Product alert: Greens Plus bar contains malt yet labeled gluten-free

Product Alert: Greens Plus Whey Crisp Protein Bar

Last week the National Foundation for Celiac Awareness (NFCA) alerted Gluten Free Watchdog that a variety of Greens Plus bar contains barley malt yet is labeled gluten-free. Barley malt is not allowed in gluten-free foods. To read the NFCA alert for this product click here.

Note: While manufacturers labeling their foods gluten-free have until August, 2014 to comply with the FDA’s gluten-free labeling rule, malt, malt extract, and malt syrup have long been considered ingredients that should NOT be included in gluten-free foods sold in the United States.

What Greens Plus Had To Say. Gluten Free Watchdog contacted Greens Plus and the Executive Vice President confirmed that the bar—Greens Plus Whey Crisp Protein Bar–is labeled gluten-free and that it does indeed contain barley malt. He also stated that as of June 1, 2014 Greens Plus will no longer be manufacturing any products containing barley malt. Gluten Free Watchdog recommended that the current formulation of this product either be removed from store shelves or have the gluten-free claim covered. Neither option appears likely to happen based on phone and email correspondence with the company.

Greens Plus believes this product to be gluten-free as currently manufactured despite the fact that it contains barley malt. In email correspondence the Executive Vice President of Greens Plus stated, “In 2012, our manufacturer Betty Lou’s, Inc who is a certified facility by the Gluten Intolerance Group (GiG Certificate ID #3274) assumed the testing of finished products and certifies every production run at a level of <10ppm…” For those who are not familiar with these organizations, the Gluten Free Certification Organization (GFCO) is a program of GIG. While Greens Plus is NOT a certified-GFCO brand (according to GFCO’s website) it is manufactured by Betty Lou’s—a GFCO-certified manufacturer and a GFCO certified gluten-free manufacturing facility (according to GFCO’s website).

Malt, Malt Extract & Malt Syrup Are Not Allowed In Gluten-Free Foods. The company was provided with the webinar statement by FDA on malt extract. To read the statement click here. The Executive Vice President of Greens Plus responded, “…the additional verbiage concerning malt extract or malt syrup contained in the webinar you presented is unfortunately not contained in the original FDA rule.” (Note: The webinar statement provided to Greens Plus was made by FDA staff not me). It is true that in the final gluten-free labeling rule, the FDA provides only one example of what the Agency considers to be an ingredient processed to remove gluten—wheat starch–and one example of what the Agency considers to be an ingredient not processed to remove gluten—wheat flour. However, just because an ingredient is not included among the examples of ingredients not processed to remove gluten does not mean it is allowed in gluten-free foods. Barley flour and rye flour are not included as examples but they certainly are not allowed. The FDA has clarified that malt and malt extract/malt syrup are considered ingredients not processed to remove gluten and therefore not allowed in gluten-free foods.

Just Because a Product Tests below 20 PPM Gluten Does Not Mean the Requirements for FDA Gluten-Free Labeling Have Been Met. It is very concerning that manufacturers of gluten-free foods continue to use malt/malt extract/malt syrup in their products. The last two manufacturers Gluten Free Watchdog has dealt with on this issue—Boulder Canyon and Greens Plus—believe their products are gluten-free because they test below 20 parts per million (ppm) of gluten. They appear to think that meeting a ppm amount for gluten is the only criterion that must be met to comply with the FDA’s rule for gluten-free labeling. This is not true. Certain ingredients are simply not allowed in gluten-free foods regardless of how much gluten the final food product contains. A manufacturer cannot add a little bit of barley flour and they can not add a little bit of barley malt extract and still be compliant with the labeling criteria.

It Is Very Difficult To Test Foods for Hydrolyzed Gluten. In addition, it is very difficult to test foods for hydrolyzed gluten—gluten that has been broken apart. Greens Plus bars are being tested with a lateral flow device (similar to a home pregnancy test) called Gluten Tox Pro. Lateral flow devices are not considered the best available tests for detecting and quantifying hydrolyzed gluten (or intact gluten for that matter). The manufacturer of Gluten Tox Pro states the following on their website, “as with any qualitative or semi quantitative test, results should be periodically validated with a quantitative test performed in an outside laboratory.” It is unclear whether this is being done.

Additional Issues of Concern

• Regardless of the fact that the Greens Plus bar is NOT GFCO-certified, why is a GFCO-certified manufacturer (ie, Betty Lou’s) and GFCO-certified facility (ie, Betty Lou’s) manufacturing a supposedly “gluten-free” bar that contains barley malt when this ingredient is NOT allowed in foods labeled gluten-free? While Green’s Plus Whey Crisp Protein Bar is NOT a GFCO-certified gluten-free brand, according to the website of GFCO, the manufacturer of Greens Plus—Betty Lou’s–is a GFCO-certified manufacturer and a GFCO-certified gluten-free manufacturing facility. It is curious why Betty Lou’s is manufacturing a supposedly “gluten-free” product that contains barley malt when this ingredient is not allowed in foods labeled gluten-free. Is Betty Lou’s aware that barley malt should not be included in gluten-free foods?

• If a certified gluten-free facility is manufacturing a supposedly “gluten-free” food that contains barley malt, are other gluten-free foods manufactured in that facility at risk of contamination? If barley malt is being used in a certified gluten-free manufacturing facility to make a supposedly “gluten-free” food that contains barley malt this potentially puts all other gluten-free foods manufactured in that facility at risk of cross contact with a barley-based ingredient. The argument that the product is testing at less than 10 or 20 ppm gluten is not sufficient. While not perfect, the best available assay for assessing the presence of hydrolyzed gluten is the competitive R5 ELISA. Based on the test results sent to Gluten Free Watchdog by Greens Plus it does not appear that this assay is being used.

Note: Gluten Free Watchdog reached out to GFCO for clarification on these issues. While GFCO responded to Gluten Free Watchdog, emails from GFCO contain a legal disclaimer that the contents cannot be shared. If you have any questions about the above issues, please contact GFCO directly.

A heartfelt plea to manufacturers: If you are going to put a gluten-free label on a food please make sure that you know the criteria for gluten-free labeling. If you discover that you have made a mistake in your labeling (and even though you do not need to be in compliance with the FDA labeling rule until August) please put the consumer with celiac disease (a serious autoimmune disease) and non-celiac gluten sensitivity first. Remove the product from store shelves immediately and take corrective action in the formulation and labeling of your product. To do anything short of this is putting the health of people with gluten-related disorders at risk.

Ingredients in Greens Plus Whey Crisp Protein Bar

Ingredients: Whey protein krisps (whey protein isolate, whey protein concentrate, tapioca starch, calcium carbonate), organic peanut butter, Omega3 Chia seed, organic brown rice syrup, organic agave nectar, Original Greens Plus Powder (gmo-free soy lecithin, Hawaiian spirulina, Appleboost peel & fiber, organic barley grass, organic wheat grass, Japanese chlorella, hydroponic soy sprouts, brown rice bran, sprouted barley malt, organic alfalfa grass, royal jelly, Montana bee pollen, acerola berry juice, natural vitamin E, licorice root, milk thistle seed extract, echinacea root extract, Siberian eleuthero root extract, astragalus root extract, licorice root powder, organic red beet juice, dunaliella salina algae, Nova Scotia Dulse, ginkgo biloba leaf extract, organic Japanese green tea extract, grape seed and skin extract, European bilberry extract), vanilla extract, sea salt.

Allergy Information: This product contains Milk, Peanuts, Soy, Wheat and Oyster-shell calcium and is manufactured in a facility that processes Tree Nuts and Egg ingredients. The Greens Plus Whey Krisp is gluten-free.

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