Ingredient Information: Dry Smoke Flavoring & Barley Malt Flour
In Honor of Celiac Disease Awareness Month, Gluten Free Watchdog is writing a series of articles (the goal is one per day during the month of May) related to the gluten-free diet–currently the ONLY treatment for celiac disease.
Please read this information very carefully as it may become confusing very quickly.
This information applies to foods NOT labeled gluten-free.
- Dry smoke flavoring may use barley malt flour as a carrier agent. For examples see:
- It is not known at this time how often dry smoke flavoring in a multi-ingredient product uses barley malt flour as a carrier agent. I have come across two products—a soup and a salsa.
- It is not known at this time (at least by Gluten Free Watchdog) how much gluten dry smoke flavoring utilizing barley malt flour as a carrier might contain.
- IF smoke flavoring is included in a USDA-regulated product (meat products, poultry products, egg products, mixed food products that generally contain more than 3% raw meat or 2% or more cooked meat or poultry) it must be declared in the ingredients list as smoke flavoring.
- IF a protein ingredient is used as a carrier for the smoke flavoring then the protein ingredient must be declared by its common or usual name (i.e., barley malt flour).
- It is unclear at this time whether barley malt flour must be included in the ingredients list when used as a carrier for smoke flavoring in an FDA-regulated food.
- In 2014 I asked the FDA to clarify whether barley malt flour when used as a carrier for smoke flavoring is considered an ingredient (versus an incidental additive). If it is considered an ingredient then it has to be listed in the ingredients list. If it is considered an incidental additive then it does NOT have to be included in the ingredients list. I received an email from FDA acknowledging receipt of my email. I followed-up with the FDA in 2016 and was told the status of my inquiry was not known but would be looked into. I have not heard back.
- The bottom line is that dry smoke flavoring when used as an ingredient in food may sometimes utilize barley malt flour as a carrier agent. Both smoke flavoring and barley malt flour will be declared in foods regulated by the USDA. Barley malt flour when used as a carrier for smoke flavoring may or may not be declared in foods regulated by the FDA.
- If you have concerns about smoke flavoring in an FDA-regulated food NOT labeled gluten-free contact the manufacturer and ask if barley malt flour is used as a carrier.
- If you are in Canada, Health Canada regulations require the declaration of all gluten sources in packaged food products (including barley).
- If the US gluten-free community is up for a project, it will be very helpful to mount a community-wide concerted effort to get barley added as an allergen under FALCPA. This would mean that all ingredients (including incidental additives) containing protein from barley would have to include the word barley in either the ingredient name [e.g., smoke flavoring (barley)] or in a Contains statement (Contains: Barley).
Tomorrow’s Post: Call to Action: Barley protein should be added to FALCPA and here’s why