Gluten Free Watchdog 2025 Summary Report

Testing: Testing was commissioned by GFWD and done by Bia Diagnostics, LLC. The sandwich R5 ELISA and cocktail extraction were used. When appropriate, the competitive R5 ELISA also was used. Most samples were tested in duplicate; oat samples were tested in triplicate due to the heterogeneous (uneven) distribution of potential gluten cross contact.

Findings:

104 unique products were tested and released in 2025—almost all of them subscriber requests.

75 unique products were labeled/represented as gluten-free.

6 unique products labeled gluten free contained quantifiable gluten (5 parts per million or more) in at least one test portion/extraction.

All 6 products testing with quantifiable gluten contained an oat ingredient.

2 of these 6 products tested out of compliance with the gluten-free labeling rule.

Of the products labeled gluten-free, 5% tested between 5 ppm and 19 ppm in at least one extraction.

3% of the products labeled/represented as gluten-free tested at/above 20 ppm of gluten.

What this means—92% of the foods requested for testing in 2025 by subscribers to GFWD tested below 5 ppm of gluten.

Two products not labeled gluten-free—cauliflower tortillas and a vitamin/mineral supplement tested with quantifiable gluten in at least one food portion/extraction.

One product tested at/above 20 ppm; the other tested between 5 and 19 ppm.

Product Warnings: Product warnings are posted to social media primarily to alert the community to facial misbranding (i.e., when a labeled gluten-free product includes an ingredient not allowed).

17 product warnings were posted in 2025.

5 of these products were reported to the FDA.

FDA lack of action: Based on a search of the FDA’s pages: Recalls, Market Withdrawals, & Safety Alerts and Enforcement Reports, no public-facing enforcement actions have been taken against any of the products reported to the FDA by Gluten Free Watchdog going back to October 1, 2024*. These products include those containing ingredients not allowed in gluten-free foods (e.g., barley malt vinegar, barley extract, yeast extract from barley) and those found to test out of compliance with the gluten-free labeling rule based on our commissioned testing–Trader Joe’s rolled oats and Pure Oats rolled oats.

*On October 1, 2024, the Food and Drug Administration updated the way in which consumers must go about reporting food-related issues to the agency. Instead of contacting an FDA consumer complaint coordinator, reports are now filed with the Human Foods Program either by phone or through the online safety reporting portal. Gluten Free Watchdog also was asked to use the portal.  According to an email sent out by the FDA, “This streamlined process will expedite delivery of inquiries and complaints to the appropriate public health experts at the FDA and allow for more consistent processing and earlier detection of potential public health problems.”

Either this new(ish) reporting process isn’t working or manufacturer non-compliance with the gluten-free labeling rule is currently not considered by the FDA to be a health threat.