Cargill recall of soy flour products: Additional information received from Gluten Free Watchdog FDA FOIA request

August 31, 2023

Brief background:

1. On March 30, 2023, Cargill issued a voluntary recall for soy flour and textured soy flour products manufactured between October 5, 2022, and March 29, 2023, after receiving test results with levels of gluten between 20 ppm and 50 ppm.
2. The source of gluten is believed to be from agricultural co-mingling with rye that was planted as a cover crop. The soy flour is not sold directly to consumers.

What we learned from the FOIA materials:

1. Cargill learned of the gluten cross-contact from three customers (companies) who tested products for gluten. They believe the issue began with the harvest year beginning October, 2022.
2. Soybean grading records for their Cedar Rapids, Iowa facility did not show the presence of gluten containing grains coming in with the soybeans, according to USDA grading standards.
3. Cargill removed the gluten-free claim statement from all soy products processed at the Cedar Rapids, Iowa facility beginning March 30, 2023.
4. These were the first out of spec complaints received from customers related to gluten testing.

Concerns:

1. Why was Cargill not aware that rye (and wheat) are common cover crops in Iowa (based on information in the FOIA materials, they learned this during their root cause investigation)?
2. Why was Cargill representing the soy flours as gluten-free without doing their due diligence into practices used by the farmers supplying soybeans?
3. Was Cargill testing for gluten or were they assuming that soy is naturally gluten-free and doesn’t require testing?

What this recall reinforces:

1. Suppliers representing naturally gluten-free agricultural products as gluten-free should know how the products are grown (e.g., In rotation with wheat, barley, or rye? Next to wheat, barley, or rye? Etc.).
2. Suppliers should have a gluten testing protocol in place, especially if they are representing a product as gluten-free.
3. Manufacturers should do their own gluten testing even when a supplier represents a product as gluten-free.
4. Consumers should choose labeled gluten-free “grain” products whenever possible.

We are indebted to Adam Rapp, pro bono attorney for Gluten Free Watchdog. He is behind all FOIAs submitted to FDA on behalf of GFWD. His expertise in filing these requests has provided us with information we would not otherwise have access to. Thank you, Adam!