Gluten-Free Labeling Best Practices

In the age of the internet, social media, and smart phones, consumers have become much savvier about the foods they eat. Whether for health reasons or medical necessity, many people are adopting special diets and are increasingly researching and choosing products based on the availability of reliable information. In fact, seven out of 10 of consumers say they want greater transparency in food labels, and 75% would switch products if another brand provided more in-depth information beyond the physical label.

Reliable information is especially important for products marketed as gluten-free. Approximately three million Americans have celiac disease and face serious health complications from consuming even a trace amount of gluten, and millions more (up to 13% of the population) choose carefully to avoid gluten due to gluten sensitivity or other health concerns. It is incumbent upon food manufacturers to provide accurate information about food products, and that starts with transparent labels. But, transparency in labeling isn’t just a compliance or safety issue. Providing clear, accurate information about food—about everything from dietary claims to allergens to the manufacturer’s processes—can generate consumer interest in your products and drive their purchasing decisions.

The Age of COVID-19

The COVID-19 pandemic has put a finer point on the issue of transparent labels due to a recent FDA rule change that allows manufacturers to make minor substitutions to ingredients without changing their packaging. While substitutions that can cause adverse health effects are prohibited—the rule specifically references gluten—the possibility now exists for companies to inadvertently substitute a gluten-containing ingredient and neglect to note it on the ingredient list.

The growth in online shopping due to COVID-19 is also creating additional demand for detailed ingredient information. Meanwhile, the pandemic is creating opportunities for businesses to slow down, reevaluate processes, and place renewed focus on quality. Now is an ideal time for manufacturers to introduce labeling practices that meet consumer demand for greater transparency in product information.

Providing clear, accurate information about food—about everything from dietary claims to allergens to the manufacturer’s processes—can generate consumer interest in your products and drive their purchasing decisions.

Terminology, Logos, and Placement

However, initiatives to make product labels more informative can backfire unless manufacturers adopt best practices in terminology, logo design, and placement. Despite best intentions, manufacturers can do more harm than good by providing unnecessary, inaccurate, or unclear information. For instance, statements that products “contain wheat” or “may contain wheat” are a common source of confusion for foods marketed as gluten-free. Manufacturers often include this phrasing to address labeling requirements for wheat allergens. But, for consumers with gluten intolerance, this wording can set off alarm bells, particularly if the product is marketed as gluten-free. Manufacturers can eliminate confusion by explaining that products labeled as gluten-free meet the FDA standard of containing less than 20 ppm of gluten. It is also an FDA requirement that products labeled gluten-free clarify when wheat ingredients have been prepared or processed to remove gluten, such as wheat starch, wheat grass, or wheat grass juice.

Statements about gluten-free foods being processed on shared equipment are another frequent source of confusion. Manufacturers include these to reduce legal liability when gluten-free products are packaged in the same plant as products that contain wheat. In many cases, such statements trigger needless anxiety about the presence of gluten even when the prospect of cross-contamination is minimal. This problem is often compounded when consumers contact manufacturers for clarification and talk to an employee who doesn’t understand procedures for preventing cross-contamination or meeting gluten-free standards. Conducting a thorough risk assessment of your plant’s packaging environment, making sure employees understand manufacturing processes, and training your employees to explain labeling claims in clear language will eliminate many potential misunderstandings.