If gluten is not detected then the food can be labeled gluten free." Ref 2

The Coeliac Society of Australia notes that “some ingredients (i.e. glucose syrup, dextrose and caramel colour) are so highly processed that when tested, the results have always shown ‘no detectable gluten,’ even if derived from wheat," Therefore, these common ingredients derived from wheat are rendered gluten-free, even though gluten is declared on the product label.” Hence the qualification: "the label gluten-free overrides the product’s ingredient listing, and products with statements such as "may contain wheat or gluten" should be avoided." Ref 2

While The FSANZ quote suggests that Australia’s gluten free labeling standard is likely to become ‘law’, a 2007 survey conducted by the NSWFA suggests that the association has very few powers to enforce it. In 2007 the NSWFA undertook a survey of foods labeled “gluten-free” and found that of the 211 foods labeled as “gluten-free” in  retail outlets that 4.7% did NOT qualify. (Ref 3) In fact, ten samples were found to contain gluten, with gluten content ranging from 4 ppm to 160 ppm. The highest foods were found to be prawn crackers (160 ppm) followed by Self- raising flour (30-45 ppm). Following international guidelines at the time, foods over 20 ppm were requested to be withdrawn voluntarily by the manufacturer.


Australia has ‘potentially’ one of the most stringent gluten free labelling laws in the world. If the ‘no detectable gluten’ clause is taken at its word and kits can test between 3 and 5 ppm gluten, then this SHOULD be the upper limit of allowable gluten in gluten free Australian manufactured foods. However from previous surveys, it appears that offenders of this law, are often given a voluntary request to withdraw products and no fines or penalties are issued, no media notification is required for ‘small’ infractions.

Europe and America have both settled on an upper limit of 20 ppm, yet this is not law in the US yet. The Celiac Sprue Association (USA) is pushing for gluten free limits to be dropped to 3 ppm however some US manufacturing groups believe that this will prove too difficult to attain in reality. Note that the Australian gluten free survey used Biokits Gluten Assay Kits manufactured by Tepnel Biosystems . The kits are an accredited AOAC Official method and measure gluten both qualitatively and quantitatively, with a limit of reporting of 3 ppm (mg/kg).

US research shows that many of its own country’s products contain labelling terms such as as ‘natural flavours’ and 'spices’ which may or may not include gluten. If this is the case on such a progressive country it is strongly suggested that eating food from other countries that don’t abide by gluten free legislation IS a high risk venture. This raises the question of how much do you trust your local manufacturer not to allow cross contamination in the manufacture of ‘gluten free’ foods, and where exactly does your favourite gluten free restaurant source its ingredients?

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Bruce Scott Dwyer
Bruce Scott Dwyer

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