Q: I am so confused about food labeling. Is it ok to consume something that just says gluten free and therefore being under 20ppm? Are we supposed to buy just strictly certified gluten free products?
Food labeling can definitely be confusing when it comes to determining if a food is gluten-free. If a food is labeled gluten-free it has to contain less than 20 ppm gluten to adhere to the FDA requirements.
- The FDA requires foods that are labeled gluten-free to contain less than 20 ppm of gluten.
- Gluten-free labeling is voluntary. Food manufacturers are not required to indicate all sources of gluten on the label, or indicate gluten-free status.
- The FDA is not mandating the use of a specific gluten-free label, so gluten-free labeling can vary from product to product. 1,2
Which foods can be labeled gluten-free?
- Foods that are naturally GF
- Foods that contain gluten grains i.e. wheat starch, but have had the gluten removed to below 20 ppm.
- Foods that do not contain more than 20 ppm of gluten
AND any unavoidable gluten in the food due to cross-contact or migration of gluten from packaging material must be less than 20 ppm gluten.1, 2
Gluten-free certification is different from gluten-free labeling and is done by an independent third-party organization. They have to follow the same or stricter requirements than the FDA. They vary in requirements, but most do not require testing of every batch. There are several different certifiers available on the market.
In general, you should be safe eating products labeled gluten-free. In a study where 275 foods labeled gluten-free were tested, 1.1% of them were found to contain more than 20 ppm gluten, so 98.9% tested gluten-free. Among foods that were not labeled gluten-free but had no gluten ingredients, 19.4% contained more than 20 ppm gluten and 10.2% contained more than 100 ppm gluten.3
Take home message: It is relatively safe to consume store bought products labeled gluten-free, but those not labeled gluten-free have a significantly higher risk of containing gluten.
However, I want to note that an exception to that are oats. Many sources of oats, even those labeled gluten-free, have had cross-contact with gluten. NCA recommends consuming oats that use the "purity protocol" (have been grown, harvested, transported and processed gluten-free). However, many manufacturers now use mechanically or optically sorted oats to render them gluten-free. Unfortunately, there is a much higher chance that some batches may end up with high levels of gluten with this method.
You can read more about our position statement on oats here:
Here is a link to a list of purity protocol oats:
- US Food and Drug Administration (FDA). Questions & Answers: Gluten-Free Food Labeling Final Rule. FDA Website: https://www.fda.gov/food/food-labeling-nutrition/questions-and-answers-gluten-free-food-labeling-final-rule . Accessed on May 29, 2019.
- National Celiac Association. Gluten-Free, Off to A Fresh Start. Presentation. May 4, 2018.
- Sharma GM, Pereira M, Williams KM. Gluten detection in foods available in the United States - a market survey. Food Chem. 2015;15(169):120-126
Note: This information is provided by NCA and Melinda Dennis, NCA's Senior Consulting Dietitian. This information is meant for educational purposes and is not intended to substitute for personalized medical advice or replace any medical advice provided directly to you by your health care provider. This information can be printed and used in consultation with your physician or dietitian. No liability is assumed by NCA, Ms. Dennis or her nutrition consulting service Delete the Wheat, LLC. by providing this information.