FDA issues a request for information regarding labeling and preventing cross-contact of gluten in packaged food
On January 21, FDA issued a request for information regarding labeling and preventing cross-contact of gluten in packaged food. The FDA reached out directly to Gluten Free Watchdog encouraging us to submit comments to help inform their decision-making process.
According to the email received, the RFI seeks public comments and data on four main areas:
- Oats and gluten contamination through cross-contact with gluten-containing grains.
- Undisclosed ingredients where gluten sources may not be apparent to consumers (e.g., “malt extract” from barley).
- Consumer perspectives on gluten avoidance, purchasing decisions, and labeling needs.
- Adverse reactions to non-wheat gluten-containing grains (rye, barley) including prevalence, severity, and potency data.
Gluten Free Watchdog will be providing comments and data on oats and gluten cross contact as well as comments and data on undisclosed barley. These are areas of concern that we have been reporting on and filing complaints about for two decades.
Gluten Free Watchdog encourages consumers to submit comments related to numbers 3 and 4 above.
Please read the request for information in full at https://www.federalregister.gov/documents/2026/01/22/2026-01121/labeling-and-preventing-cross-contact-of-gluten-for-packaged-foods-request-for-information
Comments may be submitted by clicking on “submit a public comment” at the above link.
Comments (4)
I would like to see Barley listed as a allergen on products. Sometimes when I read a long ingredient list on a product, I can always look down at the listed allergens to make sure I did not overlook one of them in the ingredient list. I would like the same for barley.
I was diagnosed with celiac almost 13 years ago, and a lot has changed since then—options have increased in number, more people have become aware of celiac, and now changes are even beginning to occur at the policy level. I am very grateful that the FDA is considering changing gluten free labeling because I have sometimes been confused when reading the labels of items to determine if they are safe for me to eat.
The “may contain” labels feel particularly ambiguous because they are vague and I don’t know how much of a cross-contamination risk there is and it seems like this could vary. So many food items that otherwise seem gluten free have this label, but I stay away from them because I decide they are not worth the risk. But a more clear label that gives us a better idea of what the risk is would be very helpful and potentially allow me to eat more items.
Another confusing label is one that says it is gluten free but without any certification that would assure me that it is safe. A lot of the time these items are fine, but sometimes, as is the case with Cheerios (because of the oats not being certified GF), they are not and even an individual product be inconsistent in each batch in terms of whether or not it causes a reaction. If there was a way to encourage oats to more commonly be grown so that they remain gluten free that would be very helpful, but if not, proper labeling would still be helpful as well. If gluten free labels were limited to items that are celiac-safe and notes were included on any oat-containing item that was not made from certified GF oats, that would help people like myself better identify what we can and cannot eat.
Finally, the presence of any major allergen (including gluten) should be disclosed on food and drink labels. They are already often disclosed, but not always, so having this as a requirement would be very helpful because it is not always obvious and it helps to have a label stating this information so that someone can be sure if their allergen is or is not in a particular item. Since wheat and gluten are two different things, both should be considered separate allergens. Wheat without the gluten would be safe for someone sensitive to only gluten but not for someone with a wheat allergy, just like how barley would not be safe for someone with a gluten sensitivity but would be for someone only sensitive to wheat.
My reactions are not always obvious or the same, so it can be difficult for me to tell if I have been exposed to gluten or not. The severity of my reaction seems to vary based on the amount of gluten I consumed, but I have only noticeably reacted since being diagnosed. Before I was diagnosed and I was eating gluten-containing foods regularly I did not ever have a noticeable reaction (I only got tested for celiac because I was not growing properly as a child despite eating well), so even now I worry that I do not noticeably react each time I am exposed to gluten (though I have probably become more sensitive to gluten the longer I have been avoiding it and probably did not noticeably react as a child because I was desensitized through such frequent exposure). As a result, I worry more about the safety of foods do that I do not unknowingly causing damage to my body by eating something that I think is safe but is not. Better labeling can help with avoiding misinterpreting labels when deciding whether or not something is safe.
Thanks for sharing, Marina. If you haven’t already, please make sure to submit your comment directly to the FDA. Please go to https://www.federalregister.gov/documents/2026/01/22/2026-01121/labeling-and-preventing-cross-contact-of-gluten-for-packaged-foods-request-for-information and click on “submit a comment” at the top right of the page.
People need to be educated. That celiac disease is not a choice, eating gluten free is necessary. I have lost half of my small intestine possibly to undiagnosed celiac disease.