Gluten free is ‘dead’: some analogies

It’s been a year and a bit since ‘gluten free’ labelling changeover became official. Although I’m aware of some of the problems it has caused (e.g. the Walkers case), I still approve of what has happened, and feel it has bedded in reasonably.

I understand confusion can and does still arise because ‘gluten free’ labelling law isn’t always intuitively compatabile with the allergen labelling laws which preceded them (it’s not unheard of to come across a product labelled both ‘gluten free’ and ‘contains barley’), but I still feel that’s an inevitability of the complexity of the subject and not the fault of those behind the new(ish) labelling law, per se.

There is, though, a form of ‘silent’ or casual confusion about the term ‘gluten free’, which manifests itself subtly, and which is fairly common. That, and the potential problems associated with it, is what I want to explore in this post.

Playing dead

A reminder: ‘gluten free’ now describes a food with 20 parts per million (ppm) or fewer of gluten. Anything above 20ppm is not gluten free. (I know we have the elusive ‘very low gluten’, but that’s still not ‘gluten free’.) ‘Gluten free’ is not a specific point in the 0-20ppm range: it is anywhere within it, no matter where.

This is important: what has happened is that the state of ‘gluten-free-ness’, if we can call it that, has been made absolute by labelling laws. A product is either ‘gluten free’ or it is not. There are only two possible states. And in this it mirrors other absolute adjectives, such as dead, pregnant, perfect, essential or unique.

Let’s take ‘dead’. You are either dead, or you are not dead. One cannot be very dead, quite dead, or a bit dead. Talk of someone being ‘completely dead’ and you’re using one word too many. Dead is absolute, and so unqualifiable.

Well, so is ‘gluten free’. It’s easy to look upon a biscuit which tests at 5ppm as ‘more’ ‘gluten free’ than one which tests at 15ppm, but that’s no longer true. It may have a lower gluten content, but it is not ‘more’ ‘gluten free’, as counter-intuitive as that may sound.

Similarly, your great-grandfather is not ‘more dead’ than the fly I just swatted. He has merely been dead for a longer period of time, rest his soul.

Let’s try the pregnancy analogy. A woman at eight months is at a more advanced stage of her pregnancy than a woman at one month, but she is not ‘more pregnant’ than her.

So: Both dead, both pregnant, both ‘gluten free’. When it comes to foods and labelling, there are no degrees of ‘gluten-free’. It just either is or isn’t. Dead or alive. Pregnant or not.

Because ‘gluten content’ is a number, and ‘gluten-free-ness’ is a yes-or-no, the former is best imagined on a scale, and the latter as a division of two zones.

And so a final analogy: you are not ‘more French’ if you are born and bred in Dover or ‘more British’ if you are born and bred in John o’Groats – you are equally British so long as you fall within the ‘zone’ of Britain.

Similarly with Gluten Free Land. If you live in 3ppm-ville or 19ppm-on-sea, you are a ‘gluten free’ national – no ifs nor buts, no matter how ‘close’ you are to Not Gluten Free Land’s border.

With me?

Does it matter?

I think so, because using terms such as ‘completely gluten free’ and ‘100% gluten free’ risks misleading and confusion.

My argument is we shouldn’t be asking ‘Are you 100% gluten free?’ because the automatic, can-do answer is ‘Yes, we’re 100% gluten free!’ – and the temptation could follow to trumpet that inappropriately or even add it to labelling. It could be infectious: “100% gluten free” trumps a competitor who is merely “gluten free”, after all, and who wants to be left behind in the newly competitive arena of ‘free from’?

When you ask such a question – and I’ve seen and heard it a fair bit online – you risk either instilling doubt in a possibly safe establishment or producer, or else paranoia that there is some other loftier standard of gluten-free-ness to be met, when there is none. “What? We’re only ‘gluten-free’? Oh balls! We need to be ‘absolutely totally gluten-free’, not just ‘gluten free’!”

There should be no degrees of ‘gluten-free-ness’ and thankfully, the law should help protect against it. As far as labelling is concerned, qualification of the term ‘gluten free’ is not even allowed, as page 15 of Food Standards Agency’s Guidance on the Composition and Labelling of Foodstuffs Suitable for People Intolerant to Gluten will tell you. I’ve been unable, though, to find an example on actual packaging (but let me know if you have seen some).

Elsewhere, though, it crops up quite a bit: Just so Natural call their products ‘completely gluten free’, the supplement company Natures Whey regularly describe their products as ‘one hundred percent coeliac compatible’, and even Coeliac UK have fallen foul, dubbing Hambleton Ales ‘totally gluten free’. Mine was describing a dish I cooked as totally GF, but I know I’ve messed up in conversation too.

Another consequence of this is that some could misinterpret an expression such as ‘completely’ or ‘100% gluten free’ as meaning 0ppm: a problem, given we can’t test to this absolute degree of accuracy, and cannot give such a guarantee of zero gluten content to any food at all.

So it’s either gluten free (0-20ppm) or not (>20ppm), no ‘completely’ nor ‘totally’ nor anything else, and if you happen to feel resistant to this, well, at least as far as food labelling is concerned, it’s the law – but even outside labelling, I feel it’s something we would benefit from honouring. It keeps things simple and clear, and we know that complexity and doubt breeds confusion and misinformation.

Gluten-free is ‘dead’, then, but long live gluten-free? Over to you …


  1. Annie

    Whilst I understand the point you are making, and particularly in the light of labelling of pre-packaged products, I have to disagree to a blanket disapproval of using the term "100% gluten free". We use the term in application to our premisis and environment and it is something that provides unbelievable security to those who, for example, dine with us at the supperclub. We are expressing the point that, unlike the vast najority of eating establishments that offer a gf menu (or to cater for gf diets), and unlike many of the smaller businesses in the gf marketplace, we do not have a shared kitchen. No gluten containing products are ever used, anywhere. Period. Only labelling, already certified gf ingrdients or naturally gf ingredients (unprocessed) are used here. For some who believe they are very sensitive" that is reassuring. But even for others, it just means they know they don't have to question, double check, ask to read the labels, as about our policy for handling cross contamination etc etc etc. So, in our context, we are very happy to declare Annie's to use a "100% gluten free" kitchen.

    My biggest argument over the bew labelling is that, as with so much legislation, it is toothless. Meaningless. Try phoning your local trading standards to report a business using the term "gluten free" incorrectly and they have no idea what you are talking about. No one is checking! No one is holding anyone accountable to the new rules and we are simply, as always, relying on the assumption that firms will comply. One could assume that the "big" players are complying and checking/testing I but the the recent horse meat scandal proves that to assume that would be at best slightly naïve..

  2. Annie

    Sorry for the typos above – I blame using my phone whilst on a bus 😉

  3. Alex G

    Typos in a comment are entirely forgivable – especially given the thoughtful content!

    I understand your thinking, of course, but I can't resist asking what the difference is between a 100% gluten free kitchen and a gluten free kitchen? Do you think your diners would not get it without the 100% – would they still have to double check etc?

    I think part of the point I'm making is that 'gluten free' should be the ultimate in reassurance. It clearly isn't if people want a 'greater' reassurance than that. How else to remedy that problem without insisting on not qualifying the term GF?


    I think there is a level of difference between advertising your kitchen as 100% gluten free to indicate you have nothing with gluten in the kitchen, to the food labelling standards which indicate you should either label your product as gluten free or not, and as you say there is no greater level of gluten freeness, a product either is or isn't. I understand your point that is it necessary to say the kitchen is '100%' gluten free but I do think it serves to emphasise the point as an entirely gluten free kitchen is not often come by, as compared to the multitude of gluten free products out there. I suspect if you didn't say 100% gluten free you would get disbelieving customers messaging to confirm is your kitchen actually totally gluten free!!

  5. The Lazy Baker

    In an ideal world, there would be the simplicity of 'gluten free' and 'not gluten free' in the same way as in an ideal world black would be black, white would be white and there would be no grey in between. I feel that often, particularly where restaurants are concerned, there are unacceptable levels of respect for the term 'gluten free', whether is be 100% or otherwise, and what it actually means. I worked on the shop floor of a bakery once which sold some cakes labeled as gluten free. At the time I was largely unaware of gluten related allergies or diseases. It is only now, retrospectively, and with a much more in depth knowledge of Coeliac disease and gluten free requirements, that I have come to realise that there is no possible way those products were gluten free, being made in a kitchen alongside non gluten free products. I have no doubt cross contamination was rife. The fact that they were allowed to label that product gluten free, without any regulation or supervision is a little terrifying. Are there food standards agencies for these things? I am not sure, but what I am sure is that anyone eating those products under the impression that they were gluten free had been entirely misled.

    As a customer I would feel reassured and confident eating at Annies supper club. The bottom line is that I personally look for any extra guarantee I can find, because however things are labelled, as someone who is new to Coeliac disease and to a gluten free diet, any extra reassurance is welcome, often favoured, because I have an issue with trusting what is and is not gluten free. I 100% agree that in an ideal world labelling should be 'gluten free' or 'not gluten free', and this should be a 100% guarantee. But when, as mentioned above, gluten free is a term any tom, dick and harry can claim and throw around, i understand the desire to want to set oneself apart by going the extra mile with how you label your product/restaurant/establishment.

    But equally, how great it would be that it was as black and white as gluten free or not. Simple straightforward labelling which was trustworthy and reliable. I feel for people and establishments who are doing it properly , legitimately and with passion, being up against those who simply don't.

  6. DavidJ_GF

    I can see both sides to the argument. There has long been needed a defined point where the term "Gluten Free" should start and come in… This ultimately is there to legally give protection to the Coeliac or Gluten Free consumer. Definitely a good thing and welcomed.

    But as in replies above, there are flaws with this laws. IE not giving any protection to cross contamination in restaurants/shops etc. that sell certified good and so… Obviously this wasn't the goal of the rule change. But believe is still an issue and can lead to false

    My main concern/disagreement with some points in your piece and the "Gluten Free" clarification being products tested below 20ppm. Is that an item that has Gluten in as part an known ingredient, can be classed as "Gluten Free" For example prescription loafs that contain Codex Wheat starch or the Super Markets own brand cereals. How can something be "Free" from it, when its known to be in there. This is where I believe the term 100% Gluten Free comes from. The legal classifications undermines companies and establishments such as Annie's that do operate as such.

    Again we do understand there has to be a clear line in the sand. Otherwise it just caused over confusion. But still doesn't sit right with me.

    I think that given that we all know Coeliac Disease is massively under diagnosed. Every individual Coeliac reacts differently. That all previous studies and test as to what levels of Gluten are safe to be consumed, have come from such a small spectrum of "all" Coeliac's (Diagnosed or otherwise) I don't feel its right to just universally stake the ground and say this is right for all! So it that respect I still welcome the different descriptions/terms of Gluten Free.

    It’s such a huge web. Obviously difficult for all involved… Charities, Restaurants, Individuals and Food Manufactures. Glad I’m not making the policy.

  7. Alex G

    @ The Lazy Baker
    Thanks for such a good long comment.

    Not sure I follow the ideal world black/white points. Grey brings variety, and degrees and shades are welcome in many aspects of life, but as far as labelling and gluten is concerned we do have black and white – GF and non-GF. It is a pretty clear cut law, and much needed.

    I don’t know when you may have been working at the bakery, but if the period preceded the introduction of gluten-free labelling legislation, then the regulation wasn’t in place, and nobody was being misled if the products were made with no gluten-containing ingredients. Lack of awareness meant that no doubt there was contamination, and some coeliacs experienced symptoms, but the law was partly introduced to protect against such a thing.

    Can any Tom, Dick or Harry can throw a GF claim around? I’m not sure that’s the case, or that labelling is not trustworthy. While there will always be mistakes / product recalls, I feel generally it works well and used appropriately, at least on food labelling. As Annie says, in cafes and restaurants, it appears to be different, and lack of policing may well be a problem…

    Thanks again – Alex.

  8. Alex G

    Thanks also for long comment, David – glad you managed it 🙂

    You seem to be making a distinction between food in which we know there is trace gluten below 20ppm (eg codex bread) and food in which we don’t know there is trace gluten between 20ppm (eg rice flour?).

    I do feel it’s a bit idealistic to assume the latter is “100%” or necessarily ‘better’. Gluten gets places. Contamination is rife. Non-rendered gluten-free flours have been found to contain varying levels of gluten contamination.

    I understand your gut feeling about Codex foods, and I know it’s a view shared by many, but the irony is that Codex-containing foods – generally made by larger companies, supplying to NHS – are far more likely to undergo the most rigorous of testing and checks, because mistakes would harm a lot of people and do damage to reputations as well as health.

    There will I’m guessing be fewer checks in some ‘naturally’ gluten-free rice flour, where assumptions of gluten-free-ness may casually be made.

    And it’s low level contamination of even the most apparently safe product that really makes it impossible to attain 100% of any description. I disagree with the use of the 100% term because of that, but also because 0ppm cannot be measured or proven, and is probably unlikely to be attainable.

  9. PhilR Goodwin

    I can understand the attraction of an entire food premises being "completely" or "100%" gluten free but would agree with Alex G that it "just ain't possible"! You can't prove a negative and it is pretty much (or actually!) impossible that any premises, no matter how good their controls, is "100% gluten free" all the time…

  10. Pingback: Prêt a Mang … Er? | Allergy Insight

Leave a Reply

This site uses Akismet to reduce spam. Learn how your comment data is processed.

By continuing to use the site, you agree to the use of cookies. Please read our Privacy Policy and our Affiliates Disclosure in 'About' more information

The cookie settings on this website are set to "allow cookies" to give you the best browsing experience possible. If you continue to use this website without changing your cookie settings or you click "Accept" below then you are consenting to this.