Labeling Gluten on Packaged Foods is Commensurate with the American Food Industry's Existing Global Operations
To gain a better understanding of the support from the global food industry for the mandatory declaration of Gluten on all food labels, it's instructive for the FDA to review the following best practice guidance from the Food & Drink Federation ("FDF") in the United Kingdom entitled, "Gluten Labelling Guidance: Best Practice for Prepacked Foods which Include or Exclude Cereals Containing Gluten ("Gluten Labeling Guidance")."
The FDF is "the voice of the UK food and drink industry, the largest manufacturing sector in the country." The FDF's Gluten Labeling Guidance was published in June 2019 in partnership with Coeliac UK, Anaphylaxis Campaign, BRC (British Retail Consortium), and GFIA (Gluten Free Industry Association).
"The Food Standards Agency welcomes the FDF's [Food & Drink Federation] work to achieve greater consistency in how the presence of cereals containing gluten and gluten-free claims are labelled on prepacked foods. Having a trusted consistent approach will make it easier for people with coeliac disease or with allergies to these cereals to find and understand the labelling information they need. And that means they can make safer food choices. I am very pleased to see further progress in this important area of public health and consumer protection." (emphasis added) -- Heather Hancock, Chairman of the Food Standards Agency, United Kingdom (FDA’s comparable regulatory agency), 2015-2021
Requiring the labeling of Gluten (Wheat, Barley, Rye & Oats) as a Major Food Allergen on all packaged foods in the U.S., like Gluten must be declared on all food labels in 87 other countries, will better protect 3.3 million American Celiacs.
Best Practice for Prepacked Foods which Include or Exclude Cereals Containing Gluten
Labeling Gluten is in alignment with the conclusions of international food safety authorities and expert committees comprised of scientists, regulators, physicians, clinicians, and risk managers from academia, government and the food industry, as well as consumers, including:
2021 Food and Agriculture Organization of the United Nations/World Health Organization Expert Consultation on Risk Assessment of Food Allergens, which included the FDA’s Dr. Lauren Jackson, Chair, and the FDA’s Dr. Stefano Luccioli ("2021 FAO/WHO Expert Consultation"). The 2021 FAO/WHO Expert Consultation found, "Based on systematic and thorough assessments which used all three criteria (prevalence, severity and potency), the Committee recommended that the following should be listed as priority allergens: Cereals containing gluten (i.e., wheat and other Triticum species, rye and other Secale species, barley and other Hordeum species and their hybridized strains), crustacea, eggs, fish, milk, peanuts, sesame, specific tree nuts (almond, cashew, hazelnut, pecan, pistachio and walnut)." (emphasis added)
The Food Industry Partners with Key Players to Ensure Food Safety & Consumer Trust in the United Kingdom
Given that Gluten is required to be labeled on packaged foods in 87 countries worldwide, many of the multinational consumer-packaged food manufacturers already label Gluten on their products sold in those 87 other countries. As such, labeling Gluten is in the United States would be commensurate with many multinational's existing global operations and best practices.
"The Food and Drink Federation (FDF) is the voice of the UK food and drink industry, the largest manufacturing sector in the country. We communicate our industry's values and concerns to Government, regulators, consumers and the media. We also work in partnership with key players in the food chain to ensure our food is safe and that consumers can have trust in it."
With a little help from our friends at the FDA, the United States can protect Celiacs in the United States, just like the FSA protects consumers in the United Kingdom!
Lessons Learned Over Two Centuries
On July 6, 1976, Queen Elizabeth spoke at the dedication ceremony for the Bicentennial Bell at Independence National Historical Park on July 6, 1976. At the ceremony, the Queen made some profound historical remarks including important lessons learned,
"I speak to you as the direct descendant of King George III. He was the last Crowned Sovereign to rule in this country, and it is therefore with a particular personal interest that I view those events which took place 200 years ago. It seems to me that Independence Day, the Fourth of July, should be celebrated as much in Britain as in America. Not in rejoicing at the separation of the American Colonies from the British Crown but in sincere gratitude to the Founding Fathers of this great Republic for having taught Britain a very valuable lesson." -- Queen Elizabeth, July 6, 1976
History teaches us that the FDA can learn a valuable lesson from its UK counterpart, the Food Standards Agency, and the Food & Drink Federation when it comes to requiring the labeling of Gluten on all packaged foods in the U.S.
The guidance from the Food & Drink Federation shows that there are not really "people on all sides of requiring the labeling of Gluten" as the FDA Commissioner purportedly claimed when 10-year-old Jax Bari bravely spoke truth to power to our nation's health leadership in front of 400 people at the HHS Food is Medicine Summit and asked them to help protect Celiacs by requiring the labeling of Gluten on all food products.
It's high time for the FDA to give it a go and grant Jax Bari's FDA Citizen Petition to require the labeling of Gluten on all packaged foods in the U.S. and catch up with what 87 other countries have been doing to protect Celiacs! As the British say, easy peasy!
Reference
GLUTEN LABELLING GUIDANCE: Best Practice for Prepacked Foods which Include or Exclude Cereals Containing Gluten, Food & Drink Federation, in partnership with Coeliac UK, Anaphylaxis Campaign, BRC (British Retail Consortium), and GFIA (Gluten Free Industry Association, June 2019.
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