Gluten-Free Labeling

Soy Sauce: More insightful news from FDA based on Gluten Free Watchdog FOIA requests

We recently filed 3 Freedom of Information Act requests with FDA for products containing hydrolyzed/fermented protein. All products had been reported to FDA for facial misbranding by Gluten Free Watchdog. What follows is a summary of the information received from FDA to date. A huge thank you to Adam, one of GFWD’s pro-bono attorneys for filing these requests.

FOIAs were submitted for the following products:

Three Crabs Fish Sauce. Ingredients list reads, “hydrolyzed vegetable protein.” This ingredient declaration hasn’t been allowed […]

Update on Pamela’s Products Allergen Advisory Statement

On August 10, 2022, Gluten Free Watchdog reached out to Pamela’s Products:

The addition of wheat to your allergen advisory statement on product packaging for gluten-free foods is causing a lot of concern in the celiac disease community. I understand from your FAQs that you still use dedicated lines for many of your gluten-free products. Can you please let me know why products produced on dedicated lines contain a shared equipment warning vs a shared facility warning. Thank you.

Pamela’s Products […]

FDA is acting on complaints filed by Gluten Free Watchdog

This spring we filed 6 Freedom of Information Act requests with FDA representing 11 products containing malt-based ingredients.* All products had been reported to FDA for facial misbranding by Gluten Free Watchdog. What follows is a summary of the information included in the materials obtained from FDA. A huge thank you to Adam, one of GFWD’s pro-bono attorneys for filing these requests.

*We also filed FOIA requests for three additional products containing wheat. As of July 26, 2022, we have […]

Do folks with celiac disease really have to worry about enzymes and growth media?

Short answer: We don’t know. This is due to the limitations of the assays currently used to detect and measure fermented or hydrolyzed gluten.

Some facts about enzymes:

1. According to the Enzyme Technical Association, “In most cases, enzymes used in food are used as processing aids where they aid in the manufacturing of food or food ingredients but do not have a function in the final food product.”

2. Also according to the ETA, “nearly all commercially prepared foods contain at […]

Statement from Gluten Free Watchdog on Nabisco Gluten-Free Oreo Cookies

***Note: What follows is the opinion of Gluten Free Watchdog. Whether or not you choose to eat gluten-free Oreo cookies is your decision. You do not owe anyone an explanation. Please make decisions based on all available information.***

Nabisco Gluten-Free Oreo Cookies: Gluten Free Watchdog is on the fence about this cookie. We have tested numerous packages and test results are very encouraging. We love that the actual cookie includes a gluten-free imprint. This is brilliant. This product is also […]

Lessons Learned from 16 Years of Testing Food for Gluten

This video presentation with audio is about 30 minutes long. The focus is on lessons learned from 16 years of testing food for gluten. The positive news is that the vast majority of the hundreds of foods tested through GFWD have tested below 20 parts per million of gluten. There have been a few unwelcome surprises over the years, including the level of cross contact in lentils and the number of products impacted by facial misbranding. We’ve also learned […]


During this period of food shortages and supply disruptions as a result of COVID-19, FDA is allowing manufacturers to make certain ingredient substitutions without changing the ingredients list. FDA stated in a letter to Gluten Free Watchdog that their COVID-19 food labeling flexibilities:

“… are not to be used when they may pose a health or safety issue. This would include the introduction of an ingredient containing gluten. Substitutions, in any amount, are not appropriate without a corresponding label […]

FDA responds to our concerns about their temporary policy on food labeling changes

The FDA has responded to the group letter submitted by Gluten Free Watchdog and six other patient/consumer advocacy and professional groups outlining our concerns about FDA’s temporary policy on food labeling changes during the COVID-19 pandemic and the impact it may have on the celiac disease community.

The FDA response further clarifies agency position and elaborates on the wording used in their guidance document. Regardless, it appears unlikely that FDA will be amending the current guidance. The agency has […]