Manufacturing and the law
Advice for manufacturers on labelling pre packaged foods
From talking with our members, they are most familiar with the term gluten-free and welcome the assurance that this gives. It’s worth going that extra step to be compliant with the law so that you can use this label.
The term gluten-free is covered by Commission Implementing Regulation (EU) No 828/2014. Only foods that contain 20 ppm or less can be labelled gluten-free. The term can be used on specialist substitute gluten-free products like breads, flours and crackers, which may contain gluten-free (Codex) wheat starch, as well as processed foods that are naturally gluten-free like soups, baked beans and crisps. The ‘gluten-free’ label may also be used for uncontaminated oat products. For oat products labelled gluten-free the oats themselves must also contain no more than 20ppm.
If a cereal containing gluten is used as a deliberate ingredient, it must be listed on the ingredients list, no matter how much is used. When labelling foods you must name the specific grain that has been used, for example, wheat, rye, barley, oats, spelt, khorasan wheat (commercially known as Kamut®), triticale or their hybridised strains.
For foods manufactured after 13 December 2014, allergens must be emphasised in the ingredients list and not in an allergy advice box. This is a requirement of the Food Information Regulations. The new regulation combines rules on food and nutrition labelling into a single EU regulation and covers:
- setting a minimum font size to make labelling clearer
- emphasising allergens in the ingredients list
- use of allergy advice boxes.
You can find a useful information booklet on the Food Standards Agency website: ‘Allergy: what to consider when labelling food’. Technical guidance is also available on the Food Standards Agency website. The British Retail Consortium (BRC) has guidance for manufacturers which is available on the BRC website.
We also have information for our Members on the changes, including a link to a new leaflet published by the Food Standards Agency.
There are some ingredients which are made from a cereal containing gluten where the grain does not have to be listed. This is because processing has removed the gluten.
The European Commission has worked with the European Food Safety Authority (EFSA) to develop a list of ingredients which do not have to be labelled as being from a gluten-containing grain.
The following ingredients are gluten-free:
- glucose syrups derived from wheat or barley including dextrose
- wheat based maltodextrins
- distilled ingredients made from cereals that contain gluten e.g. alcoholic spirits.
Although these ingredients can be made from cereals containing gluten, you do not have to label them as such because the processing has removed the gluten.
‘May contain’ guidance
The Food Standards Agency has produced voluntary guidance on when to label a product with a ‘may contain’ statement. You can download this guidance from the Food Standards Agency website.
Examples of labelling terms include:
- may contain traces of gluten
- made on a line handling wheat
- made in factory also handling wheat.
Before using terms like these, manufacturers should assess the risk that the product could be contaminated with gluten. This allows the consumer to make an informed individual risk assessment and decide whether or not to include the product in their diet. Food Standards Agency best practive guidance does not recommend using a 'may contain' statement on products labelled gluten-free. You can read the FSA guidance here.
How we can help you
Making sure you can comply with the law is key for both your business and your coeliac customers, and we can help you do this. We offer the internationally recognised Crossed Grain symbol for packaged products to help you stand out in an ever growing market. This is the gold standard for labelling products suitable for people with coeliac disease and is available under licence. Contact us to find out how you can get certified.