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

***Note: What follows is the opinion of Gluten Free Watchdog. Whether you choose to eat 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, GF Harvest, Montana Gluten-Free Processors, Glanbia, and MGM Seed & Grain.
  • Is supportive of manufacturers using gluten-free oats solely from the above purity protocol suppliers.
  • Is supportive of 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 products containing oats as a relatively minor ingredient use purity protocol oats. However, products can be evaluated on an individual basis (please see below for questions to consider)
  • Is not supportive of General Mills gluten-free Cheerios or Lucky Charms.
  • Is on the fence about Nabisco gluten-free Oreos (please see below for details)


First some facts:

1. Oats are considered a naturally gluten-free grain.

2. They 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 suppliers of purity protocol oats (and manufacturers using oats solely from these suppliers): Avena Foods, GF Harvest, Montana Gluten-Free Processors, Glanbia, and MGM Seed & Grain. 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/

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/.

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, oatmeal cookies, granola bars): 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 versus our recent test results. 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 updated 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?

Nabisco Gluten-Free Oreo Cookies: Gluten Free Watchdog is on the fence about this cookie. We have tested numerous packages and test results are very encouraging. We love that the actual cookie includes a gluten-free imprint. This is brilliant. This product is also certified gluten-free by GFCO*. According to the manufacturer, Oreo cookies are made with GFCO certified gluten-free oats and manufactured in a GFCO certified facility. However, despite repeated inquiries, Nabisco will not answer a simple question about their oats–are they sorted or purity protocol? In the opinion of Gluten Free Watchdog, it is very problematic when a manufacturer refuses to disclose the source of their oats. This is less about their choice of oats (sorted versus purity protocol) and much more about their unwillingness to be completely transparent with a community of folks with celiac disease and gluten-related disorders


Final note to suppliers, manufacturers, and certifying organizations: It is understood that over the years, improvements have been made to protocols for sorted oats. Not all sorted oats are created equal and not all purity protocol oats are created equal. As improvements continue to be made, purity protocol oats aren’t automatically “safer” than sorted oats. As mentioned earlier, 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. Regardless, many in the celiac disease community, including Gluten Free Watchdog, view sorted oats with skepticism. The reasons go back years and have to do in large part with the lack of transparency.

Purity protocol oats made their debut around 2004 and remained the only gluten-free option for years. For most folks, Cheerios was their first exposure to sorted oats and this brand got off to a rough start due to an early recall.  What many in the community didn’t realize at the time is that when gluten-free Cheerios premiered in 2015, sorted oats were already in many foods labeled gluten-free. Unfortunately, suppliers, manufacturers, and certifying organizations were not forthcoming with this information. One former purity protocol manufacturer/supplier (no longer in business) even made the change to sorted oats without letting consumers know. This lack of transparency led in large part to a lack of trust in sorted oats. Trust is hard to win back and this is why transparency now is so important.

*Statement from GFCO: Manufacturers come to GFCO to ensure the safety of their products, and they are fully transparent with us as part of the certification process. Contractually, we cannot reveal propriety information about a brand that we certify, but we also won’t certify a product if it isn’t safe.

GFCO stands by our earlier response, which is that there is no reason to differentiate between purity protocol and mechanically sorted oats when either is used in a certified product. Both methods can and do result in safe oats, and all oats used a GFCO certified products must contain less than 10 ppm of gluten.

GFCO doesn’t blanketly accept terms like “purity protocol” or “mechanical sorting” to determine product safety, as those terms don’t begin to encompass everything that we expect our clients to do. From in-depth annual audits, to proficiency testing, suppler approval, and regular review of data from testing and visual examination of both ingredients and products, we work to make sure their products meet our standards.

© March 8, 2021. Gluten Free Watchdog, LLC. All Rights Reserved.

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Comments (8)

  • Kerri

    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
  • 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

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