Last week, Tracy Attridge, gluten-free blogger at Not A Trace, reminded me of some puzzling labelling on a pack of Kallo rice snacks, which crime author Samantha Hayes, who has a coeliac daughter, had drawn my attention to a few months ago on Twitter. View it here.
Here are the key points to notice:
1. In the ingredients list, ‘soya sauce powder: soya, wheat’
2. In the allergen information box, ‘contains soya and wheat’
3. Again in the allergen information box, ‘no gluten containing ingredients’.
This is one of those cases which can at first throw you – clearly soya sauce is a gluten-containing ingredient. Isn’t it? I was puzzled, and found myself revisiting the Coeliac UK site, the FSA site, and my own book’s lood labelling chapter to remind myself of the legislation and the quirks allergy labelling rules can throw up in practice. I also contacted Kallo.
Before I begin to explain this case as I see it, it’s important to remember that allergy labelling is not just for the benefit of coeliacs, but for those with food allergy and food intolerance not related specifically to gluten too.
Threshold limits have been established for gluten by which a product can be labelled gluten-free (sub 20ppm) and they have not for other allergens, including wheat: we do not have a definition for what ‘wheat-free’ is. So any wheat must be declared – as it has been on this label. This is important for those with a wheat allergy – which is distinct from coeliac disease.
Soya sauce is normally gluten-containing, I put it to Kallo, but they informed me that the soya sauce they used was gluten-free, therefore is not a gluten-containing ingredient, and that the final rice cake product tested below the 20ppm.
Why, if the final product is below 20ppm, does Kallo not describe it as gluten-free? I was told it was “a marketing decision not to make the gluten-free statement” and that the “no gluten containing ingredients” label would be removed “to avoid any further customer confusion”.
What do we learn from this?
That allergy labelling can be complex and potentially confusing, and that it is extremely difficult to find a fully user-friendly, intuitive system of labelling for all the kinds of needs and levels of understanding of individuals with disparate food sensitivities.
That some companies know that their products test below 20ppm but do not advertise the fact, for reasons which I have to confess puzzle me, but in some cases – and I’m not specifically referring to this one – may have something to do with the increased burden of having to be more stringent against cross-contamination, increased cost of more regular testing, or of the association with a ‘disease’ that a gluten-free claim can bring. I’m speculating, and if you have other ideas, I’d be interested to hear them.
That as a coeliac, when you see the ‘no gluten containing ingredients’ claim on a product you’re interested in, it’s definitely worth getting in touch with the manufacturers for clarification if something seems ambiguous.
And that thresholds for other allergens – wheat, soya, nuts, peanuts – really need to be established soon, as they have been with gluten, so that we know exactly what terms such as ‘wheat free’ and ‘nut free’ really mean in practice.
There's also the thousands of products that don't say gluten free or no gluten containing ingredients but don't list anything gluten related in the ingredients. This makes up the vast majority of things I buy… Does that mean these things haven't been tested or x-contamination procedures aren't in place? The allergen box should just state whether or not something contains an one of the main allergens, let's keep things simple…
Trouble is, it's not always clear whether it does or doesn't contain an allergen. 21ppm and it does contain gluten; 20ppm and it does not contain gluten. This line is not established for other allergens – one of the reasons we see 'may contain traces' etc.