Identifying Gluten-Free Products: Ingredient Labeling of Food Products

Labeling of Wheat Ingredients

In the United States, most of the time, if a food or an ingredient found in a food is wheat or contains protein from wheat, the word wheat will be present on the food label. This is the result of the Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA).

One exception is food labeled before FALCPA went into effect (January 1, 2006). However, as time passes, you are less likely to come across a product packaged before January 1, 2006.

Another exception is food regulated by the U.S. Department of Agriculture (USDA)—namely, meat products, poultry products, and egg products.

The Food Allergen Labeling and Consumer Protection Act

The Food Allergen Labeling and Consumer Protection Act of 2004 is an amendment to a federal law (the Federal Food, Drug, and Cosmetic Act) that, among other things, regulates the labeling of food. Even though it does not specifically address gluten, it does address wheat, and that is a big help to anyone who can't eat gluten. FALCPA requires that labels of all packaged food regulated by the Food and Drug Administration and labeled on or after January 1, 2006, clearly state when a food or an ingredient found in a food is or contains protein from one of eight major allergens, including wheat. The seven other major allergens covered under FALCPA are milk, eggs, fish, crustacean shellfish, tree nuts (such as almonds, cashews, and pecans), peanuts, and soybeans.

Under FALCPA, if an ingredient in a food product is wheat or contains protein derived from wheat, the food manufacturer has two alternatives for declaring wheat on the food label:

1. The word wheat can be stated parenthetically immediately after the ingredient that is or contains protein from wheat. For example, if farina is an ingredient, it may be listed as "farina (wheat)" in the ingredient list.
2. The word wheat also can be included in a separate "Contains" statement immediately following the ingredient list. For example, after the ingredient list on a package, you may find the statement Contains wheat.

Manufacturers may choose one or the other alternative, so if the label has no "Contains" statement, you must read the ingredient list looking for the word wheat.

There is one exception to these labeling alternatives. If the word wheat is already present in the ingredient list, then the word wheat would not have to be stated again. For example, the ingredient list would not read, "wheat, farina (wheat)." It would simply read, "wheat, farina," and any other ingredients.

Keep in mind the bottom line. If an FDA-regulated food product contains protein from wheat, the word wheat must be clearly stated on the food label. If you don't see the word wheat, the product does not contain wheat protein.

Wheat Ingredients in FDA-Regulated Foods

The FDA regulates all domestic and foreign packaged foods sold in the United States except meat, poultry, and egg products. FDA-regulated packaged foods include conventional foods, medical foods, dietary supplements, and infant formula. In addition, prepackaged foods labeled for sale at restaurants, delis, supermarkets, and other retailers must comply with FALCPA requirements. Raw agricultural commodities in their natural state, such as fruits and vegetables, are not considered packaged foods and are not subject to FALCPA requirements.

All ingredients found in FDA-regulated packaged foods must comply with FALCPA requirements. Therefore, if a flavoring contains protein from wheat, wheat must be declared on the food label and cannot be included under the collective term flavoring. If a seasoning mix or spice blend contains protein from wheat, wheat must be declared on the food label as well. Likewise, if an incidental additive, such as a processing aid, contains protein from wheat, wheat must be declared on the food label.

Note: If modified food starch, dextrin, caramel color, maltodextrin, or glucose syrup is listed in the ingredient list of an FDA-regulated food product and the word wheat is not included in the ingredient list or in a separate "Contains" statement, these ingredients do not contain wheat protein.

Wheat Ingredients in USDA-Regulated Foods

You have to be more vigilant when considering USDA-regulated foods, such as meat or poultry products, than with FDA-regulated foods. While all FDA-regulated packaged foods will include the word wheat on the food label if there is wheat protein in the product, at the present time, labels of USDA-regulated products need only list the common or usual names of ingredients containing wheat. However, the Food Safety and Inspection Service of the USDA is in the process of developing regulations for labeling of food allergens on meat, poultry, and egg products. In the meantime, the USDA encourages manufacturers to list food allergens on product labels. Regardless, it is still important to be able to identify possible "hidden" sources of wheat protein on USDA food labels.

If the food label of a USDA-regulated product includes any of the following ingredients, the food product contains wheat:

• Flour (unless, of course, the word flour is preceded by a descriptor such as corn, rice, or buckwheat)
• White flour
• Plain flour
• Enriched flour
• Phosphated flour
• Self-rising flour
• Graham flour
• Durum flour
• Farina
• Semolina

In addition, the following ingredients may be made from wheat starch or wheat starch hydrolysates (wheat starch that has been partially broken down):

• Modified food starch
• Dextrin
• Maltodextrin
• Caramel
• Glucose syrup

Note: It is very important to stress that while caramel, dextrin, glucose syrup, maltodextrin, and modified food starch may be made from wheat starch or wheat starch hydrolysates, according to the results of inquiries originally submitted by Gluten-Free Living magazine to ingredient manufacturers in the United States, manufacturers are much more likely to use cornstarch. Nonetheless, ingredient manufacturers exist worldwide, and U.S.-based food manufacturers may outsource some of the ingredients in their food products. While foreign ingredient manufacturers must comply with U.S. regulations, they may not always use cornstarch. For example, in Europe, these ingredients are more likely to be made from wheat starch.

Science Class

You may be wondering why ingredients that may be made from wheat starch hydrolysates, such as caramel, dextrin, maltodextrin, and glucose syrup, are even an issue in celiac disease. Theoretically, these ingredients should not contain protein. However, because the starch and protein components of grain cannot be completely separated, some residual protein remains in the starch. Remember, this is why there is so much controversy surrounding the use of wheat starch.

However, because some ingredients that may be made from wheat starch hydrolysates—namely wheat-based glucose syrup and wheat-based maltodextrin—contain such small amounts of gluten, they have been exempted from having to be declared as allergenic ingredients on food labels in Europe by the European Food Safety Authority. Also, keep in mind that in the United States under FALCPA, if any ingredient made from wheat starch contains wheat protein, wheat must be declared on the label of an FDA-regulated food.

In addition, under the FDA's proposed ruling regarding use of the term gluten free on food labels, ingredients that have been processed to remove gluten, such as wheat starch, modified food starch made from wheat, and wheat starch hydrolysates, may be included as ingredients in foods labeled gluten free as long as their use in the food product does not result in the product having 20 parts per million or more gluten. So, while ingredients such as caramel, glucose syrup, and maltodextrin may be made from wheat starch hydrolysates, they may contain such small amounts of gluten that their use in a product still allows the product to be labeled gluten free.

Once the FDA ruling is finalized, you may see products labeled gluten free that contain wheat starch and wheat starch hydrolysates. If you wish to consume only wheat-free, gluten-free products, read the label, looking for the words wheat in the ingredient list and in the "Contains" statement. If wheat is not listed on the label of a gluten-free product, that product is free of wheat protein. Keep in mind, however, that if a product labeled gluten free does contain wheat starch or wheat starch hydrolysates, the product by definition contains less than 20 parts per million of gluten—a very small amount.

In My Opinion

In my opinion, if the only suspect ingredient(s) in a USDA-regulated food is maltodextrin, glucose syrup, or caramel, the food is safe for people with celiac disease to consume. Even if the source of the ingredient is wheat starch, the amount of gluten in the food product is likely very low. I would recommend continuing to avoid USDA-regulated foods containing the ingredients modified food starch and dextrin if the sources of these ingredients are not named (unless of course the product is labeled gluten free).

Barley Ingredients

FALCPA does not include barley, so it is important to be able to identify possible sources of "hidden" barley protein on food labels.

Some terms may be used on a food label in place of the word barley. If the label includes any of the following ingredients, the food contains barley unless the label states otherwise:

• Malt
• Malt syrup
• Malt extract
• Malt flavoring

Also, if an FDA-regulated food product contains the ingredients "natural flavor" or "caramel," there is a very small chance that these ingredients might be sources of barley. Also, there is a very small chance that if a USDA-regulated food product contains the ingredient "caramel," it might be a source of barley. It is important to note, however, that while malt may be used as a flavoring agent, it will most likely be listed as "malt flavoring" in the ingredient list and not included under the collective term flavoring. Caramel usually is not made from malt syrup; it is most likely made from corn.

Rye Ingredients

While FALCPA does not include rye, it is likely to be named in an ingredient list. It is possible that rye could be a "hidden" ingredient in a natural flavor of an FDA-regulated food. However, foods that would typically include rye flavoring (for example, bread products) are likely to be gluten-containing foods that you wouldn't be eating anyway.

Oat Ingredients

Products containing oats as an ingredient should not be eaten unless the product is from one of the manufacturers producing gluten-free oats.

Contacting Manufacturers

If after reading the food label you still have a question about whether a product is gluten free, contact the manufacturer and ask. An address, website, or phone number generally is provided on the packaging.