How Voluntary Advisory Statements Can Cause Confusion

Consumers who are allergic to food which contains gluten usually rely on gluten-free certifications. Those certifications ensure that consuming these products would not cause any harm. However, it happens quite often that consumers find gluten-free labelled products in combination with a voluntary advisory statement which says "May Contain Wheat". Therefore, it is not surprising that many consumers feel insecure about which products they can or cannot consume. The question is: Why does confusion like this exist making both consumers and retailers feel insecure?

Life has never been easy for people who suffer from allergies or intolerances. Living with restrictions on what you can eat is common and often unavoidable. For example, people with Celiac disease have to make sure that gluten is not an ingredient of the food they consume. However, gluten is a protein which is usually an ingredient in common foods like bread, cake or pasta. In the past, products were not as well labelled as they are today. Many people with a Celiac disease didn't know what kind of food they are able to consume or what implications eating the food may have. Nowadays gluten-free labeling helps consumers to find safe products. Moreover, the food industry has responded as well: The number of gluten-free products available increases year on year. But there is still confusion sometimes.

Products which are labelled as gluten-free may contain a voluntary advisory statement which says "May Contain Wheat". Since wheat is both an allergen and a source of gluten it doesn't imply that every product which contains wheat also contains gluten. However, at a first sight many consumers may expect by reading this label that gluten is an ingredient. The Food Allergen Labeling and Consumer Protection Act (FALCPA) determines that wheat must be marked by its name whenever any kind of wheat is present. This includes gluten-free wheat as well. In 2013 the U.S. Food and Drug Administration (FDA) issued a final rule defining the term "gluten-free" for voluntary use in the labeling of foods to improve food safety. This rule states that food is inherently gluten free and does not contain an ingredient that is

  • A gluten-containing grain (e.g., spelt wheat)
  • Derived from a gluten-containing grain that has not been processed to remove gluten (e.g., wheat flour)
  • Derived from a gluten-containing grain that has been processed to remove gluten (e.g., wheat starch), if the use of that ingredient results in the presence of 20 parts per million (ppm) or more gluten in the food
  • Any unavoidable presence of gluten in the food must be less than 20 ppm

Manufacturers who choose to use this gluten-free labeling must make sure that consumers recognize at first sight which products are safe for them. However, this label is just voluntary. There are still many manufacturers who do not use a gluten-free label and consumers are forced to read labels carefully. Having a look on the ingredients list should clarify which ingredients contain gluten and which do not. It is important to know that some ingredients like wheat do not necessarily contain gluten. Therefore, consumers have to know which grains are gluten-free and which are not - For example rice, corn, soy or potatoes do not contain any gluten. Grains which people with a celiac disease should avoid are among others - wheat bran, rye or cracked wheat.

In conclusion, manufacturers should be aware that voluntary advisory statements like "May contain wheat" may create confusion more than helping consumers to choose safe products. It is therefore necessary that manufacturers focus on clear labelling and transparency to avoid causing confusion.

References:

https://www.foodsafetymagazine.com/magazine-archive1/december-2017january-2018/striving-for-transparency-resolving-the-conflict-between-gluten-free-labeling-and-precautionary-allergen-labeling

https://www.bobsredmill.com/blog/special-diets/comprehensive-list-gluten-free-foods/

https://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/Allergens/ucm106890.htm

https://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/Allergens/ucm577489.htm

https://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/Allergens/ucm362880.htm

https://celiac.org/live-gluten-free/glutenfreediet/label-reading/