Labeling Quiz #1

Labeling Quiz #1

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 25, 2018

Gluten Free Watchdog Pant Tug, Post # 25


A package of hotdogs NOT labeled gluten-free includes the word “starch” in the ingredients list. The source of the starch is not named. The label does not include a Contains statement.

Question: What is the source of starch in this product?

  1. Wheat
  2. Corn
  3. Wheat or Corn

The answer is below the photo. No peaking! 

Answer: 3 (Wheat or Corn)

Apologies for the photo using letters to designate possible answers–Wordpress automatically changed the formatting.


Brief: The USDA regulates this product. The single word starch in a USDA-regulated food means either “corn starch” or “wheat starch” unless another source of starch is named (e.g., tapioca starch).

Detailed: Under USDA food standards, “starch, wheat starch, and cornstarch are synonymous in meaning. When ‘vegetable starch’ is used as a designation, it refers to the starchy materials derived from any vegetable source (e.g., potatoes, peas, etc). Tapioca starch cannot be declared as ‘starch.” If starch in a USDA-regulated product is derived from wheat, it may still be listed as “starch.”

All ingredients in foods under the labeling jurisdiction of the USDA must be listed by their common or usual name. Examples of common or usual names include starch and modified food starch.

The Food Allergen Labeling and Consumer Protection Act does not cover foods regulated by the USDA. Labeling of allergens in USDA-regulated foods is not mandatory. The USDA estimates that there is widespread compliance (80% to 90%) with voluntary allergen labeling among manufacturers.

If a product regulated by USDA includes a Contains statement or other FALCPA-like allergen labeling, the manufacturer is voluntarily complying with allergen labeling.

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