Why 20 ppm Isn’t Gluten-Free Enough: Decoding the new FDA gluten-free food labeling rule
The U.S. Food and Drug Administration (FDA) recently issued a final rule on gluten-free food labeling. The new rule standardizes the definition of “gluten-free” to indicate that the food is either inherently gluten-free or must not contain any ingredient that is, “1) a gluten-containing grain (e.g., spelt wheat); 2) derived from a gluten-containing grain that has not been processed to remove gluten (e.g., wheat flour); or 3) derived from a gluten-containing grain that has been processed to remove gluten (e.g., wheat starch), if the use of that ingredient results in the presence of 20 parts per million (ppm) or more gluten in the food. Also, any unavoidable presence of gluten in the food must be less than 20 ppm.” Foods that are labeled as containing “no gluten”, being “free of gluten”, and “without gluten” must also meet the definition of gluten-free.
There is no question that a standardized definition of gluten-free labeling is long overdue to help those with celiac disease and gluten intolerance make informed decisions about the packaged foods that they consume. But is 20 ppm gluten-free enough when it comes to preventing consequences of gluten exposure in people with celiac disease and gluten intolerance? Some research, conducted by none other than the FDA, suggests not. The report, published in May 2011, is lengthy, but worth reading if you are impacted by the gluten-free labeling rules. The conclusion of the report is particularly compelling:
“In sum, these findings indicate that a less than 1 ppm level of gluten in foods is the level of exposure for individuals with CD [celiac disease] on a GFD [gluten-free diet] that protects the most sensitive individuals with CD and thus, also protects the most number of individuals with CD from experiencing any detrimental health effects from extended to long-term exposure to gluten.”
When comparing these findings to the gluten-free food labeling rule, it is clear that 20 ppm is not low enough to protect all individuals with celiac disease. The FDA maintains that 20 ppm will protect the majority of those with celiac disease; however, the negative effects of gluten exposure do not always result in obvious symptoms and gluten sensitivity exists on a spectrum. How can you be certain that you aren’t in the category of those who will be sensitive to 20 ppm of gluten? What about the effects of repeated exposure to low levels of gluten, such as 20 ppm, over long periods of time? There are no simple answers, but I believe that it is precarious to generalize a safe level of gluten for those with celiac disease or gluten intolerance.
In fairness to the food manufacturing industry, it is not possible to ensure that a processed food contains absolutely no gluten because of the reality of cross-contamination and the nature of manufactured foods. Also, the current testing methods for gluten can only detect as low as 3 ppm (which is the current standard for gluten-free in Australia and New Zealand). If a gluten-free label doesn’t guarantee that a food is truly free of gluten, what is the solution?
Opting for a whole food, nutrient-dense diet that greatly reduces dependence on foods that need to be labeled gluten-free is a great start. I recommend a Paleo nutrition template because it focuses on eating real foods and eliminating those that are processed or refined, contain anti-nutrients and proteins that are difficult for many to digest (such as gluten), and contribute to inflammation and metabolic dysfunction in the body. And remember, just because a food is labeled as gluten-free does not mean that it is healthy or that it is the right choice for you and your body.
What are your thoughts on the FDA gluten-free food labeling rule?