Rule on Gluten-Free Labeling of Fermented or Hydrolyzed Foods

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 […]

Gluten Free Watchdog presents with FDA at IAFP on Gluten in Fermented/Hydrolyzed Foods

Amy Keller, MS, RDN, LD, an associate at Gluten Free Watchdog presented with FDA at the International Association of Food Protection conference. The session, titled “Gluten in Fermented or Hydrolyzed Foods: Regulatory, Consumer, and Analytical Perspectives” was presented today, August 3, 2022. Gluten Free Watchdog was invited by FDA to represent the voice of the consumer. We greatly appreciate this opportunity. The slides presented by Gluten Free Watchdog are available at:

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 […]

Chef Myron’s sauces containing wheat-based soy sauce FINALLY recalled

Recalls for eight Chef Myron’s sauces posted to the FDA’s enforcement report page the week of December 16th. The reason given for all recalls: “Product utilized a gluten-free claim but has as an ingredient a fermented soy sauce that is produced from wheat which was not processed to remove the gluten prior to fermentation.”

It is huge that these recalls are happening. Finally, the FDA appears willing to recall foods labeled gluten-free containing wheat-based soy sauce as an ingredient. This […]

Troubling statement by the Prolamin Working Group on the determination of gluten in fermented foods containing partially hydrolyzed gluten

Gluten Free Watchdog is very troubled by a statement recently released by the Prolamin Working Group “on the determination of gluten in fermented foods containing partially hydrolyzed gluten.” While we have a great deal of respect for each of the authors, the insinuation that the FDA did not lead with science in determining that “the R5 Competitive ELISA method is not suitable for the detection and quantification of gluten in any fermented or hydrolyzed food” comes across as exceedingly […]

Is beer made using malted barley and crafted to remove gluten safe for folks with celiac disease? FDA says it is not possible to know based on current testing methods

This post is part of a series covering the FDA’s Final Rule on Gluten-Free Labeling of Fermented or Hydrolyzed Foods. 

The rule is available at:

Background (Important):

FDA regulates the following:Beer made without malted barley but with hopsBeer made without hops but with malted barleyBeer made without either malted barley or hopsTTB regulates malt beverages including traditional beers made with both malted barley and hops.

Bottom Line:

Beer under the labeling jurisdiction of FDA that is made from gluten-containing grains (including malted barley) cannot […]

Gluten Content of Distilled Alcohol: Gluten Free Watchdog Summary Report

October 13, 2020: This report was published in 2018. It is being released publicly due to discussion around FDA’s 2020 rule on gluten-free labeling of fermented and hydrolyzed foods and ingredients. Please address any questions to Tricia Thompson at

The report is available at

Product Warning: Pots & Co. Flourless Chocolate Cake

This product is made in the UK and sold in the US. It is labeled gluten-free yet contains the ingredient “gluten-free barley malt extract (barley malt, water).”

Gluten Free Watchdog reached out to the manufacturer and was advised: “Our Flourless Chocolate Cake recipe uses a gluten free barley malt extract. It undergoes a special treatment to reduce the gluten content.  We have certification showing that it has a less than 5ppm and therefore can be labelled as Gluten Free.” 

While gluten-free foods […]

Product Alert: Schiff Digestive Advantage Lactose Defense Formula labeled no added gluten contains an enzyme cultivated on growth media containing wheat

A concerned consumer reached out to Gluten Free Watchdog about this product. GFWD contacted the manufacturer asking about the source of wheat. The manufacturer reply stated: “The product does not contain any wheat or gluten. The enzyme used in our product is grown on fermented wheat so we are required to add it to our label.”

HOWEVER, under FDA’s newly released rule on gluten-free labeling of fermented and hydrolyzed ingredients, FDA has declined to exempt enzymes. This means that enzymes […]

What the FDA has to say about wheat starch and hydrolyzed gluten

This post is part of a series covering the FDA’s Final Rule on Gluten-Free Labeling of Fermented or Hydrolyzed Foods. 

The rule is available at

Bottom Line:

Under the FDA’s 2013 gluten-free labeling rule, wheat starch is considered “an ingredient processed to remove gluten.”It is an allowed ingredient in foods labeled gluten-free as long as its use does not result in the final food product containing 20 parts per million or more of gluten.Fermented foods and ingredients made using gluten-free wheat […]