Gluten or no gluten: an ingredients dilemma

The Food and Drink Federation (FDF) - the 'voice of the food and drink industry' - have published a new guide today called Gluten Labelling Best Practice. It is in partnership with Coeliac UK, among others.

I'm not sure why this has appeared now, six months following the introduction of EU regulation 1169/2011 in December. The press release accompanying the launch says its aim is to 'support food manufacturers on the labelling of food products containing gluten', but I can speculate that it is required because a number of those manufacturers have been getting it wrong. This isn't surprising, because allergen labelling is complicated; indeed, the release talks of illustrating some examples of 'the more challenging labelling situations of gluten-containing foods'.

One of the contentious issues covered concerns the appearance of the word 'gluten' in the list of ingredients. As we know from the regulations, it is the name of the gluten grain which should be listed and highlighted when either wheat, rye, barley or oats or their derivatives are ingredients in the product. Should 'gluten' appear alongside these? It can, but in their guide the FDF advise that it shouldn't.

"... best practice is not to include the word gluten in parentheses but to solely emphasise the name of the cereal in the ingredients list. The consistent application of this particular best practice is to be recommended, as this would ensure consumer understanding by encouraging the reading of the ingredients list for the presence of the specific gluten-containing cereal. This in turn reduces the risk to individuals looking for the word “gluten”, which may not be listed."

In at least one respect, this does make sense. There is no argument for naming the allergenic protein fractions in other food allergens - such as "milk (casein)" or "egg (ovoalbumin)" - on food ingredient lists, and so for consistency, it seems logical to do likewise with respect to gluten grains. 

But as has been pointed out to me by a number of coeliacs, while coeliacs themselves will know that barley and rye contain gluten - relatives of coeliacs may not. 'Gluten' is the alarm word for such shoppers to look out for, and in its absence, mistakes might more easily be made. 

That it is essentially optional is not ideal, as it discourages the consistency which the FDF clearly find desirable. I'd like to see a decision made at EU level on whether gluten should or shouldn't appear, and be absorbed into labelling law.

That said, I can see some difficulties with including 'gluten', as (I imagine) most coeliacs would prefer. 

Take the ingredient 'barley malt flavouring', in a jar of chutney. Barley malt flavouring contains a small amount of gluten, but if no other gluten-containing ingredient is present in the chutney, the product may well be able to make an overall 'gluten free' claim. So should the ingredient appear as 'barley malt flavouring (gluten)' or 'barley malt flavouring', in this case? The first would surely confuse both coeliacs and their relatives, if appearing on a gluten free product, and yet that would be correct, under a system where gluten-containing ingredients are labelled with the word gluten. This sort of scenario would have to be covered in any legislation - perhaps with exceptions made, further complicating an already complicated area of law - and perhaps that is why the issue has not been tackled.

I'm only 60:40, but on balance, because of it, I do feel that the FDF best practice advice is probably better. Coeliacs need to look for wheat, barley, rye and oats, like nut allergics need to look for almond, walnut, cashew and the rest - and 'train' loved ones to do likewise. If it's any consolation, I suspect many manufacturers will continue to add 'gluten', and if you feel strongly about it, it's perhaps worth telling them you're happy for them to continue to do so. 

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