Make no mistake about it: Wheat-based soy sauce is NOT allowed in foods labeled gluten-free

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 info@glutenfreewatchdog.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.

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Comments (6)

  • asp
    Reply

    FDA & WHO specify that foods containing less then 20 ppm of gluten are 100% safe for persons with celiac disease. It matters not that wheat is or is not listed as an ingredient. What matters is the gluten content, not the wheat.

    November 5, 2018 at 7:56 pm
    • Tricia Thompson Reply

      You are mistaken about the FDA. Certain ingredients are not allowed in foods labeled gluten-free. These ingredients include soy sauce made from wheat. From the FDA: “If a soy sauce is made from wheat and soybeans, “wheat” is a gluten-containing grain, and, therefore, cannot make the gluten-free claim.”

      November 5, 2018 at 8:08 pm
  • asp Reply

    From the FDA “Ingredients derived from a gluten-containing grain that have been processed to remove gluten if use of that ingredient results in the presence of 20 parts per million (ppm) or more gluten in the food” are considered gluten free and can be labeled as such.

    November 5, 2018 at 8:06 pm
    • Tricia Thompson Reply

      Reposting here as well. You are mistaken about the FDA. Certain ingredients are not allowed in foods labeled gluten-free. These ingredients include soy sauce made from wheat. From the FDA: “If a soy sauce is made from wheat and soybeans, “wheat” is a gluten-containing grain, and, therefore, cannot make the gluten-free claim.”

      November 5, 2018 at 8:09 pm
    • Lusa Reply

      What is that ‘process’? Too remove gluten from a wheat based soy sauce? Very curious.

      December 23, 2018 at 3:23 am
      • Tricia Thompson Reply

        Soy sauce is a fermented product. During the fermentation process, wheat gluten is broken down into smaller fragments. The open question is whether the protein is broken down to such an extent that it is no longer problematic to folks with celiac disease. At this time, the FDA stance on wheat-based soy sauce is as posted above, “… 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.”

        December 28, 2018 at 12:03 pm

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