If these gluten labeling laws pass, Gluten grain derived ingredients will be outlawed in all food.
Also, 20ppm gluten will be the limit of gluten in a gluten free product.
On one hand, this makes me happy. I’m so glad that this frightening practice of removing gluten from a gluten grain and calling it “gluten free” will be outlawed in more than just beer (I wrote about that here). On the other hand, I’m very unhappy that 20ppm is still in place.
First off- if this is from the FDA, how does it affect gluten free cosmetics?
Well as far as I know, no country has gluten free labeling laws for their cosmetics. What ends up happening is that the gluten free laws for food simply become the gluten free standard for all products that need to be gluten free. The country cannot police it once it’s outside of food, it just keeps everyone on the same page.
So legally, this does not affect anything gluten free cosmetic related. It will affect everything in how people view gluten free.
Case in point: Both Mineral Fusion and Arbonne have products they advertise as gluten free with ingredients that are directly derived from gluten grains. If this new law passes and outlaws that practice in food, it will pull the rug out from under these “gluten free claims” by saying that it isn’t good enough for gluten free food. So it follows that it’s not good enough for cosmetics either.
This is something I have a history of fighting for and I firmly believe that outlawing it in food is an excellent thing.
But 20ppm gluten allowed in my food?
I have a very simple problem with this. Celiacs and gluten sensitive can still react to <20 ppm gluten.
How do I know this? The FDA told me so.
Here’s an excerpt from an extremely well researched, well written article about the issue of <20 ppm:
The final sentence of the FDA Health Hazard Assessment report (Ref. 2, p. 46) states that:
In sum, these findings indicate that a less than 1 ppm level of gluten in foods is the level of exposure for individuals with CD on a GFD that protects the most sensitive individuals with CD and thus, also protects the most number of individuals with CD from experiencing any detrimental health effects from extended to long-term exposure to gluten.
It is important to note that a 1 ppm threshold would be beyond the capabilities of current assay, which creates a quandary for the FDA.
As explained earlier, there are remarkably few clinical studies which actually address the question of the specific dose of gluten that is safe for a celiac. Two publications were of particular concern to the FDA. One widely cited paper by Catassi et. al. (Ref. 10) was a small pilot study which attempted to define a safe intake of gluten. Thirteen celiac patients were tested with 50 mg gluten per day and showed a statistically significant level of mucosal damage compared to placebo. At the lower dose of 10 mg per day (which would correspond to 400 g food containing 25 ppm gluten), no statistically significant effects were observed. However, the authors noted:
The gluten microchallenge disclosed large interpatient variability in the sensitivity to gluten traces. Some CD patients showed a clear-cut worsening of the small-intestinal architecture after ingesting only 10 mg gluten/d[ay]…
and cautioned that:
Because of the limited number of patients, we were not able to reach firm conclusions about the potential toxicity of 10 mg gluten/d[ay], which remained a “gray” area.
You can read the whole article HERE. They pretty sum up all my conclusions, opinions and strong beliefs on the matter of gluten free labeling.
But in short, we have evidence that extremely small amounts of gluten, down to 1 ppm, can cause Celiacs to react.
So <20 ppm may simply not be good enough to keep all Celiacs safe.
I appreciate that the FDA is not trusting our tests that can go down to 5 ppm, which is their cited reason for going with <20 ppm. But I’m not at all happy that they are willing to put this into law before they find a test they trust to go lower than <20 ppm. It sets a precedent that may be difficult to overturn as time goes on. You’ve seen how long it’s taken for this to even go into final review. It’s been 9 years, folks!! More and more people are being diagnosed as Celiac, not less. This is something that will continue to gain importance as more of the population requires gluten free food. Is it really worth letting the very dubious <20 ppm sit as our law for potentially another decade?
So this news puts me somewhere in between ecstasy and anger. Heh. Yay/grrr?