I've just had to research this. Wheat is considered an allergen while Gluten is considered a sensitivity. Both must be included in labelling in Canada.
For the purposed of labelling, wheat sources are considered to be different types of wheat (Atta, Bulgur, Couscous, Durum, Einkorn, Emmer, Flour, Farina, Fu, Graham, high-gluten and high-protein flour, Kamut, Seitan, Semolina, Spelt (dinkel, farro), and tricale; which contain gluten.
Gluten means any gluten protein from the grain of any of the following cereals or the grain of a hybridized strain created from at least one of the following cereals: barley, oats, rye, triticale (will be considered a WHEAT ALLERGEN), and wheat (all species - will be considered a WHEAT ALLERGEN), or any modified gluten protein, including any gluten protein fraction, that is derived from the grain of any of the cereals referred to above or the grain of a hybridized strain referred to earlier. The definition of gluten also includes prolamins, which are a group of plant storage proteins having a high content of the amino acid proline. Prolamins are also found in the seeds of the above cereal grains as follows: gliadin in wheat, hordein in barley, secalin in rye, and avenin in oats.
The requirement for food allergens and gluten declarations apply to all generations of ingredients. Therefore, food allergens and gluten must be declared regardless of which generation they are present in. For example, if they are present in the third or fourth generation of ingredients they will still have to be declared in the list of ingredients on the product label or in a contains statement. Food allergens and gluten must be declared in one of two ways: 1) by being declared in the list of ingredients or 2) in a "contains" statement.
Option 1: The prescribed source name of the food allergen or gluten may be shown in parentheses in the list of the ingredients, as follows:
- (a) Immediately after the ingredient that is shown in the list, if the food allergen or gluten [B.01.010.1(8)(a), FDR]
- Is, or is present in, that ingredient, but is not a component or present in a component of that ingredient, or
- Is, or is present in, a component of that ingredient and the component is not shown in the list of ingredients;
For example: Ingredient List: flour (wheat), liquid albumin (egg), vegetable oil, sugar, flavour.
In this example:
- Wheat protein is an inherent part of flour but is not a component. Since wheat is both a food allergen and gluten source it must be declared.
- Liquid albumin is an egg protein. As eggs are a food allergen, "egg" must be declared.
or
- (b) Immediately after the component that is shown in the list of ingredients, IF the food allergen or gluten is the component or is present in the component [B.01.010.1(8)(b), FDR].
For example: Ingredients list: pastry pieces [flour (wheat), butter (milk), liquid albumin (egg), canola oil], sugar, natural flavour.
In this example, as "pastry pieces" are not exempt from component declaration, its components must be declared. The required food allergen and gluten prescribed source names are declared in parentheses after the component in which they are present:
- Wheat is a part of flour;
- Butter is made from milk;
- Liquid albumin is an egg protein;
Option 2: The prescribed source name of a food allergen or gluten may be shown on the label of a product in a "contains" statement that complies with the naming and location restrictions outlined in B.01.010.3(1) of the FDR [B.01.010.1(9), FDR], IF the food allergen or gluten
- (a) Is, or is present in, an ingredient that is not shown in the list of ingredients, but is not a component of that ingredient or present in a component of that ingredient,
or
- (b) Is, or is present in, a component and neither the component nor the ingredient in which it is present is shown in the list of ingredients
For Wheat, you do not have to list both wheat and gluten in "Contains" statments. You would list "Contains Wheat".
) proteins found in certain sources as you nicely describe.)
