Gluten Free Claims – Clear Language, Strong Controls

At events and in conversations with clients, we have heard conflicting advice about gluten free claims. Some food businesses have been told they should avoid describing a dish as gluten-free if gluten is handled in the same kitchen. Others believe they must test every dish before making the claim. This uncertainty can leave businesses reluctant to offer clear information to customers with coeliac disease.

We raised these questions with the Food Standards Agency (FSA). In its correspondence with us, the FSA stated:

“While testing is not mandatory, it is a beneficial check that the gluten-free 20ppm has not been exceeded.”

Testing every dish is not a requirement, but a gluten-free claim must be supported. The food served to the customer must contain no more than 20 mg/kg (20 ppm) gluten. Each business needs to assess its own operation, identify where gluten cross-contact could occur, and put appropriate controls, monitoring and verification in place. Testing may be useful as one way to check those controls; it does not replace them.

That assessment should follow the food from supplier to service. Check ingredient specifications and substitutions, consider storage and preparation areas, assess shared equipment and cooking processes, document cleaning procedures, and make sure staff understand what to do when a customer asks for gluten-free food. If the risk cannot be sufficiently controlled, the business should not make a gluten-free claim for that dish.

Clear language matters too. Terms such as gluten friendly or coeliac compliant do not give customers the same clear, defined information as gluten-free. Wheat-free describes something different: a dish without wheat could still contain gluten from barley or rye. Businesses should explain their practices honestly and give customers the information regarding their gluten free claims they need to discuss their requirements and make an informed choice.

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