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Gluten Free - Processed in a facility that processes gluten

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Posted 22 October 2017 - 07:01 PM

Hello fellows!


I would be grateful to hear your opinion about a certain trend I noticed on many food products in Canada (nutrition bars, beverages, ready broths, frozen meals, frozen pizzas, etc. Many different kinds of products).


They have a nice "GLUTEN FREE" claim on the front / main label, with or without the barred ear of wheat or the circled GF logo.


If you turn the product and read the little statements behind (usually under the ingredients list) you find also a similar statement:





1) Isn't this a contradiction in terms?


2) I thought that you cannot use the GLUTEN FREE claim unless you can be absolutely sure that your product is gluten free (whether it is below 20 ppm or zero/undetectable, this is another topic). If you are sure (allergen program, suppliers program, ingredients testing and segregation, production appropriately scheduled, specific cleaning procedures before processing the gluten free products, food contact surfaces tests before production, batches/lots of finished products tests, etc.), then you can claim it.

But, in this case, because you are sure and you verify every lot, you DO NOT NEED to write "processed in a facility that processes gluten".

It wouldn't make any sense!

What's the purpose of this warning? To inform the consumer that, because of that, there might be gluten traces. So the allergic people will be afraid to eat the product, and prefer avoid. So what's the point of having the allergen program in place and the gluten free claim?


3) Then I thought that, even though you do not add any gluten or gluten-containing ingredient, if you don't have the above allergen program in place, if you also have gluten in your facility, and you are not able to assure that it doesn't cross-contaminate the non-gluten products, than you need the warning.

But in that case, the last thing you can do is claiming GLUTEN FREE on the label! Because, indeed, you do not know if it's gluten free or not.


4) Finally, definitely I always knew that both the statements on the same products are an absurd.


I talked with some manufacturers and they even said that it's mandatory for them to write the warning if they have gluten in the facility, no matter what! Is this true? It doesn't make any sense! If a facility is controlled enough to be able to claim GLUTEN FREE, they should be allowed to omit the warning.

That warning basically destroys every effort, time, and dollar spent by the company to ensure the product is Gluten Free!


Any hint about this?

US-related answers are also welcome.





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Posted 22 October 2017 - 09:31 PM

The statement processed in a facility that also processes Gluten is a regulatory requirement.


As a Gluten Free Certification Program (GFCP) Approved Consultant I tell you first hand that it is difficult to establish a GF production within a facility that has gluten present in other items, but it is doable.  


GFCP by the way is a Canada based certification that is global in scope.


You can find them here: www.glutenfreecert.com


We have a client that wanted to get into gluten free production and had space to do so within a facility in New York City that traditionally has been (and still is) a major producer of pita bread and various flat breads. They actually designed a self-contained facility within the facility and have been under 10ppm (well within limit.)


It is doable.

All the Best,


All Rights Reserved,

Without Prejudice,

Glenn Oster.

The Business of Food CONSULTANT

ceo - Glenn Oster Consulting, LLC

ceo - Goodstart Coastal Enterprises, LLC

ceo - VikingStone, LLC

Partner - Lighthouse Health & Wellness, PMA


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Posted 22 October 2017 - 09:44 PM

Thanks Glenn,


And what about the double statement?


It seems to me that the "Gluten Free" statement is not compatible with the "Manufactured in...." warning.


• Is it legal?

• Is it tolerated by private gluten free certification programs?


Let's analyze the purpose of a statement.


The purpose of a "Gluten Free" statement is to reassure people they won't get sick.


What about "Processed in..."?

The immediate purpose of the "Processed in..." statement is regulatory compliance; but, the remote purpose is people protection. What's the goal of law? It's not abstract. The goal of legislation is to protect people. So, if regulations want manufacturers to state that, it's because the legislator is aware that, if food is processed in such environment, there might be chances of cross-contamination, so people with allergies might get sick.


In other words, such products basically state this on their labels, on the same product, what follows:


Go ahead, you can eat this, you won't get sick.

Pay attention! If you eat this you might get sick.


I believe there's a glitch here.

Either regulations need to be revised, and stop requiring the "Processed in..." statement to be added if the manufacturer can prove that the product is not contaminated (it would be easy to define requirements for this to be proven, for example test of surfaces and finished product for every batch, and a comprehensive constantly verified allergen program), or, simply, the Gluten Free claim should not be allowed anymore, unless a facility is a dedicated gluten free one (or is a completely isolated area within a facility).


What are your thought?


Thank you.



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