Contains Gluten-Free Ingredients
Hello,
We are a NON gluten-free bakery and are thinking about making a product that contains only gluten-free ingredients. If we claim "made with gluten-free ingredients" (as opposed to "gluten free"), list that we use wheat in the facility, and have an extra statement on the back saying not recommend for individuals with Celiac disease, is this enough? Are there any other regulations we should be aware of?
Is it gluten free or isn't it? Customers will think the same thing.
The product would not contain gluten but we use wheat flour in the facility. Maybe to avoid any trouble with "GF" we could say "Made with Rice (or whatever we end up using) Flour" instead of mentioning anything about gluten?
Is it possible that the product really is gluten-free? For $55 (I think) you can send a sample of the finished product (or the dry mix) to FAARP for testing.
We have worked with gluten bakeries thst wanted to make gluten free items and it becomes very difficult even if you are using ALL GF ingredients you still find the gluten counts exceeding thresholds due to so many possible introductions of gluten from seemingly inocent things like people crossing from a gluten area to the non gluten area, mix ups in flour usage, drift, etc.
I just would not get into doing something like this because at the least your company gets bad PR and at the worst people think your product is GF and they end up getting sick.
So it really is a no go unless you section off a clean room and all the requirements that come with this.
All great points. Are there any articles on companies who have tried (and failed) to do this that I can show the sales team? We're having a meeting tomorrow so I'd love to show them proof of it going awry.
https://www.abc.net....d-food/10479564
https://www.verywell...nts-mean-562781 (this one is an article that people looking for gluten free will probably end up reading)
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What 'No Gluten Ingredients' Means"No gluten ingredients" means just that: the food product doesn't contain gluten ingredients. It does not mean that the food meets the legal definition of "gluten-free."
If a manufacturer doesn't want to test a product for gluten, or if that manufacturer is concerned that a product might not consistently meet that FDA standard of 20 parts per million, the company might decide to use the term "no gluten ingredients" instead of "gluten-free." For the consumer, it signals a bit more uncertainty about the gluten-free status of the product.
In fact, several companies that produce both gluten-free products and gluten-containing products use the term "no gluten ingredients" for products whose ingredients don't include gluten, but which may be at risk for cross-contamination or aren't tested for gluten.
Other companies label their products "no gluten ingredients" as a form of legal protection—the products may actually meet the FDA's "gluten-free" standards, but using the phrase "no gluten ingredients" doesn't promise as much, just in case.
Finally, some in the gluten-free community say that foods with no obvious gluten ingredients listed on their labels are safe to eat, especially if the company in question has a policy of clearly labeling any gluten-containing ingredients. However, these products still can contain plenty of gluten from cross-contamination.
Foods labeled "no gluten ingredients" (or which don't appear to contain gluten ingredients) can vary widely in their actual gluten content. Some might actually meet standards for "gluten-free," while others may have a high degree of gluten cross-contamination.
For example, a study published in the scientific journal Food Chemistry, looked at 186 foods with no gluten ingredients that were not labeled "gluten-free," and found that nearly 20% of them had gluten levels above the legal level. A total of 10% had gluten levels above 100 parts per million."
Some thought, from an enterprise risk perspective, is needed before you move forward. In order to have confidence in (and therefore add some protection to your organizations brand) a "free from" type claim, you would need to consider:
- ingredients and formulation (you covered this, not intentionally adding gluten containing materials)
- supplier approval (risk of accidental, hidden, or contaminated raw materials coming into the facility)
- cross contact mitigation (you highlighted this as a risk - you use wheat flour in the facility)
- employee practices (are the aware of the need to protect the product)
Putting any verbiage on your consumer facing packaging indicating the product is made for those interested in gluten free products, you are targeting a higher risk consumer. My recommendation - if you are going to produce for a high risk group do it right, and have a full blown gluten management system im pace that mitigates your risks, otherwise you are likely to run into significant issues and do some damage to your brand.
Hi rebudke
my assumption is that it will be judge as misleading to consumers, especially because GF is regulated. And - other as organic - gluten is an health issue. But even for organic it is forbidden to give only the impression to comsumers by wording, modified logo etc But I have a European view on legeislation.
Rgds
moskito
From my experience,
The highly sensitive individuals usually don't purchase items that aren't made in a gluten free environment.
The less sensitive individuals will usually scan the ingredient list looking for gluten.
I recommend avoiding that claim altogether and just have "Processed in a facility that also processes wheat" on the label.
Thanks everyone for all of your input!