Email from Sue Cane, coeliac, FreeFrom Food Awards judge and and organiser of the beer judging for the awards:
I am doing some research on Marmite as it’s one of those products which is anecdotally gf but I’m convinced isn’t. During my digging, I have been told by the FSA (Food Standards Agency), that one cannot assume a product is gluten free simply because there is no gluten in the ingredients. Did you know this?
It’s an interesting take on things isn’t it? It sort of turns everything upside down – and polarises the market – ordinary foods and dedicated gf foods. Not to mention undermining all the good work the supermarkets are doing in removing gluten from standard products that don’t really need it so as to broaden the range for those on gluten-free diets.
Interesting that the official FSA position on gluten-free shopping is probably the polar opposite of what the consumer thinks. Were you aware of this?
Well, yes I was….
Since the regulation defining ‘gluten-free’ as less than 20 parts per million of gluten came into force last January, the FSA have to say that as, if a products has not been tested and proved to have less that 20ppm of gluten it cannot be called ‘gluten free’! Practically speaking of course, there are hundreds, probably thousands of products which are effectively gluten free because they do not have any gluten-carrying ingredients but…. There is nothing to stop any of these products getting contaminated with gluten somewhere along the supply line or during the process of manufacture, especially if they are made in a factory which also makes gluten-containing products. Although the risk of them doing so is also pretty-to-very small.
Back in the day, if a product didn’t have any gluten in the ingredients (eg deliberately added) then it was assumed that it was gluten free. But since the new regulations came in everyone has got a lot fussier/more paranoid/more careful/more responsible – depending on how you look at it. So nowadays, if a manufacturer cannot guarantee that there is less than 20ppm (which could be caused by accidental contamination anywhere along the line) they are not prepared to claim gluten free – and this is obviously the stance taken by the FSA.
But, as far as the supermarkets and manufacturers in general are concerned, they are not only targeting coeliacs to whom this matters, but the ‘voluntary food restricters – in fact, it could be said that they are principally targeting ‘voluntary food restricters’ as there is where the main growth in the market is coming from. As far as this group is concerned, they are not gluten sensitive, they merely prefer to eat gluten-free foods. Contamination is really not an issue for them so they will be very happy to buy foods which are ‘gluten free’ in as much as they contain no gluten-carrying ingredients, but are not ‘gluten-free’ as now understood by the FSA and the regulators.
Does that make sense?
Yes, I agree the risk is small. In fact it probably varies from almost no risk at all at one end of the spectrum to, as you put it, quite-to-very small, but it’s interesting looking at it from this perspective rather than my normal one – which is no risk unless there’s gluten in the ingredients. And it was a bit weird to see this quote from the FSA, which logical as it is, is surely opposite to what most consumers believe.
I don’t think much has really changed in terms of the way ordinary products are manufactured. In fact there’s probably LESS risk of contamination etc now because of ‘good practice’ etc but it just means that manufacturers have to either go the whole hog and market products specifically for the gf market… or not. And that’s why we have the confusing situation where some products which are not listed in the coeliac directory (because they’re not marketed for people with gluten intolerance) are still deemed by the manufacturers to be gluten free.
You can tell there’s a lot of confusion here because of the number of times the same questions come up on message boards about it.
For interest I have just gone through what I’ve eaten today and only a small fraction of it is food that’s been made for people with gluten intolerance. And what’s interesting is that, as a reasonably savvy coeliac, I would have sworn that the law on labelling meant that everything I’ve eaten with no gluten in the ingredients MUST be gluten free. But I’m wrong.
But I’m also right in that this food IS safe to eat, despite the FSA’s scary statement. So we can, and do, trust food labelling. Particularly that of the big supermarkets who have really got their act together big-time in the labelling dept.
However, it worries me that as a result of the FSA assertion that you cannot assume a food is gluten free just because it doesn’t contain any gluten in the ingredients means the market will now split in two? Will the supermarkets making lifestyle gluten-free stuff (eg stuff which just does not contain any gluten in the ingredients) stop bothering about coeliacs and truly gluten-free free foods that are guaranteed to contain less than 20 ppm of gluten? It would drive a wedge through what we currently understand the classification of safe food to be and it would mean that cheaper, readily available non-specialist gluten-free food would cease to be suitable for coeliacs.
To which I said:
I don’t think that the supermarkets are likely to abandon their ‘freefrom’ ranges at this point. They have invested far too much in them and anyhow, ‘freefrom’ is good PR for them – shows them as loving, caring people which, to be fair, many of the people who work in freefrom genuinely are. And the ‘freefrom’ ranges will always have to comply with the ‘reg.s’ to be able to called themselves ‘gluten free’ so super sensitive/concerned coeliacs can stick with those.
As far as products that do not contain any gluten in their ingredients are concerned coeliacs/gluten intolerants will be in the same situation as they were before – eating products with no gluten in the ingredients without any awareness of the contamination issues. The only difference is that now they will be aware of what they are doing, and the low risk that they are taking, whereas before they were not.