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.
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.
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 …