Oats are complicated! Updated Position Statement on Oats from Gluten Free Watchdog

Oats are complicated! Updated Position Statement on Oats from Gluten Free Watchdog

This statement may not be reposted without the express written permission of Gluten Free Watchdog, LLC

This post was updated on October 24, 2022.

***Note: What follows is the opinion of Gluten Free Watchdog. If you tolerate oats, whether you choose to eat mechanically/optically sorted oats or only purity protocol oats is your decision. You do not owe anyone an explanation. Please make decisions based on all available information.***


Gluten Free Watchdog…

  • Is supportive of purity protocol gluten-free oats supplied by Avena Foods, Montana Gluten-Free Processors, and Bay State Milling/MGM (pertains to oat supply in North America only).
  • Is supportive of manufacturers using gluten-free oats solely from the above purity protocol suppliers.
  • Is supportive of mechanically/optically sorted gluten-free oats from Quaker Oats.
  • Is not supportive of any other single ingredient oat products using oats sourced from suppliers of gluten-free sorted oats.
  • Would like to see manufacturers of labeled gluten-free multi-ingredient products containing oats use purity protocol oats. However, products can be evaluated on an individual basis (please see below for questions to consider).


First some facts:

1. Oats are considered a naturally gluten-free grain. Note: Some people with celiac disease are unable to tolerate oats. Research is ongoing to determine the reason why.

2. Oats are highly likely to come into contact with wheat, barley, or rye anywhere from the field to the mill to the food processing facility.

3. Gluten-free oats are available for folks with celiac disease and other gluten-related disorders.

4. Gluten-free oats may be either purity protocol or sorted.

5. Despite what may be the best efforts of suppliers and manufacturers, gluten-containing grains have been found in both final product purity protocol oats and final product sorted oats.


Purity protocol oats:

1. Are produced following steps to control the presence of gluten-containing grain throughout the entire process of growing, harvesting, milling, and processing.

2. There is no standardized definition for purity protocol.

Sorted oats:

1. Sorted oats are traditionally grown (standard) oats that undergo a mechanical and/or optical screening at the mill to remove gluten-containing grain based on a variety of grain properties (e.g., size and color). 

2. There is no standardized process for sorting oats.


Why testing oats for gluten is so difficult:

1. Errant wheat, barley, and rye grain in oats is not evenly distributed.

2. If there is gluten in a product, hopefully it is captured in the smaller sample selected for testing.

3. It is also hoped that any gluten in the selected sample can be evenly distributed.

4. The protocol for testing oats for gluten involves grinding a larger than normal sample size and testing larger than normal sub-samples to hopefully “find” gluten if it is present.

5. When ANY gluten is found this is cause for concern precisely because it is so hard to find.

6. Regardless of testing difficulty, oat products account for almost half of the grain-based foods testing out of compliance with the gluten-free labeling rule (at or above 20 parts per million of gluten) at Gluten Free Watchdog.


Purity protocol oats:

We remain supportive of the following North American suppliers of purity protocol oats (and manufacturers using oats solely from these suppliers): Avena Foods, Montana Gluten-Free Processors, and Bay State Milling/MGM. Our support is based on the protocols followed by each supplier, beginning with planting pure gluten-free seed. For more information on supplier protocols and a listing of manufacturers using oats from the above suppliers, see https://www.glutenfreewatchdog.org/news/oats-produced-under-a-gluten-free-purity-protocol-listing-of-suppliers-and-manufacturers/. Note: This listing was updated on October 21, 2022.

Sorted oats are a bit trickier…

Quaker Oats gluten-free products: We remain supportive of Quaker gluten-free instant oatmeal, gluten-free old fashioned oats, and gluten-free quick oats. This is due to Quaker’s transparency, willingness to always answer questions from Gluten Free Watchdog, and most importantly their robust sorting and testing protocols. For more information, see https://www.glutenfreewatchdog.org/news/oats-revisited-quaker-gluten-free-oats/. Note: The protocol described in this post was reconfirmed on October 21, 2022.

Other single ingredient labeled gluten-free oat products, such as oatmeal and oat flour (or products containing oats as a major ingredient, such as oat-based granola and other breakfast cereals): Other than Quaker oat products, we are not supportive of any single ingredient oat products using oats sourced from suppliers of sorted oats. This is due primarily to a lack of transparency on the part of suppliers and an inability on the part of Gluten Free Watchdog to vet sorting and testing processes.

General Mills Gluten-Free Cheerios and Lucky Charms: Gluten Free Watchdog cannot in good conscience support gluten-free Cheerios or Lucky Charms manufactured by General Mills using sorted oats. This is due largely to the testing protocol followed by General Mills. We truly wish General Mills would adopt a testing protocol similar to the one followed by Quaker Oats, a manufacturer also using sorted oats. For more information see Gluten Free Watchdog’s position statement on Cheerios available at https://www.glutenfreewatchdog.org/news/gluten-free-watchdogs-updated-position-statement-on-cheerios/.

Manufacturers of labeled gluten-free products containing oats as a relatively minor ingredient: Generally speaking, Gluten Free Watchdog would like to see manufacturers of labeled gluten-free foods use purity protocol oats. However, products can be evaluated on an individual basis. Questions to consider include:

  • Is the product certified gluten-free?
  • Has the product been independently tested and to what extent?
  • Is the manufacturer transparent about the source of their oats?
  • Is the manufacturer transparent about their testing protocols?


© March 8, 2021. Updated on October 24, 2022. Gluten Free Watchdog, LLC. All Rights Reserved.

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Comments (17)

  • Kerri Reply

    Interesting topic. My daughter has a gluten detection dog that detects gluten down to about 3-5 ppm. Oats are always a source of concern. I can tell you that the dog will routinely clear 2 of the new gluten free oreos at a time, and will alert at 3-4 oreos at a time (all held in the clean, washed, hand). This tells us that in a quantity of 2, there is less than 5 ppm. As for Quaker oats, using the sorting method, the dog has NEVER cleared any of Quaker’s products. As for Cheerios and Lucky Charms, I have only had rare occasions that the dog would not clear the cereals, at which time the box is marked with an “X”, and someone else eats that box. I have always had luck with Trader Joes oats, the dog has never alerted on them, not sure of the method they use. I think there is always a risk of contamination, no matter the product. I have had countless times that a gluten free product has been alerted on by the dog, and not just oat containing products. UDI’s is one such product, Bush’s beans is another, along with many others. I am thankful for the dog, it saves us a lot of incidental sick days.

    March 10, 2021 at 4:42 pm
    • Tricia Thompson Reply

      Thanks, Kerri. It would be very interesting to conduct a placebo controlled blinded study assessing several products using gluten detection dogs and the R5 ELISA. Gluten Free Watchdog would be willing to help fund such a study.

      March 10, 2021 at 4:54 pm
    • Evelina Reply

      The question that I always have is… Like rolled oats, right? They’re not milled, so if I don’t see any non-oats, why can’t I just wash them well to wash off anything that’s not the oats? (That’s if we put aside the avenin bit). There are no answers about this… I would be happy with an answer even as to “why not” that wouldn’t work. But it needs to make sense, as all of this oat stuff barely makes sense from most sources.

      December 8, 2023 at 10:24 am
      • Tricia Thompson Reply

        Whole grains (including oat groats) can be poured onto a cookie sheet (or other flat surface) and carefully picked through (one grain at a time) for errant wheat, barley, or rye. Grains can then be rinsed immediately prior to cooking to remove grain “dust”. Oats and barley look very similar. It may be hard to spot barley as a whole grain but super tricky when the grain is rolled (and looking at every rolled grain could be a bit tedious).

        December 11, 2023 at 4:08 pm
  • Kirsten Legner Reply

    Wow – this is comment discussion is really interesting. I know I’m kind of a nerd about this stuff but I would love to see the results of this experiment. I have a son with Celiac and have to eat GF myself. And hearing there are GF support dogs is just the coolest thing ever!! (again, kind of nerding over here )

    June 11, 2021 at 2:56 pm
  • Mary Linda Smith Reply

    I would certainly be interesting to see what other products your dog has sniffed out that have gluten. We were certainly were surprised to see Bush’s beans!

    July 20, 2021 at 2:45 am
  • Laura D. Reply

    Would love to see evidence based research comparing gluten detection dogs with the R5 Elisa! Yes please. I imagine it’s fairly complex to train a dog on gluten only with so many associated ingredients in foods, and yet what a great resource for families if there’s solid evidence of the efficacy to support Kerri (and others) anecdotal experiences. Now, can we train my cats?? Ha! Tricia THANK YOU for all your support of the celiac community. The world needs more watchdogs that aren’t partnered up with the industries they’re monitoring! Your work is truly amazing.

    September 22, 2021 at 4:26 pm
    • Tricia Thompson Reply

      Hi Laura, Thank you for your kind words and years of support.

      September 22, 2021 at 5:10 pm
  • Amanda Reply

    What’s your take on One Degree Organics Gluten Free Sprouted Oats?

    May 9, 2022 at 8:36 pm
  • Kim Reply

    Thanks for the detailed information you’ve supplied
    Agree with comments regarding the dog – would love to see a clinical trial to evaluate efficacy
    I do have an actual question. What is the best way to handle mixed-ingredient products eg from Trader Joe’s? Kind bars? I saw that you tested Joe-Joes and they were fine but how to handle things like pancake mix? Baked goods? And if the oats are more than 20 ppm, should all oat flour be discarded, or is it ok to use as a small component of a larger blend? If thinking about this from a purely proportional issue, it should be ok to use a small fraction of an imperfect ingredient if everything else is pristine (I realize that’s anathema to say). Nevertheless, I am not sure what to do. Full disclosure is I bake the majority of foods my child eats that contain oats.

    October 25, 2022 at 6:41 pm
    • Tricia Thompson Reply

      You are asking an important but tricky question. This is a judgement call and everyone must make their own decision. If a mixed food product containing oats is labeled gluten-free but the source of oats is unknown AND purity protocol is important to you, you could contact the manufacturer and ask if they source purity protocol oats from one of the suppliers in the listing. Of course, if you are in the airport and starving and the only gluten-free bar is a Kind bar, you don’t have time to contact a manufacturer. Proportion matters. If the weight amount of oats in a mixed food product is relatively low in terms of the final product (e.g., Kind Bar), then concern about a product may be lower than if oats are the main ingredient (a packet of maple and brown sugar instant oatmeal). In terms of single ingredient products like rolled oats or oat flour, the cross contact from wheat or barley may be in pockets and not evenly distributed. Yes, it will be diluted when mixed with other ingredients BUT we can’t know the level of cross contact (assuming it is there) in the portion we choose. The total gluten load of the product will obviously depend on the ppm level and the weight amount of oats used (and then the amount eaten). As an aside, when oats are tested, the sample is homogenized to hopefully evenly distribute any cross contact (this doesn’t necessarily work all that well because errant wheat, barley, and to a lesser extent rye aren’t evenly distributed within oats. These are comments off the top of my head but I hope they help.

      October 25, 2022 at 7:53 pm
      • Kim Reply

        Thanks, Tricia, for the thoughtful reply. You can see why I asked you directly!

        October 28, 2022 at 4:06 pm
  • Kate Reply

    My dad is an old farmer, he said it’s near impossible to sort oats from wheat. I believe him. I don’t eat any oat containing gf product. Studies are now showing oats cause an immune response so that is just inflaming an already stressed celiac body. Stop using oats in gf food. In addition it’s stupid that 20 ppm gluten is allowed in gf products
    Australia has zero ppm why can’t this be the standard?

    October 26, 2022 at 4:36 pm
  • Liana Yates Reply

    Are you able to test Only Oats Purity Protocol oats – 100% Canadian? “All of our oat products are held to the highest industry standards. Our farmers follow strict protocols to produce the purest product from seeding and harvest, to cleaning and delivery. Only Oats is prepared in a certified gluten-free facility to ensure they are pure and of the highest quality before they get to you.” Westoak Naturals Inc, Saskatoon, Saskatchewan 1-888-927-2944 myonlyoats.com They have steel cut, regular oats, and quick cooking. I am very sensitive celiac and I am able to use some in with my burger patties to hold them together better and soak up the juices.

    October 31, 2022 at 12:25 am
    • Tricia Thompson Reply

      Hi Liana, Only Oats used to be included in our purity protocol listing. I emailed with the CEO about a month ago. There hasn’t been any stock of Only Oats since June (although there may be some old stock available via a reseller on Amazon).

      October 31, 2022 at 9:08 pm

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