Yesterday we finished the judging for this year’s FreeFrom Food Awards. Over 500 products judged over three weeks by 57 different judges – and that’s not counting 10 children!! (The shortlist will be out next week so keep an eye on the awards site.) Here are some of the Store Cupboard entries lined up in the store rooms waiting for their moment in the sun.
Some really excellent products entered – we all thoroughly enjoyed ourselves – and now feel distinctly fatter than we did three weeks ago!!
However, the judging was not without its moments of disagreement – not, normally, about winners but about the ever-fraught topic of labelling. What do precautionary ‘may contain’ warnings actually mean (a topic for a different blog…) – and what about oats? How should they appear in an ingredients list? How indeed!! And how should an oat-sensitive coeliac ‘read’ them?
In an attempt to elucidate this for one of our entrants I have just written the following. Do not attempt to read unless you have had at least two cups of coffee and are feeling very ‘switched in’….
How should oats be listed in an ingredients list?
The regulations state that:
‘You need to tell your customers if any food products you sell or provide contain any of the main 14 allergens as an ingredient. The 14 allergens are:’
- ‘Cereals containing gluten – including wheat (such as spelt and Khorasan), rye, barley and oats’
- Crustaceans such as prawns, crab and lobsters
- Eggs’ etc etc down to Sulphites
But…. gluten is not, technically, an allergen.
Gluten is a protein, made up of, in the case of wheat, barley and rye, the elements gliadin and glutenin; in the case oats of it is made up of avenins. An allergen is a type of antigen or structural molecule.
So the regulation is confusing from the start.
Of course, wheat, barley, rye and oats can also be antigens (allergens) and it is perfectly possible for someone to have a genuine allergic reaction to eating them. But they are not included in the list in their own right as potential allergens as only relatively few people have allergic reactions to them; they are included because they contain gluten.
Contradictory though this may seem, one can see why the regulations were phrased this way.
- Gluten is what is relevant to coeliacs.
- Coeliacs make up a very significant proportion of the allergic or food sensitive population that these regulations are trying to help – although of course coeliac disease is not an allergy but an autoimmune condition.
- So it made total sense to include gluten in the list of ingredients that needed to be highlighted.
- But once you drill down into the list for labelling purposes, because gluten and allergens are not the same thing, then whole thing becomes confusing and self contradictory.
However, what it means for the manufacturer is that, in order to abide strictly by the regulations, you need to highlight/bold ‘oats’ in your ingredients list, even when they are gluten free oats.
Unfortunately, this will probably just confuse the poor coeliac consumer who may worry that, because they have been highlighted, they are actually an allergen and therefore not safe for them……
Gluten free oats
As long as you are using gluten-free oats, then, according to the regulations, the product can be flagged as gluten free (eg under 20 parts per million of gluten) whether you specify that the oats are gluten free or not.
However, this is even more confusing for the consumer who doesn’t know about this aspect of the regulation. Therefore oat-tolerant coeliacs worry that if the oats in the ingredients do not state that they are gluten free, even if the overall declaration is gluten free, then the oats might not be.
So we would always advise any manufacturer to say ‘gluten-free oats’/’gluten-free oat flour’ etc whenever oats are mentioned in the ingredients.
In this context it is even more confusing for the consumer if an ingredients list contains both oats and oat flour and one is flagged as gluten free and other is not. Even if all the oats in the product actually are gluten free the oat tolerant coeliac may be, understandably, confused.
Have you followed me so far? If so, congratulations. And you can see why I do not feel strong enough to embark on the subject of ‘may contain’ labelling right now….