Cartoon by Sam Hockstra
Gluten-free has spread like wildfire. In hot pursuit of sales, brand owners are jumping on the bandwagon and gluten-free products appear to have taken over the grocery aisles.
Through participation in Canadian Celiac Association (CCA) conferences, I have learned a great deal about the gluten problem and, as a result, am concerned about the reliability of gluten-free claims.
In conversations with food processors and brand owners who make gluten-free claims, it is clear that many do not understand the risks behind manufacturing gluten-free products in compliance with Health Canada regulations. They do not know what they do not know. And that puts their brand and customers at risk.
The Regulations
In Canada, gluten-free foods are classified as “Foods for Special Dietary Use”. Section B.24.018. of the Food and Drug Regulations states: “It is prohibited to label, package, sell or advertise a food in a manner likely to create an impression that it is a gluten-free food if the food contains any gluten protein or modified gluten protein, including any gluten protein fraction, referred to in the definition “gluten”… ”
They go on to define “gluten” as:
“(a) any gluten protein from the grain of any of the following cereals or the grain of a hybridized strain created from at least one of the following cereals: barley, oats, rye, triticale, or wheat, kamut or spelt; or
(b) any modified gluten protein, including any gluten protein fraction, that is derived from the grain of any of the cereals referred to in subparagraphs [above] or the grain of a hybridized strain referred to in paragraph (a).”
Oats Not Allowed
In Canada, regular oats do not meet the requirements for a gluten-free claim. Health Canada regulations only permit a gluten-free claim for foods containing gluten-free oats “that do not contain more than 20 parts per million (ppm) of gluten from wheat, rye, barley, or their hybridized strains.” These are specially produced oats sometimes marketed as “pure uncontaminated oats”.
Gluten Threshold
Health Canada’s rules do not specify the threshold for gluten. For that, we must look to the CFIA (Canadian Food Inspection Agency) who is responsible for enforcement. When making a gluten-free claim on a product, its gluten content must be LESS THAN 20 ppm (parts per million). To help you visualize how minute this is, consider the following example: a typical flat screen TV has 2 million pixels; 20 ppm is equivalent to only 40 pixels. That’s a scary thought for anyone with celiac disease.
The Watch-Out
Contrary to popular belief, just because a food does not inherently contain gluten, like rice for example, does not mean it is gluten free. Here’s why:
#1. Cross-contamination can come from anywhere in the supply chain, from the field to the fork.
Major risk areas include raw ingredients, manufacturing facilities, packaging, transportation and storage. Take a look at our grain handling system. Wheat and other grains are stored in the same elevators and transported in the same trucks, unless they are handled by grain companies certified under the Canadian Identity Preserved Recognition System (CIPRS).
#2. Common ingredients used in food processing, such as additives, seasonings and sauces, can be hidden sources of gluten. Even packaging materials and adhesives may contain gluten.
What are the risks?
- Subjecting your customers to illness.
- Your product could be the cause of a costly recall that will spread through the supply chain. CFIA tests products labelled as “gluten free”. Those with 20 or more ppm of gluten could be recalled. That means paying the costs of withdrawing the product from the market, designing and printing new labels, re-labelling, re-distribution, reimbursing retailers, paying penalties and losing sales in the meantime. Is it worth the risk?
- Negative publicity can damage a brand’s reputation, erode customer trust and ultimately result in lost sales.
How can “less than 20 ppm” be detected?
There are a number of scientific tests to detect the presence of gluten. But, according to medical doctors speaking at the CCA conference, these tests are not 100% reliable.
How do consumers know what brands to trust?
There is a plethora of “gluten-free” symbols in the market. Many are self-declarations; in other words, the brand owner created the “certification mark”. Some “gluten-free certifications” are based entirely on end product testing. However, that’s not good enough. CFIA states “manufacturers and importers should have good manufacturing/importing practices (GMP/GIP) in place to achieve the lowest levels of gluten possible to avoid cross-contamination.”
The Solution
Making a gluten-free claim can be a minefield in the absence of preventive control measures. The solution is a HACCP-based gluten-free management system for food processing facilities. That’s the principle behind the Canadian Celiac Association’s Gluten-Free Certification Program (GFCP), which is based on Canadian regulations. To ensure compliance with GFCP requirements, annual audits from independent third party auditors are required.
Building Trust in Your Brand
The Gluten-Free Certification Program is an investment that goes beyond protecting your brand. Products prominently displaying the GFCP mark stand out on shelf, are differentiated from competitors and build trust in your brand.
Resources
Check out these links to learn more about Canadian regulations and the Gluten-Free Certification Program.
Canadian Gluten-Free Labelling Regulations
Gluten-Free Certification Program
As a packaged foods consultant, Birgit Blain helps brands that struggle to maintain listings. Her experience includes 17 years with Loblaw and President’s Choice®. Contact her at Birgit@BBandAssoc.com or learn more at www.BBandAssoc.com
© Birgit Blain