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Do we need to change labels now we found traces of gluten in product?


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#1 Alfbru

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Posted 08 January 2020 - 02:21 PM

Hi

 

We are a rice company who produce composite rice dishes of different flavourings.

 

One of our products contains cumin seeds. Our cumin seeds supplier has sent us an update of the specification and they declare traces of gluten.

 

How do we proceed? Do we make a new label reflecting these traces? (Please keep in mind that the % of cumin seeds in the final product is very small ~ around 2%). 

 

The product beforehand was not declared as gluten-free but gluten was also not included in the label allergen list as our ingredients do not contain gluten. 

 

Thanks



#2 pHruit

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Posted 08 January 2020 - 03:15 PM

Where are you selling these products?
Allergen requirement aren't the same globally, so the labelling implications will depend on the country/countries in which the finished products are sold.

Irrespective of that I'd be asking my supplier why they'd suddenly decided that the allergen cross-contamination risk cannot be sufficiently controlled. This might genuinely be outside their control, as some spices are known to be a potential challenge at the agricultural and initial harvest/handling end of things (I feel like the European Spice Association used to have a good position statement on this, but can't seem to track down a copy).

 

If it cannot be avoided then yes, I do think you should include the presence / possible presence on the label.



#3 Hank Major

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Posted 08 January 2020 - 08:25 PM

You need only be concerned with the gluten content of your finished product, not the ingredient. Most likely the level of gluten will be undetectable in the finished product even if there are traces of gluten in the cumin seeds. Send it out for testing.



#4 pHruit

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Posted 08 January 2020 - 08:33 PM

You need only be concerned with the gluten content of your finished product, not the ingredient. Most likely the level of gluten will be undetectable in the finished product even if there are traces of gluten in the cumin seeds. Send it out for testing.

 

This depends to an extent on the region in which the finished product is being sold - for EU purposes, it is not strictly the gluten that is the allergen, but the cereals in which it is found. An allergen labelling requirement could therefore be triggered by presence of other proteins from these as there is no threshold set, even if the gluten content is below the 20ppm threshold applicable for a "gluten free" claim.

I suppose the same thing could be accomplished with further testing, but it's not necessarily going to be the most reliable approach, and would require a far broader suite of analysis.

Similarly one could make the inference that gluten below LOD implies all other relevant protein components similarly below LOD, but it's not a strong position in and of itself without considerably more validation, IMO.



#5 Hank Major

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Posted 08 January 2020 - 08:46 PM

This depends to an extent on the region in which the finished product is being sold - for EU purposes, it is not strictly the gluten that is the allergen, but the cereals in which it is found. An allergen labelling requirement could therefore be triggered by presence of other proteins from these as there is no threshold set, even if the gluten content is below the 20ppm threshold applicable for a "gluten free" claim.

I suppose the same thing could be accomplished with further testing, but it's not necessarily going to be the most reliable approach, and would require a far broader suite of analysis.

Similarly one could make the inference that gluten below LOD implies all other relevant protein components similarly below LOD, but it's not a strong position in and of itself without considerably more validation, IMO.

 

It is likely that the alleged traces of gluten in the cumin are confined to the specification; that is, they are legally indemnifying themselves. Whole cumin seeds, even if grown in fields that have some wheat plants, should not have much gluten. What gluten there is will be in the form of actual wheat kernels.






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