Some confusion yesterday morning (16th January 2012) on Twitter from Sainsbury’s account concerning gluten levels in foods, which follows neatly on from my post of two weeks ago which has been so widely read and commented on (thank you all who have read, commented or emailed).
It began with Si asking Sainsbury’s about the paragraph on breakfast cereals on the first page of their brand new Product Guidance for People Avoiding GLUTEN (their caps – yes a bit scary, but I’ll press on as I’m made of stern stuff). I’ll paste it here in full:
The own-brand breakfast cereals listed are suitable for a gluten-free diet even though they contain barley malt extract and the allergy advice box states “contains gluten”. This is because they have been tested for gluten and only contain a very small amount of gluten (from the barley malt extract) which is at a level that most coeliacs can tolerate.
Si enquired whether this looked ‘odd’. Sainsbury’s offered their assistance quickly, and Si asked what that ‘very small amount of gluten’ might be. This was John from Sainsbury’s two-tweet response (combined and micro-edited for clarity):
Our own brand cereals are less than 10ppm, however due to legal changes we can’t label products as gluten free if they contain any amount of gluten, items must be completely free before labeling.
We all know this is not the case. Items must be <20ppm, and not the immeasurable and probably unachievable ‘completely free’. Because I had tons of work to do I stuck my fat Italian nose in at this point and asked why a product could not be labelled gluten free if testing at <10ppm. Chris from Sainsbury’s this time:
The legislation changed last year meaning we’re no longer allowed the logo if the product has any traces of gluten.
He was presumably referring to the Crossed Grain logo and this is wrong again. You’re allowed the logo if a product has traces up to 20ppm (and you pay for the logo…). And the legislation changed several years ago – and became effective this year.
Still not giving much attention to the barley malt issue, I tweeted back, and was briskly directed to the Coeliac/Gluten-free labelling page on the Sainsbury’s site, which I’m not convinced the Sainsbury’s tweeters had themselves read. Later, Chris appeared to have done so, and said sorry for the confusion, and corrected himself, although I didn’t feel 100% reassured.
Perhaps wrongly, I’m less interested in mistaken customer service Tweeters than I am in the paragraph in the guidance document which Si thought odd, and which I thought odd too.
This is what I think the explanation is, from what I can gather. Barley malt extract is not gluten free and so must be declared on labels. If a product using barley malt extract has an allergy box, barley may be declared there too – which, we must remember, is also for the benefit of those with allergies, ie barley allergy, and not just coeliacs. But, because barley malt extract is so low in gluten and because so little of it is used in cereals, such products are often found to pass the < 20ppm test – and therefore are safe for those on a GF diet, even if claims about suitability cannot legally be made.
Do I still think the paragraph odd? I think perhaps that ‘most’ in the last line should be removed (according to legislation, ‘suitable for coeliacs’ accompanies a <20ppm, ‘suitable for most coeliacs’ accompanies a 20-100ppm – as we’re talking <10ppm, it could be argued that it should be the former), but I think it would be better to make clear somehow that barley malt extract in cereals is just one of those exceptional cases – as evidenced by its specially devoted pages in the Coeliac UK Food and Drink Directory.
So, problem solved? Sort of. Consider the following consequence of the labelling laws, which appears to fly in the face of common sense and logic:
A cereal with barley malt extract containing, as we’ve been told, < 10ppm cannot be labelled ‘gluten free’ and can bear a label reading ‘contains gluten’.
And yet a theoretical cake containing, say, 15ppm, and therefore of a greater concentration of gluten than the cereal above, and also likely to be consumed in greater quantity per serving by weight, can be labelled ‘gluten free’ and will of course bear no such label.
Seems bonkers, doesn’t it.
As I don’t believe it to be compulsory, I genuinely can’t imagine why the ‘contains gluten’ warning has been included on the cereal, and I’m not at this point suggesting Sainsbury’s are mistaken in doing so, but all this does illustrate the imperfection of allergen labelling laws and the fiendish difficulty (impossibility?) of implementing a system which is both clear and flawless.
The maddening consequence of it all is that it casts doubt in our minds – even though we probably know more than we think. Yet just when we think we’ve understood labelling’s works, another spanner gets thrown in. We’re suddenly uncertain whether we get the rules at all, and we’re left with a paralysis of crushed confidence. Can I eat that? What does that mean? I’m not even confident what I’ve written above is correct, but that’s not the worst of it: the worst of it is that later today, when I’ve moved on to something else, I’ll have forgotten some of it again, and when someone asks me about something else I can’t immediately answer – what about ‘may contain’? what about ‘made in a factory…’? – I’ll be struggling to rebuild it all and rationalise it in my head and I’ll probably come to the conclusion that no, I don’t bloody understand it at all.
NB. Edited on 19th January 2012 to correct a statement made about the illegality of making a gluten-free claim on a product including a gluten-containing ingredient. This is not true, providing the product can meet sub 20ppm gluten thresholds. Coeliac UK’s post below (comment 10) made this point, and I’m happy to put the record straight.
I have to agree. I struggle to come to eatting with eating something that has a gluten ingredient in it, no mater how small a quantity. But its all information and important for us Coeliacs to make an educated choice….
But the new labelling laws are causing doubt and havoc. Items we have happily eaten for ages are suddenly ringing alarm bells. Walkers growled and rice cakes etc have lost the Suitable for Coeliac label and know warn of being produced on a production line that also handles gluten.
The same with Bisto Best Gravy. I had a Twitter discussion with Coeliac Uk about this. Why is it in the Cuk handbook when it has these warnings. Cuk said Bisto had test results to prove its safe… Fair play, but why not use the Cross Grain or lable GF. I would be happier with these products than cereal with barely added…
But at least its being taken seriously. Guess bringing into line same as Nut labeling. Id rather be safe than sorry…. Just guess we all have to start learning our way round the supermarket again!
It is really frustrating but I think that we must all take a deep breath and try to get our heads around the fallout from the new regulations – if only because they are a very serious attempt to come to grips with the labeling laws, absolutely vital for the increasing number of people not only with coeliac disease but with innumerable other allergies.
The problem is, as Alex has so clearly illustrated, that the whole area is fiendishly complicated and is not really understood by anyone, medical experts included, as no one still knows how little of a specific ingredient that you have problem tolerating, will trigger a reaction.
Minute amounts, such as the amount of gluten in barley malt which is only used in very small quantities in a bread or a cake are always going to cause confusion and will need to be avoided by those (relatively few) who, like Micki Rose (http://trulyglutenfree.co.uk/) are acutely sensitive to any trace of gluten. But, for most people, the new 20ppm and the 100ppm 'low gluten' levels are helpful guidelines.
Thanks both for comments.
David – I don't understand the Bisto issue either. I mean, they don't have to label GF if they don't want to or use the symbol (which they have to pay for), but I can't think why they go to all the trouble of testing to make sure GF if it's not information they'll be using as a selling point.
Michelle – you're right. It's still early days. I wonder how we'll all be feeling at the end of 2012, when we've had a year to get 'our heads around' it all, as you say… Will be interesting to see…
This is a really interesting debate and a well written blog. I always steer clear from barley malt extract, purely because the word barley sends alarm bells ringing. As my symptoms aren't particularly strong at the moment, my main concern is ensuring I don't regularly consume a product containing gluten which could have detrimental effects on my health. I do however, agree with your previous blog that if there are limits which are declared safe by professionals then I will consume those products. As David said above, I was intrigued by Walkers' decision to remove their 'suitable for coeliacs' labelling. I have always eaten Walker but now they all state made in a facotry which handles…. I've continued to eat Walkers and do not appear to have had any effects but it does put a doubt in the back of your mind. The Sainsbury's reasoning is also concening, as you would not expect this sort of misunderstanding from one of the leading supermarkets.
Thanks very much for the comment. I will get around to blogging about Walkers at some point – soon I hope.
Out of interest… How much does it cost to use the cross Grain symbol?
Between £500 and £7,000 annually. http://www.coeliac.org.uk/sites/files/coeliac/licensing_information_pack_2012.pdf
It seems to me that they seem to be sitting on the side of caution – and the new regulations means they do not want to commit for fear of retribution! even when this none! Today I have eaten in well known restaurant the chicken and bacon salad dish stated on their charts as gluten free, but as I was about to order I was told they could not guarantee the product was not cross contaminated at the point of production or packing! And the risk was mine to decide. I wonder if this statement would have applied to all GF dishes on the menu?
Did they say 'gluten free' or did they say 'no gluten containing ingredients'? The term 'gluten free' is protected now and they can only use those precise words if they can guarantee it is GF, is my understanding. You should have a word with them and Coeliac UK about this, I think.
Barley malt extract in cereals is a confusing area and one which we are frequently asked about. Foods which contain 20ppm or less of gluten can be labelled gluten-free, and this includes foods that contain barley malt extract, so breakfast cereals containing barley malt extract at less than 10ppm could be labelled gluten-free.
Just to clear up the Sainsbury’s cereals debate, it looks like there is a bit of confusion about the terms gluten-free and suitable for coeliacs. Sainsbury’s cereals used to label suitable for coeliacs but have removed this. The new law means that suitable for coeliacs is now a supplementary phrase, so can only be used in addition to gluten-free, it can’t be used on its own, it must be used alongside gluten-free. Therefore Sainsbury’s are correct in saying that they cannot use this label anymore on its own, although they could label them gluten-free and also add suitable for coeliacs.
How manufacturers label their products does vary and different brands like to market their products in different ways. In some cases, manufacturers choose not to label gluten-free on products that are not specifically made for people with coeliac disease. No Gluten Containing Ingredients, or NGCI, is a statement that is not covered by the law and is being used by some manufacturers who don’t want to label gluten-free but do want to signpost products for people with coeliac disease. This wording can be used for foods that don’t have gluten containing ingredients and where cross contamination is controlled during production. This could not be used on cereals containing barley malt extract but could be used on foods like crisps, snacks and gravy mixes that don’t contain gluten.
Thanks very much for coming along to post such a clear explanation.
You say that Sainsbury's are 'correct in saying that they cannot use this label anymore on its own' – but I don't know where they have said that? (ie that they can't use 'suitable for coeliacs' because they're not using 'gluten free'.) I mean, you're right, and they're right, but it feels as if you're clarifying a point we've not challenged here.
I'll correct the remark suggesting that a product with a deliberately included gluten-containing ingredient cannot be labelled gluten-free – thanks for clarifying that.
Incidentally, and perhaps ironically, I've just checked all this in my own coeliac book (pages 26-28) and I seem to have got it correct – but would be great if you could cast your eye on it all, so that I can make any necessary clarifications for the second edition.
To mix it up a bit… amuses me that supermarket own brand cereal are recognised as at safe levels. But supermarkets also make there so own GF cereals, corn flakes, rice pops etc…. without barley extract in the ingredients and at £3 a box. Contradicts itself a bit!
Sorry about that Alex. We think the confusion coming from the Sainsbury’s response is over the issue of gluten-free and suitable for coeliacs. They only need to remove the suitable for coeliacs label because they are not labelling gluten-free, hence their comment about having to remove the logo.
We'll let you know about pages 26-28 as soon as we can!
Ah, I see… they're referring to the expression 'suitable for coeliacs' as the 'logo' – and we're viewing the crossed grain symbol as the 'logo' (rightly, in my view).
I still feel, though, that if they're choosing not to put 'gluten-free', they should make it clear it's their choice, not frame it in terms which suggests it's to do with new legislation.
Thanks again – really appreciate your clarifications.
It's interesting to see this discussion from across the pond. In the US barley malt in cereals is widely avoided by those who have celiac disease. (We still don't have any official definition for use of the gluten-free label here, but our Food and Drug Administration has proposed 20 ppm as a standard too.) One of the concerns about barley is that testing for its gluten content is not as precise as testing for the gluten in wheat unless some very specific tests are used. My understanding is that barley malt extract is hydrolyzed or broken down and that some tests miss some of the tiny fragments of harmful protein. All this means a product with barley malt could test at less than 20 ppm inaccurately unless a test designed to pick up the small fragments is used. I am not sure what kind of tests food companies in Europe are using so this may or may not be an issue for you. A few years ago a frozen waffle labeled "gluten free" but containing barley malt was introduced here. The formulation was quickly changed because gluten-free customers reacted so negatively. Interestingly, in the US, it's still not clear if barley malt would be prohibited in food labeled gluten-free, as barley is, or if it would be allowed as long as the food test to less than 20 ppm of gluten.
One of the many things US and European gluten-free consumers have in common is a complicated set of circumstances when it comes to labeling,
Thanks Amy for making a very insightful point about testing. I'd heard of this issue before, perhaps in relation to beers, but is not something I've ever explored in any depth. But, as we've seen above, some people do steer clear of barley, regardless. It will be fascinating to see what is eventually approved in the US – not only re: barley malt but on all issues concerning gluten-free labelling – but am I right in thinking Canada disallows barley malt in GF food? Thanks again for stopping by – good to have the thoughts of an authority outside the UK.
My 7yr old Grandaughter' antibodies were up at his last blood test. She had been for steak & fries at TGI's just prior to the test. The assure food to be GF and cooked seperately but who knows. My only other concern is that she has been having Asda and CoOp own brand cereal which are stated to be safe in CUK handbook.
They clearly state containBarley….is Barley not gluten containing and does this not mean that they are unsafe. Does anyone think they may be the cause???
It's impossible to answer the question on the cause of the antibodies, I'm afraid – that's for the medics or dietitians to help with, hopefully.
If the CUK handbook says it's GF, then this should be reliable. As my blog explains, 'contains barley' has to be included to alert those who have a barley allergy – which is distinct from coeliac disease.
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