I recently met the owner of Andi Lynn’s Elderberries, a local business that produces herbal syrups, tinctures, glycerites, and tonics. Her supplements are made with farm sourced, wild harvested, and organic ingredients then handcrafted according to traditional herbal preparations.
And her product contains no gluten ingredients, but she was wondering how a small business should go about labeling products as gluten free. I researched a little bit and I hope this info can help her and other mompreneurs.
If you label your product Gluten Free it means that:
- None of the ingredients is a gluten-containing grain. Gluten-containing grains are wheat, rye, barley or spelt.
- None of the ingredients is made from a gluten-including grain without the gluten removed. Wheat flour and malt are just two examples of ingredients that are made from gluten-including grains.
- If an ingredient is made with a gluten-including grain with the gluten removed, it must test below 20ppm (parts per million) gluten. Wheat starch is an ingredient made from a gluten-including grain that has had the gluten removed.
Should you test?
You are not required to test your ingredients, but you are responsible for ensuring that your finished product contains less than 20ppm from any source of cross contamination. If you want to have laboratory testing done, ELISA Technologies will test a sample for $75.
The FDA encourages you to use effective measures to ensure that you are complying with their requirements such as: laboratory testing, requesting certificates of gluten analysis from your ingredient suppliers, or seeking third party certification from organizations like the Celiac Sprue Association or the National Foundation for Celiac Awareness.
What should your label look like?
The “Gluten Free” label can be anywhere on your package and can look however you’d like it to look.
You must comply by these rules if you make any gluten free claim such as “free of gluten” or “no gluten.”
You are not required to use “may contain” or “produced in a facility that also uses” warnings on your labels.
You are not required to label your product “Gluten Free”, even if it is gluten free, unless you want to.
Even if you don’t label gluten free, you ARE required to list the top 8 allergens that your product contains. These are: Milk, Eggs, Fish, Shellfish, Tree Nuts, Peanuts, Wheat and Soybeans.
For more info:
Guidance for Industry: Gluten-Free Labeling of Foods; Small Entity Compliance Guide