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