Shopping for safe gluten free products should have gotten easier after the FDA’s gluten free food labeling rule became final in 2014. As a celiac, I believe it has actually become more complicated in many ways to read food labels.
When I returned from speaking at The Food Allergy Blogger’s Conference in Denver, Colorado, I sat down to write this post. One of the sessions at which I spoke was about activism and advocacy, and I took the opportunity to encourage other bloggers to help educate their readers about how to choose safe gluten free products.
Mind you, this was an audience of food allergy bloggers — if anyone would be aware of how to shop for the safest products, it would be them. While we all agreed that buying products that are certified gluten free is ideal, not everyone knew how to tell the difference between those that are certified by an independent agency and those that are merely called gluten free by the manufacturers themselves.
It’s confusing stuff and I’ll tell you why.
FDA Gluten Free Food Labeling Regulations
Less Than 20 Parts Per Million Standard
The FDA gluten free food labeling regulations which we fought so hard for through 1in133.org went into effect in August, of 2014. Those regulations require any manufacturer who wishes to call their product is gluten free must also claim that the product contains less than 20 parts per million (ppm) gluten.
No Requirement to Test for Gluten
Oddly enough though, manufacturers are not required to actually test their products or to test in any particular way, with a set frequency or using a preferred testing method.
“May Contain Wheat” Statements / “Made in a Facility” Claims
Additionally, manufacturers can declare their products gluten-free even if they are produced in a facility with or on equipment with gluten. Manufacturers also may or may not choose to state that they are “made in a facility” or “made on equipment” with wheat. Either is acceptable. This means that you could be looking at identical products from two different manufacturers which were both made on equipment with wheat, both labeled gluten free, and only one says “made on equipment with wheat.”
You can start to see why gluten free food labeling is confusing, even after the regulations were put into place.
Not Gluten-Free Cheerios
We already have some very prominent examples of how these loopholes can hurt consumers. One you may be familiar with is General Mills’ iconic product, Cheerios®, which it has chosen to self-label as “Gluten Free” in the United States (it is no longer allowed to be labeled as “Gluten Free” in Canada).
At the end of this article is more information on Cheerios and why this product is not gluten-free enough, how thousands of consumers have been made sick by trusting this claim, and how General Mills has taken advantage of this labeling loophole to continue to market products to unsuspecting gluten free purchasers.
Gluten-Free Manufacturers Doing it Right Are Certified Gluten Free By Outside, Independent Agencies
Fortunately there are many companies at the other end of the spectrum which have chosen to subject their facilities and products to outside, independent gluten free certifying agencies. These agencies oversee these manufacturers, audit, and in some cases train them, test their products for gluten, and have recall authority over their products should too much gluten be found in them.
Independent, Third Party Gluten Free Certification Organizations
The definition of “certifier” is one who vouches for the authenticity of something. In the U.S., there are now SIX recognized independent certifiers of gluten free products.
These agencies test, audit, train and certify that products within their purview test to (at least) below 20 ppm gluten, the current FDA standard. They also have the ability to require their manufacturing customers order recalls or re-labeling if a product does not meet their testing standards. These assurances exist to protect gluten free consumers and to give them confidence in the safety of their certified products.
SHOPPING TIP: If you wish to buy products which have been independently tested by a third party, look for the words “CERTIFIED GLUTEN FREE” or “CERTIFICATION” and one of these symbols on the products you buy.
The 6 Independent Gluten Free Certifiers in the US:*
1) The Gluten Free Certification Organization – probably the most well-known of all the certifiers, currently uses a clear black and white “Certified Gluten Free” mark. The GFCO certifies tens of thousands of products in the U.S. and internationally. Requirements include gluten testing to less than 10 ppm gluten, even though the FDA only requires less than 20 ppm gluten. (Full disclosure: my gfJules products are all certified by the GFCO). The GFCO is changing its logo by 2022 (see below).
2) Kitchens with Confidence by MenuTrinfo – The leading food allergen and gluten free auditor for products, facilities & procedures certifies restaurants, kitchens, university dining halls, food manufacturers and products for food allergens and for gluten, specifically. Certifying to a level of 10 ppm or less gluten.
3) The National Celiac Association — formerly the Celiac Support Organization, this organization requires gluten testing to 5 ppm gluten, but in the past has also certified some products which are “gluten removed” like beers made with gluten ingredients, for which experts agree current testing is insufficient to read gluten levels accurately. As of 2019, NCA has ceded ownership of its certification program to the Gluten-Free Food Program and hence, changed its label (see below).
4) Beyond Celiac Gluten Free Certification Program — formerly National Foundation for Celiac Awareness has endorsed and partnered with the Canadian Gluten Free Certification Program. The program certifies hundreds of brands and thousands of products in Canada and the U.S.
5) NSF (National Sanitation Foundation) — offers a separate gluten free certification which tests products to less than 15 ppm gluten.
6) Scientific Certification Systems (SCS) certifies many things, including non-GMO and Organic. In 2021 they added gluten-free certifications to their quiver of independent reviews. They certify products to no more than 10ppm gluten.
Although each agency differs somewhat in their standards and applications, in general, these organizations all require end product testing, review ingredient sourcing, help develop employee training, and audit and inspect cleaning practices and cross-contamination controls throughout the entire manufacturing process to some degree.
**Note: if a product passes these agency testing protocols, it still MAY BE produced in a facility which also processes gluten — confusing, but still permitted.
*The International Certification Organization — now, Where Food Comes From Organic, also certifies gluten free as part of a bundle of certifications offered for operations that produce crops and livestock, or make organic products. It is unlikely that you will see this certification on finished consumer products.
Gluten Free Labels Which Do NOT Indicate Independent Certification and Testing
Do not be confused by other labels that may look like independent certifications. Here are some examples of symbols which DO NOT indicate independent certifications (these are “self designations” of gluten free status):
There was even a lawsuit filed in 2018 over the dispute caused by Bob’s Red Mill’s use of a gluten free logo that was alleged to be confusingly similar to the GFCO’s gluten free logo.
Products produced in dedicated gluten free facilities may indicate that fact on their packaging or on their company websites. This isolation goes a long way toward ensuring the gluten free status of the finished product, but I urge manufacturers to also require the raw ingredients for those products and their final gluten status to be tested independently and confirmed before being sold as gluten free, in order to ensure customer safety.
If you have any questions about the gluten free status of a particular product, contact that manufacturer directly and inquire as to their cross-contamination prevention procedures and what testing they do. And while you’re at it, encourage them to seek independent gluten free certification from one of the five organizations which offer these services in the U.S.
If the company truly wants to ensure the safety of their products for gluten free consumers, they should embrace the oversight, training, auditing and certification label they’ll receive for their products by being affiliated with one of these independent agencies.
*For more information on why gluten-free experts are not satisfied with General Mills’ current testing protocols for Cheerios boxes labeled “gluten free,” read The Gluten Free Watchdog.
To learn more about “mechanically separated” versus “purity protocol” oats, listen to this “You Had Me At Eat” free podcast.
Example: Why Cheerios Cereal is NOT Gluten Free Enough, Despite its Label
General Mills® announced in 2015 that certain varieties of Cheerios would be made using oats that would be mechanically separated to reduce the amount of gluten-containing grains contaminating the batch (rather than using oats grown, harvested and packaged using the “purity protocol“).*
They claimed that each batch would be tested in-house, but the method they used for testing combined multiple boxes which were then ground and the “lot mean” was tested, rather than testing individual boxes for hot spots of contamination.
A Change.org petition was started by some passionate gluten-free bloggers who were afraid for the health of those in the gluten free community who were trusting in the safety of these General Mills products. The flawed testing protocols and the fact that “pure” gluten-free oats were not being used caused great concern to many who had taken the time to look deeper into how General Mills was producing this product.
Gluten-Free Watchdog became involved and together, the voices of concern began to be heard above General Mills’ corporate messaging. Sadly, gluten-free people around the country began to report that they had been made sick by “gluten free” Cheerios.*
Then in October, 2015 General Mills disclosed that its Lodi, California plant had failed to test any of the lots of “gluten free” Cheerios for a period of 13 days. During this period, the oats had also been transported in containers which had been used for wheat, so the oats were further contaminated — a situation General Mills was unaware of until customer complaints lodged with the Gluten Free Watchdog and later with the FDA brought it to their attention, necessitating a recall of 1.8 million boxes produced during that 13 day period.
The remaining “gluten free” labeled Cheerios are still on store shelves despite numerous reports of illness, but unless and until it is proved that General Mills has actually produced other individual boxes sold as “gluten free” that contain over 20 ppm gluten, General Mills is still technically in compliance with the FDA rule. Safe for celiacs? Worth risking your health for? You be the judge.
Gluten in Cheerios Update: July 2017:
Reports of illness from Cheerios continue to stream in to the FDA. Buzzfeed filed a Freedom of Information Request and reported on the claims which are still being made by celiacs and others who say they’ve been sickened by Cheerios. Jocelyn Silvester, a physician at Boston Children’s Hospital, says that her team recommends patients with celiac disease avoid products made with mechanically-optically separated oats, noting that it remains unclear whether any given product is safe and there is no reliable tool to find out for sure.
*And in case you’re wondering, Cheerios isn’t the only brand using this type of mechanical sorting of oats. Quaker® has now released a line of “gluten free” oats and other sellers of oats labeled as “gluten free” also utilize this method to remove gluten-containing grains from oats not grown according to the purity protocol. Unless the brand is listed in this list compiled by the Gluten Free Watchdog, it is not using pure oats for its “gluten free” oats.
Gluten in Cheerios Update 2018:
The Canadian Celiac Association released this news: “The Canadian Food Inspection Agency (CFIA) has made an announcement that the words “gluten-free” will be removed from all Cheerios package sold in Canada by January 1, 2018.” However, General Mills has said it will not remove any boxes currently labeled gluten-free; it will not label Cheerios as gluten-free with replenishment of stock.
Melissa Secord, Executive Director of the Canadian Celiac Association elaborated, “Based on the advice of the members of our Professional Advisory Board, the experts of the Gluten-Free Certification Program, and other professionals working in the field, we believe that there is not adequate evidence to support the claim. When added to many reports from consumers with celiac disease reacting to eating the cereal, we believe this is the safe recommendation for Canadians.”
We can only hope that the FDA follows suit so that Cheerios sold in the U.S. will no longer be labeled gluten-free, but it will only happen if they hear from enough consumers to merit the change. To date, the FDA has made no comment or hint that it will follow the Canadians on this course of action.
2021 Update:
General Mills is still using mean test results from a composite sample made up of sub samples taken from 12 to 18 boxes of cereal to determine if a “lot” — a 24 hour production cycle — is gluten-free. Using this testing method, if high results are found, General Mills has no idea which box is to blame and “hot spots” are not accounted for.
For more information on why gluten-free experts are not satisfied with General Mills’ current testing protocols for Cheerios boxes labeled “gluten free,” go to The Gluten Free Watchdog.
In Conclusion …
READ EVERY LABEL, EVERY TIME.
Labels change, ingredients change, and you can never be certain there isn’t gluten lurking in strange places. Here’s an example of gluten found in cooking oil spray.
And, whenever possible, choose products that are certified gluten free by an independent organization.
Beyond that, with regard to oats, know that oats are an inherently risky gluten free ingredient. If not using purity protocol gluten free oats, the product is likely to contain too high a gluten content, at least in hot spots.
Without an independent certifying agency, manufacturers are free to test or not test, recall or not recall, report problems or not … on their own timelines. Yes, they are subject to FDA oversight, but we’ve already seen far too many examples of the FDA either not acting with the authority they’ve been given or being too slow to do so.
If General Mills had instead subjected its products to an independent third party certifier, each batch of product have been tested according to more stringent protocols. Such testing would have avoided at least the Lodi disaster, but also the potential for other contaminated boxes to be released into the market because of the lot mean testing methods currently used.
There would also have been an immediate examination of methods, testing and ingredients upon receipt of customer complaints, and a recall could have been ordered more quickly, sparing people from illness.
No system is perfect, but by using one of the 6 independent certifying agencies currently in the U.S., Cheerios (and any other product claiming to be gluten free) would be much more likely to be truly gluten free and therefore safe for those adhering to a gluten free diet.
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