Sticky Fingers Bakeries: Enriched Wheat Flour isn’t an ingredient “processed to remove gluten”
To manufacturers of gluten-free foods (in particular Sticky Fingers Bakeries because yes, this is a label from a Sticky Fingers Bakeries’ product):
1. The FDA has a codified gluten-free labeling rule. Read it at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=101.91
2. In the codified rule, wheat flour is considered “An ingredient that is derived from a gluten-containing grain and that has not been processed to remove gluten.”
3. In the codified rule, wheat starch is considered an ingredient “that has been processed to remove gluten.”
4. This rule includes the provision that if a food labeled gluten-free includes an ALLOWED wheat-based ingredient (e.g., wheat starch), then the word wheat in the ingredients list or Contains statement must be followed by an asterisk that leads to another asterisk and the wording “The wheat has been processed to allow this food to meet the Food and Drug Administration (FDA) requirements for gluten-free foods.”
5. Manufacturers, you can’t include an ingredient NOT allowed in a food labeled gluten-free (wheat flour) and include the statement, “The wheat has been processed to allow this food to meet the Food and Drug Administration (FDA) requirements for gluten-free foods.” This is misbranding. No ifs, ands, or buts.
An example of correct labeling
- Red underline: Wheat syrup is a wheat starch hydrolysate. This ingredient is allowed in foods labeled gluten-free as long as the final product contains a level of gluten below 20 parts per million.
- Yellow arrow: Wheat is declared in the Contains statement
- White box: This language is required
An example of a misbranded label
- Red circle: Enriched wheat flour is NOT allowed in foods labeled gluten-free
- White box: This wording doesn’t apply to ingredients NOT allowed in foods labeled gluten-free
- Yellow arrow: Wheat is NOT included in the Contains statement
Comments (4)
Thanks for the explanation, RE starch vs flour. Dr Schar has products that contains gluten free wheat starch, I did not know manufacturers were not supposed to use / label the ingredient as flour.
When companies change their contents in their products there should be a warning that their product has been changed.
(eg.) Kellogs corn pops never had wheat content in their product and now do have, without any warning to the consumer.
It’s a surprise that an FDA statement about barley meeting the gluten free requirements would exist. (https://www.amazon.com/Juroku-Cha-Unsweetened-All-Natural-Artificial-Sweeteners/dp/B08BBXTWDK), That barley tea has pearl barley, barley, and malted barley. Those 3 ingredients including (only barley in the same ingredient) hasn’t been crafted to physically remove gluten. If they got furthur crafted to remove gluten: barley starch, distilled barley, and maltose would be the current ingredients.
Hmm. This is odd indeed. There must be some misunderstanding on the part of the manufacturer. An email has been sent to them. Thank you for alerting us.