Tricia Thompson, MS, RD is a nutrition consultant, author and speaker specializing in celiac disease and the gluten-free diet. She is the author of The Gluten-Free Nutrition Guide and has a MS degree in nutrition from Tufts University in Boston, Massachusetts and a BA degree in English Literature from Middlebury College in Vermont.

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Living Gluten-Free

by Tricia Thompson, MS, RD, The Gluten-Free Dietitian

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There is still so much confusion in the celiac disease community regarding food labeling, including allergen and gluten-free labeling of foods regulated by the United States Department of Agriculture (USDA). The USDA regulates meat products, poultry products, egg products (meaning any dried, frozen, or liquid eggs, with or without added ingredients), and mixed food products that generally contain more than 3 percent raw meat or 2 percent or more cooked meat or poultry meat. Hopefully the following information will help address any of your lingering concerns.

Allergen Labeling

The Food Allergen Labeling and Consumer Protection Act (FALCPA) requires that packaged foods regulated by the Food and Drug Administration clearly state on the food label when a food or an ingredient in a food is or contains protein from one of eight major allergens, including wheat.

FALCPA amended the Food, Drug, and Cosmetic Act. It did not amend the Federal Meat Inspection Act, Poultry Products Inspection Act, or the Egg Products Inspection Act under which the Food Safety and Inspection Service (FSIS) of the USDA regulates meat, poultry, and egg products.

Currently, under FSIS regulations all ingredients must be listed in the ingredients list by their “common or usual name.” Common or usual names include modified food starch, dextrin, maltodextrin, caramel, and glucose. Unfortunately, common or usual names do not always indicate the source of the ingredient. While the USDA does not have mandatory allergen labeling at this time, the FSIS believes they have widespread voluntary compliance with allergen labeling among their manufacturers.

Jeffrey W. Canavan, MPA, RD from the Labeling and Program Delivery Division of the Food Safety and Inspection Service, USDA graciously agreed to clarify some issues regarding allergen labeling of USDA-regulated foods.

Is FSIS still planning to release its own rule regarding allergen labeling? If so, do you anticipate that this rule will be similar to FALCPA? Is there any scheduled time frame for release of this rule?

FSIS has policies in place and encourages the use of allergen statements,consistent with FALCPA, and other statements that highlight the presence or absence of ingredients of public health concern; particularly the “big eight” allergens. However, FSIS will consider rulemaking if it does not continue to observe, through its prior label approval system, widespread voluntary compliance with the use of allergen statements on meat, poultry, and egg product labels. The Agency’s compliance policy guide on the use of allergens statements can be found here.

Do you have any idea what percentage of manufacturers of USDA-regulated foods voluntarily comply with allergen labeling?

FSIS evaluates approximately 60,000 labels per year for compliance with Agency regulations and policies. Through this prior label approval system, FSIS estimates that approximately 80 to 90 percent of all meat, poultry, and egg product labels bear statements that highlight the presence of ingredients of public health concern (e.g., “contains: soy and wheat”).

Currently, “modified food starch” and “dextrin” are considered the “common or usual names” of these ingredients. Are these terms considered acceptable ingredient declarations on the label of USDA-regulated food products regardless of whether these ingredients contain wheat protein?

“Modified food starch” and “dextrin” are acceptable ingredient declarations on the labeling of meat, poultry, and egg products. If these ingredients are derived from wheat, the declaration of “wheat” could be highlighted in an allergens type statement that most establishments are voluntarily including on their product labels. If the label does not bear an allergens statement and a consumer is unclear as to the source of the modified food starch or dextrin, they should contact the manufacturer of distributor for clarification. The name and address of the manufacturer or distributor is a required labeling feature on meat, poultry, and egg products.

Can you please clarify the USDA’s policy on the ingredient “natural flavors” as well as the labeling of malt extract?”

For labeling purposes, FSIS defines the term “natural flavor” in its regulations. Ingredients such as, spices, spice extractives, essential oils, oleoresins, onion powder, garlic powder, celery powder, onion juice, and garlic juice may be labeled as “flavor” or “natural flavoring.” They may be designated as "natural flavors" because they are substances used chiefly for flavor and do not make a nutritional contribution (e.g., protein) to the product. Other ingredients may be used for flavoring but need to be identified by common or usual name. Protein hydrolysates must identify the source from which the protein was derived as part of the common or usual name (e.g., “hydrolyzed ...    Continue

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@ 9:16pm ET on November 18, 2009

Today I read a blog that states that USDA requires manufacturers to disclose ANY grain (wheat, barley, rye) that is added to the meat. The post I was reading was discussing GF turkeys. This is not my understanding of the USDA laws at all. Am I missing something here, am I crazy?



@ 10:28am ET on November 19, 2009
Hi Al,

Thanks for bringing up an issue that confuses a lot of people. The USDA requires that ingredients be listed on the food label by their common or usual name. In that sense, wheat, barley, and rye ingredients must be disclosed BUT they can be listed as "modified food starch," "dextrin," "malt extract," etc. Manufacturers are not required to list the actual grain source (e.g., wheat, barley, rye) of the ingredient.


@ 2:24pm ET on November 19, 2009

I understand the common/usual name part. I was not aware or did not interpret that barley & rye is REQUIRED to be disclosed.


@ 2:51pm ET on November 19, 2009
Hi again Al,

Your understanding is correct. Wheat, barley, and rye are not required to be disclosed in the ingredients list of a USDA-regulated food product--only the common or usual name of the ingredients made from these grains (e.g., "malt extract," "modified food starch," etc).

Hopefully my explanation is clear!


@ 2:42am ET on March 12, 2016
replique montre

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