Getting into the weeds with FDA: Can gluten-free bread carry an “enriched gluten-free bread” claim?Tricia Thompson
In honor of Celiac Disease Awareness Month 2018,
A series of bites, barks, tail wags, face licks, and pant tugs from Gluten Free Watchdog
May 16, 2018
Gluten Free Watchdog Bite, Post # 16
Question: Can gluten-free bread carry an “enriched gluten-free bread” claim?
Why: In a conversation with the FDA, a dietitian colleague and I were advised that the term “enriched” cannot be declared on the label of a gluten-free food that has an “equivalent” wheat-based product with a standard of identity. In other words, a gluten-free bread, roll, or bun cannot be labeled “enriched bread” because the gluten-free bread does not meet the FDA’s standard of identity for enriched bread (e.g., a gluten-free bread cannot meet the standard of identity requirement because it does not contain wheat). It also remains somewhat murky as to whether (and when) nutrients may be added to gluten-free breads, pastas, etc.
The FDA regulates the term “enriched” when used on a food label to describe a standardized food, such as “enriched bread.” Products including enriched bread, enriched flour, enriched macaroni products have standards of identity. Only certain nutrients are allowed to be added to these products and then only in specific defined amounts. Vitamins and minerals that must be included are thiamin, riboflavin, niacin, folic acid, and iron.
Many of the refined wheat-based products available in the grocery store are enriched with B-vitamins and iron. These products provide a large percentage of American intakes of these nutrients.
Note: Keep in mind that refined gluten-free cereal grain foods (e.g., breads, pastas, flours) typically are NOT enriched.
What is enrichment?
Enrichment when used on a food label generally means that vitamins and minerals originally present in food but lost during processing were added back. For example, when a whole grain such as brown rice is milled to make white rice or white rice flour, the outer bran and germ are removed, leaving the starchy endosperm. Stripping grains of bran and germ also strips them of many nutrients.
History of enrichment in the US (from the Gluten-Free Nutrition Guide by Tricia Thompson, McGraw-Hill, 2008)
“Government recommendations to enrich flour and bread products with the B vitamins thiamin, riboflavin, and niacin (as well as iron) were first made in the early 1940s. These recommendations came about because of the poor nutritional status of enlisted men during World War II, as well as the identification of specific vitamin deficiency diseases related to poor dietary intake of B vitamins. Deficiency disease such as pellagra (due to poor niacin intake) and beriberi (due to poor thiamin intake) are rarely seen in the United States today, largely eliminated by enrichment of cereal grains.”
But again, refined gluten-free cereal grain foods (e.g., breads, pastas, flours) typically are NOT enriched and according to the FDA they are not allowed to be enriched.
What if something was labeled “vitamin power” bread and never used the word “enriched”?
This is a very odd holdover from WW2, and while I’m tempted to say “just take a vitamin per day” that doesn’t work if you can’t afford vitamins or if you’re in the service and everything you eat is basically controlled externally. Although I’ve heard rumors of people hiding their Celiac in the armed forces, I believe that they are cashiered from service if they are found to have it.
So this has more of an effect than we often think about. Great article!
Wait a minute, this is enriched… http://www.ener-g.com/tapioca-loaf-thin-sliced.html I also asked a dietician (email me and I’ll tell you who) and she said you can add vitamins, but not Folic Acid… except… this one also has folic acid too… so now I’m lost on this issue.. is it allowed or not? Look they even use the word “enriched” – this is a very old brand though, maybe they have some grandfather clause? I doubt if they go back to WW2 tough, I think they’re 1970s. I happen to love this bread, it toasts nicely and can be used as a thickener. Idk what to think about the enriched thing now.
It isn’t worth trying to figure out (trust me). I’ve been encouraging manufacturers to enrich their refined products since 1991. At this time the FDA told me in writing that it was okay stating that “manufacturers may provide additional nutrients in gluten-free food products consistent with FDA regulations and policies for food fortification.” They went on to state, “a product claiming to substitute for an enriched food should be nutritionally equivalent to that food.” However, in a phone conversation many years later, the FDA changed their story. As the post states, FDA advised us at the time that the term “enriched” cannot be declared on the label of a gluten-free food that has an “equivalent” wheat-based product with a standard of identity. Keep in mind that just because a manufacturer isn’t supposed to do something doesn’t mean they don’t do it. There is no FDA pre-approval process for labels. Going after a gluten-free manufacturer for enriching gluten-free bread is likely low on the list of priorities. In addition, Ener-G Foods refers to their products as “loafs” which may make a difference. Regarding the addition of folic acid (or lack thereof), I am aware of this situation and the folks involved. However, the standard of identity for enriched bread, etc continues to include folic acid.
Oy! You’re right, my head is spinning! Thanks for the explanation though, I really appreciate it. This does seem like a micromanagement issue really. If they did bother some GF bread makers for adding typical vitamins and calling it “enriched” I think people would react with eyerolls. I think a manufacturer would have to create “multivitamin one slice a day bread” before they raised a hackle (because now it’s not bread anymore, but a supplement).
The whole system is old. We have good data from NHANES about what deficiencies the population is running right now. A real Public Health bread/milk enrichment plan would be updated every few years to include those things people are currently missing. Vitamin E comes to mind. Still they can’t even decide if Choline is a vitamin or not… so there’s that.
I get it, they are only replacing the vitamins that normally come with the whole wheat or the whole milk. But if you’re worrying about industrialization affecting health, then, using NHANES data makes more sense to me, in the modern day.
How many people expressing problems with gluten actually have problems with folic acid that is added to enriched products? My body reacts very poorly to consuming folic acid (an artificial product, not the same as naturally-occurring folate) to the point I treat is as an allergy. I can safely consume whole wheat flour or anything labelled as unenriched, but when I go out to eat, I typically avoid any products that might be enriched (bread, white rice, pasta). I wondered if eating gluten-free would guarantee that the food doesn’t contain folic acid. If so, that would open up many more options to eat out than I currently have.
No guarantees. If a product is enriched or fortified with folic acid, this will be indicated in the ingredients list.