Gluten-Free Foods Still Contain Barley Malt
Despite having a gluten-free labeling rule in place, there are manufacturers who still believe that if they test their final food product for gluten using the sandwich R5 ELISA and it tests below 20 parts per million of gluten then they can label the product gluten-free, regardless of ingredients. As a result manufacturers are labeling food gluten-free even though these products may contain such ingredients as malt, malt extract, malt syrup, extracts of rye, extracts of barley, soy sauce (with a sub-ingredient list that includes wheat), etc.
These manufacturers are missing two major facts…
First, there is more than one criterion for labeling a food gluten-free. A gluten-free food may NOT contain ingredients that have NOT been processed to remove gluten. It doesn’t matter how much gluten the final food product contains, even if it is less than 20 parts per million. A manufacturer cannot include a little bit of wheat flour or a little bit of barley malt and label a food gluten-free, regardless of test results.
Second, the sandwich R5 ELISA is not able to accurately detect gluten peptide fragments. Gluten peptide fragments result when gluten protein is hydrolyzed (in other words broken apart). A competitive R5 ELISA should be used to detect gluten protein fragments.
Note: If you are interested in learning more about the differences between the sandwich and competitive R5 ELISAs please click here.
Products containing barley malt, barley malt extract, or barley malt syrup
If you come across a product labeled gluten-free yet containing malt, malt extract, or malt syrup please know that despite what the manufacturer may tell you about the product testing gluten-free, these ingredients are NOT allowed in gluten-free foods. This is the single biggest ingredient issue—malt in gluten-free foods–that we deal with at Gluten Free Watchdog. And it is great to report that to date all of these issues have been dealt with successfully (although some cases have taken longer to resolve than others!).
Note: If you are interested in what the FDA has to say about malt ingredients, please click here.
Products containing other hydrolyzed gluten ingredients
Foods labeled gluten-free yet containing extracts of roasted barley, extracts of roasted rye, or wheat that has undergone hydrolysis during processing have proven far more difficult to address. There are several reasons for this difficulty:
1. There is no Code of Federal Regulation definition for “extracts of roasted barley” or “extracts of roasted rye” as there is for malt.
a. For example, at Gluten Free Watchdog we tested a product containing as ingredients extracts of roasted barley and extracts of roasted rye and it tested below 5 parts per million using the sandwich R5 ELISA but tested above 20 parts per million of gluten using the competitive R5 ELISA. In other words, test results indicate that this product contains gluten peptide fragments. The first time Gluten Free Watchdog sent test results to FDA, the agency responded that, “we are not certain what exactly the extracts of roasted barley and roasted rye contain so we cannot make a decision on labeling as yet.” After the second round of testing approximately one year later, results were again sent to FDA. The agency responded, “We will review your information and follow up as warranted.” The product is still being sold as gluten-free. The ingredients have not changed. This response is vastly different than the response received from FDA when a product labeled gluten-free and containing barley malt was reported. Product was removed from store shelves in a matter of days. Please note that Gluten Free Watchdog always contacts the manufacturer FIRST when dealing with ingredients that should not be included in a labeled gluten-free product. FDA is contacted only when the manufacturer is nonresponsive.
2. The FDA has not yet released the proposed rule regarding gluten-free labeling of hydrolyzed and fermented foods. This may be preventing the Agency from acting on foods containing certain hydrolyzed ingredients.
Note: To read the update received from FDA on this proposed rule please click here.
3. While we wait for the proposed rule to be released the FDA provides some nondescript guidance to manufacturers. The FDA states the following in the preamble to the gluten-free labeling rule: A “gluten-free” claim will be permitted on fermented and hydrolyzed foods or foods containing fermented or hydrolyzed ingredients that meet all of the requirements for bearing a “gluten-free” claim even though the gluten content of the food cannot be reliably measured.” Consumers along with manufacturers will have to wait for the proposed rule to find out exactly what FDA means by this statement. In the meantime, manufacturers are interpreting this statement in a variety of ways based on the conversations I have had with some of them.
At this time and in my professional opinion, individuals with celiac disease and other gluten-related disorders should NOT eat products containing hydrolyzed gluten ingredients. I certainly would not. But this is a personal choice. At the very least, I recommend the following:
1. Do NOT eat any foods containing malt, malt extract, or malt syrup even if they are labeled gluten-free. These products should be reported first to corporate and then to FDA if necessary. If you are not comfortable doing this yourself, please contact Gluten Free Watchdog.
2. If you come across a product containing hydrolyzed or fermented wheat, barley, or rye, contact the manufacturer. If you are told that the gluten-free claim is based on testing using a sandwich ELISA, this product should be avoided. It may contain undetected gluten peptides. If the manufacturer is not transparent and does not provide testing information, this product should be avoided.
a. If the manufacturer is basing their gluten-free claims on testing using both a sandwich and competitive R5 ELISA I am a bit more comfortable with the product because the testing is more comprehensive. But please keep in mind that the competitive R5 ELISA is not a perfect assay. Personally, I would still avoid this product. You may or may not feel the same.
i. Note: The above does not hold true for gluten-removed beer as the enzyme treatment involved in the processing of these beverages renders the competitive R5 ELISA useless at detecting the amino acid sequence this assay is designed to “find.”
Testing foods for gluten contamination is an exceedingly complicated process and there is no such thing as too much testing. The more testing we do through Gluten Free Watchdog the more often I am left scratching my head. There are very smart people working on the subtle nuances of testing food for gluten. The Working Group on Prolamin Analysis and Toxicity does some of the best work. To read the proceedings of their last meeting click here.
If you come across a product you feel may be misbranded based on ingredients, please let us know.
© February 2, 2015 by Tricia Thompson, MS, RD for Gluten Free Watchdog, LLC. All Rights Reserved. No part of this article may be reprinted without the express written permission of Tricia Thompson.