One of the most critical skills a person with celiac disease or gluten intolerance can master is label reading. In this article, I’ll explain the current gluten-free labeling laws and how to decode if a product is gluten-free. This article applies to food labeling standards in the U.S. only. Please read my disclosures.
Three million people in the U.S. have celiac disease, a genetic autoimmune disease that damages the small intestine, an organ responsible for absorbing and distributing nutrients from food to every cell and organ in the body.
Another 18 million people in the U.S. suffer from non-celiac gluten sensitivity or gluten intolerance, which causes inflammation in the small intestine and can lead to various autoimmune and metabolic diseases depending on where the weak link is in a person’s chain.
Understanding gluten-free labeling laws is one of the most critical skills a gluten-free person can develop. There is a lot to learn, understand, and decode when figuring out a product’s safety, and it can be an overwhelming and frustrating experience regardless if someone is new to the gluten-free diet or has been gluten-free for decades!
In this article, I detail everything a person needs to know about the FDA’s gluten-free labeling guidelines, the difference between “gluten-free” and “certified gluten-free,” how to decode confusing “may contain” statements, and what red flag ingredients people with gluten disorders should avoid.
Tip: Watch the following webinar: How to Decode Food Labels for Hidden Gluten.
What the FDA Says about Gluten-Free Labeling
On August 2, 2013, the U.S. Food and Drug Administration (FDA) set forth guidelines for food manufacturers to use when making products they claim as “gluten-free.”
These guidelines help to not only define what “gluten-free” means but also set forth uniform standards that are “truthful” and “accurate” for people living with celiac disease.
While the FDA says these guidelines are voluntary, and food manufacturers must regulate themselves to ensure accurate claims, the guidelines offer much-needed protection to the celiac disease and gluten-intolerant communities.
Below is what the FDA gluten-free guidelines say:
(1) A product labeled “gluten-free,” “no gluten,” “free of gluten,” or “without gluten” means that the product does not contain any gluten-containing grains (wheat, barley, rye) or any ingredients derived from gluten grains (i.e., wheat flour or barley malt). Please note the guidelines don’t mention oats, which are notoriously cross-contaminated with wheat. Please read: Are Oats Gluten Free? Unpacking Confusing and Contradictory Information.
(2) A “gluten-free” labeled product must contain less than 20 parts per million (ppm) of gluten to include the “gluten-free” claim on its packaging. This tiny amount of gluten is what the FDA has deemed to be a safe amount of gluten for someone with celiac disease to consume without causing an autoimmune reaction. Concerned that 20 ppm gluten threshold isn’t enough? Read, Is the FDA’s 20 ppm Gluten Threshold Enough?
(3) If an ingredient derived from a gluten-containing grain has been processed to remove the gluten protein, such as wheat starch, it can be labeled “gluten-free” only if the final product verifiably contains less than 20 ppm of gluten.
(4) A food labeled “gluten-free” and whose label includes the term “wheat” in the ingredient list or bears a separate “contains wheat” statement (more on contains statements next) must also include clarifying language that explains that the wheat has been removed and that the final product contains less than 20 ppm of gluten.
Please note that the FDA guidelines cover all food and beverages except for meat and poultry, which is regulated by the USDA, and alcohol, which is regulated by the Alcohol and Tobacco Tax and Trade Bureau. (Read Answers to 11 Common Questions about Alcohol and the Gluten-Free Diet.)
Gluten-Free vs. Certified Gluten Free
A product can be labeled “gluten-free” if it meets the above criteria set forth by the FDA. However, many products take it a step further by becoming “certified gluten-free.” If a product is certified gluten-free, it means a third-party certifying agency has verified that it meets the FDA’s gluten-free labeling guidelines.
Certifying agencies include the most widely used certification agency, the Gluten-Free Certification Organization (GFCO), and also include certification programs from Beyond Celiac, The National Celiac Disease Association, and NSF International. Many of these agencies require products to contain less than ten ppm of gluten vs. 20 ppm of gluten as set forth by the FDA.
The following image shows the logos designed by the various gluten-free certifying agencies. In 2020, the GFCO created a more distinct logo, changing from the widely used GF in a circle to its current squiggly purple “g.” The agency did this because the circle logo was often mistaken as a generic gluten-free label.
While food manufacturers pay for third-party certification, such labels offer good ROI. In fact, products that bear these logos instill consumer trust and confidence and make it easier for people following a gluten-free diet to shop for groceries and quickly identify safe products.
Understanding “May Contain” Statements
The Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA) requires food manufacturers to clearly disclose if their products contain any of the top eight food allergens, which include:
- Milk
- Eggs
- Fish
- Shellfish (crustaceans)
- Tree nuts
- Peanuts
- Wheat
- Soy
If, for example, a product contains food starch, and that food starch is derived from wheat, a company is required to list wheat in or below the ingredient label.
For example, an ingredient label might say “food starch (wheat)” inside the ingredient listing, or it’ll include a disclosure below the ingredient list saying, “Contains wheat.”
While a product may not outright contain one of these eight allergens, food manufacturers sometimes add precautionary statements to their food labels. These precautionary statements usually look like the following:
- “May contain wheat.”
- “Manufactured in a facility that uses wheat ingredients.”
- “Manufactured in a facility which process.es wheat.”
- “Processed in a facility that us.es wheat.”
- “Manufactured on equipment that processes products containing wheat.”
- “Manufactured on equipment that uses wheat.”
- “Manufactured in a facility that processes wheat, but not on the same equipment.”
- “Manufactured on shared equipment with products that contain wheat.”
Keep in mind that while wheat is considered an allergen, gluten is not. This means products can be wheat-free but not gluten-free. Barley or rye are wheat-free, but they contain gluten.
Precautionary statements are incredibly confusing and leave many people in the gluten-free community scratching their heads.
I approach precautionary labels using common sense. Please keep in mind that my comfort level may differ from the comfort level of others. I offer this information to provide perspective on how to can approach confusing precautionary statements.
- I avoid all products that bear the disclosure, “May contain wheat,” unless the product is labeled or certified gluten-free. For example, if a product contains gluten-free wheat starch, I know the product is gluten-free. Keep in mind that people with gluten intolerance (not celiac disease) may react to various components of wheat, not just gluten, and therefore should cautiously eat products containing gluten-free wheat starch. For more details, read The Truth about Gluten-Free Wheat Starch.
- I generally avoid products with the disclosure, “Manufactured on shared equipment with products that contain wheat.” The risk of wheat exposure is low because manufacturing equipment is cleaned between runs; I typically skip the product altogether because the risk doesn’t outweigh the reward.
- When I see the claim, “Manufactured in the same facility as wheat,” and the product does not contain any other gluten-containing grains, I feel comfortable eating that product. I may even contact the manufacturer to better understand the disclosure.
How to Decode Confusing Ingredients
While it’s great that food manufacturers label their products as “gluten-free,” still many manufacturers do not. Gluten-free labeling is voluntary, so each food manufacturer decides if it wants to test and label its products as “gluten-free.” Some do, and some don’t.
When a product doesn’t contain overt gluten in the form of wheat, rye, barley, or oats, the decision to trust that product is up to the consumer. And this is where things can get dicey.
Many ingredients on food labels are confusing, including maltodextrin, yeast extract, modified food starch, gelatin, MSG, natural flavors, vinegar, and more. I’ve written extensively about these confusing ingredients in my article, 20 Confusing Ingredients that May Contain Hidden Gluten, which I highly recommend reading.
Be cautious about eating products when ingredient sources are unknown. Many of these products are gluten-free, but it can be hard to fully decipher which are and which aren’t.
Tip! A great way to quickly scan a food label for questionable ingredients is to use the Fig Food Scanning App. This app will scan the UPC of a product and highlight ingredients that require further research.
Shop Smartly
Decoding a food label for hidden gluten is one of the best skills a person with a gluten disorder can learn and hone over time. I’ve been on a gluten-free diet for ten years and still have to research ingredient labels and questionable ingredients.
To make grocery shopping more bearable, I recommend the following as a rule of thumb:
(1) Shop for Certified Gluten-Free Products: Certified gluten-free products will always be the safest bet at the grocery store. These food manufacturers have invested the time and resources to create safe products, and the community should feel comfortable and proud supporting the brands that support them.
(2) Trust “Gluten-Free” Claims: When a product bears a gluten-free claim on its label, it means the product meets the FDA’s gluten-free labeling guidelines. Remember, even gluten-free products can contain trace amounts of gluten, and of course, some food manufacturers aren’t always truthful, and such products should be reported to the FDA. Also, be sure to read, Is the FDA’s 20 ppm Gluten Threshold Enough? to better understand how a product can contain trace amounts of gluten (and it’s okay that it does).
(3) Read Ingredient Labels Carefully: The most accurate and latest information about a product’s ingredients will always be on the label itself. Look for clues to decode and decide if a product contains gluten. The Fig Scanner App can help. Remember, product formulation and ingredient labels change constantly, so never get too cozy with a product. Read my list of formerly gluten-free products that now contain gluten.
(4) Contact the Manufacturer: If it’s unclear if a product is safe, contact the manufacturer and ask questions. If enough people ask questions, the manufacturer might take a hint and actually make the effort to test and label its products as “gluten-free.” However, many manufacturers cannot (or will not) say for sure if their product is gluten-free because they haven’t tested it to verify it meets the FDA’s gluten-free labeling guidelines.
(5) When in Doubt, Don’t: There is almost always a gluten-free substitute for a product, so shop wisely. When unsure if a product is safe to eat, the best course of action is to put it back on the shelf.
(6) Money Talks: I encourage the gluten-free community to support brands that support them by shopping for products labeled gluten-free or certified gluten-free. Supporting brands that make gluten-free products is a way the community can speak loud and clear with their wallets. When a brand knows they can make more money by labeling their products “gluten-free,” more will take the time and resources to test and label their products as such.
Additional Reading
- Is the FDA’s 20 ppm Gluten Threshold Enough?
- 5 Hidden Sources of Gluten at the Grocery Store
- Is European Wheat More Tolerable than U.S. Wheat?
- Wheat Free vs. Gluten Free – What’s the Difference?
- Is PBfit Gluten Free? Maybe Not
- Is Sprouted Wheat [Bread] Gluten Free?
- What You Need to Know About Nima Sensor Before You Buy