It is generally accepted that any food product which contains less than 20ppm of gluten (or 20mg/kg) can make a claim to be “gluten-free”. However, before we can agree what “gluten-free” really means, we first have to know what “gluten” is.
Gluten is a protein found in wheat, barley, and rye, plus any of these grains’ hybrid strains - such as farro, spelt, kamut and triticale – among others. As well as these grains, gluten can also be found in inherently gluten-free foods and ingredients such as oats. The way that oats are grown, harvested and processed leaves them very vulnerable to contamination from gluten-containing grains.
Other inherently gluten-free ingredients can become contaminated anywhere along the food production process via cross-contact (the ingredients being in direct physical contact) or cross-contamination (by indirect contact through shared equipment and utensils).
Of course, once you have navigated all of these potential minefields, a perfectly “clean” gluten-free product may become contaminated with a gluten-containing ingredient through direct addition – either intentionally or in error.
Some gluten-free certifications allow the intentional addition of gluten-containing ingredients, provided the finished product meets the regulatory threshold for gluten (usually <20ppm) in the country of sale. While this may seem like an acceptable approach, it can be problematic if an incorrect amount of the offending ingredient is added leading to an unsafe product. Although gluten detection test methods have shown significant improvement over the years, gluten can be a very tricky protein to detect as it does not easily evenly distribute. Gluten has the tendency to accumulate in “hot-spots” in certain matrices leading to false negatives.
We also need to consider the fact that not all of those who are intolerant to gluten have Celiac Disease. Those consumers will be far more likely to react to trace amounts of gluten in a gluten-free product than those who are gluten intolerant. For example, it is perfectly foreseeable for a person with Celiac Disease to have an adverse reaction to a product legally labelled gluten-free, but which has utilized the intentional addition method. If the intentionally added ingredient contains wheat, even trace amounts could make the individual sick.
It is for this reason that BRCGS’ Global Standard Gluten-Free does not allow the intentional addition of gluten in any products using any of its trademarks. The Standard does not consider any addition of gluten to be “safe” and it takes a management system approach to the control of gluten in sites which are certificated to the Standard. The long-term outcome of the Standard is to prevent failures that could harm the public. Correctly applied, a site’s gluten-free management system will provide a very strong level of protection from failure, and if failure does occur, it will enable the rapid identification and management of risks and deviations.
Products displaying any of the Standard’s trademarks at the point of purchase assist consumers by removing the stress of drilling down through a complicated list of ingredients that the manufacturer might have changed without warning, adding gluten to a previously trusted gluten-free product. Ultimately, consumers will benefit by having increased confidence in their purchases, wider availability, and variety of choice.