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Gluten Free Labeling - IT'S A TRAP!

FDA Gluten free labeling

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#1 Louie S.

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Posted 16 September 2016 - 09:08 PM

We are a nut and snack company and our only processing step is dry roasting.  A customer asked if we sold any gluten free products and it prompted us to look into labeling guidelines and what it would cost.  Some of our mixes contain wheat but we also have a lot of product that are just plain nuts with salt, honey, or chocolate.  

 

So after searching the web and reading the FDA's final rule Q&A I have concluded that Gluten Free labeling is a TRAP!!

 

It is voluntary, no actual certifying body, no official stamp, minimal supervision, etc.  I have ZERO knowledge of this so I'm curious to see what you guys think or if your company uses gluten free labeling.

 

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#2 mgourley

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Posted 17 September 2016 - 04:10 AM

There is at least one certification body

We make some gluten free products and we have annual audits by this group.

 

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#3 WowQC

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Posted 21 September 2016 - 12:47 PM

We have done a "self certification" for gluten free. We claim gluten free on the label and must be able to back that claim up. We do this through supplier approval, process controls, and annual testing. It is a bit easier for us, as we do not have any gluten in the facility at all. Third party certification specifically for gluten free is not required, it just allows you to use a certified logo on the label, which customers may recognize.

 

As with any other claim on the label, you need to prove it - validate and verify ;)

 

WowQC


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#4 Louie S.

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Posted 21 September 2016 - 05:29 PM

We have done a "self certification" for gluten free. We claim gluten free on the label and must be able to back that claim up. We do this through supplier approval, process controls, and annual testing. It is a bit easier for us, as we do not have any gluten in the facility at all. Third party certification specifically for gluten free is not required, it just allows you to use a certified logo on the label, which customers may recognize.

 

As with any other claim on the label, you need to prove it - validate and verify ;)

 

WowQC

 

Ok, this is actually where we want to start.  Create a program that helps us "self certify" and as we grow, invest in an annual validation and logo usage from an approved certifying body.  


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#5 Ryan M.

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Posted 21 September 2016 - 07:43 PM

Ok, this is actually where we want to start.  Create a program that helps us "self certify" and as we grow, invest in an annual validation and logo usage from an approved certifying body.  

 

If I were you I would just tack it onto your current allergen program.  This is the most efficient method.  You can validate the program with finished product testing for gluten, and/or sanitation practices between gluten to non-gluten.


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#6 moskito

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Posted 23 September 2016 - 05:16 PM

Hi,

there are minimum three certifications in the US with max gluten levels are 10 ppm or 5 ppm. The legal limit (FDA) is 20 ppm. You will need clear procedures which can be integrated in your allergen management program.

The advantage vs other allergens is that your able to measure vs a limit. I have certified 6 products for the US market.

In the US thee are a lot of "free from" claims like "dairy free", "wheat free", "nut free". Until today I have not understood how these claims are verified. In analytic there is no Zero or free from, you can only claim < LOD of a method. Therefor we don't use these claims even marketing is presenting examples from the market.

What "wheat free" does mean and how to verify? What is the consumer perception? No wheat in recipe? There is gluten intolerance and wheat allergy. Gluten you are able to measure. How to exclude with which limit other proteins from wheat?

So, as long as you want to claim "free" where a limit is legally defined, it is "easy" and manageable IMO if processes and raw materials are under control and speciall selected.

 

Rgds

moskito


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#7 jpollock

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Posted 08 February 2017 - 08:25 PM

Believe 21 CFR 101.91(a)(3) is what you should be looking at.


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#8 SQFconsultant

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Posted 17 February 2017 - 03:08 AM

Well Louie, there are actually several GF certication bodies including the one that we are approved to offer consulting on GFCP which is process based unlike the others.

The only trap we see are companies that assume their oroducts do not contain gluten, noting this on their label and all of a sudden a random aisle pull is done and product tested only to find that the gluten count exceeds the threshold.


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