Make no mistake about it: Wheat-based soy sauce is NOT allowed in foods labeled gluten-free
October 9, 2017
Bottom Line: Neither the FDA nor the USDA allows soy sauce made using wheat to be labeled gluten-free. There are no ifs, ands, or buts about it.
If you are a consumer or a manufacturer and you continue to have doubts about the veracity of the above bottom line statement, please read the communication from the USDA to me pasted below. I contacted the agency after Scott of the blog Gluten Dude posted about a jerky product* labeled gluten-free yet containing wheat-based soy sauce. My question to the USDA was simple, “Is USDA allowing products containing wheat-based soy sauce to be labeled gluten-free?” While I already knew the answer was no, I wanted the information in writing so that it could be shared publicly. The following statement is posted with permission:
“Soy sauce is an ingredient under FDA’s jurisdiction. We received clarification from FDA on whether such a product could be labeled as gluten free. If a soy sauce is made from wheat and soybeans, “wheat” is a gluten-containing grain, and, therefore, cannot make the gluten-free claim (emphasis mine). Since soy sauce is a fermented product, in order to make the gluten-free claim the manufacturer of the soy sauce would have to make sure all the ingredients meet the definition of gluten-free before fermentation (emphasis mine). FDA’s regulation permits ingredients that are gluten-containing grains that have been refined in such a way to remove gluten so long as the food contains less than 20 ppm gluten, e.g. “wheat starch.” Soy sauce, however, undergoes a fermentation wherein the gluten fragments are broken down. There is uncertainty in interpreting the results of current gluten test methods for fermented or hydrolyzed foods on a quantitative basis that equates the test results in terms of intact gluten.”
Thank you to the USDA for their very speedy response!
*Note: Gluten Free Watchdog purchased the jerky from Amazon. The product is currently labeled gluten-free and contains wheat-based soy sauce. This product will be added to our FDA Citizen Petition via a comment.
If you come across a product labeled gluten-free yet containing a soy sauce that includes wheat as a sub-ingredient, please take photos of the gluten-free claim and the ingredients list and send them to firstname.lastname@example.org.
© October 9, 2017 by Tricia Thompson, MS, RD. All Rights Reserved. No part of this article may be reprinted without the express written permission of Tricia Thompson.