Gluten-free claims vs. certification: what’s the difference?
“I want to test my product to ‘certify’ it as gluten-free.”
It’s a common request in the food industry— and while testing is an essential component in determining gluten content, testing alone does not automatically ‘certify’ a product as gluten-free. Certification involves a broader process, which includes compliance with specific certification body standards.
Local certification
There are currently no approved gluten-free certification schemes in South Africa, meaning there are no official gluten-free logos or endorsements that manufacturers can or should use on their products.
International certification
If you are looking to certify your facility or product and include a gluten-free organisation’s trademark on the label, we recommend working with an international certification body. Each organisation has its own requirements, certification process, and costs. For export purposes, it is advisable to partner with a certification body recognised in the destination country. In some cases, an on-site audit may be required, which could involve flying in an auditor if an online audit is not an option.
So, when can a product carry a gluten-free claim? Let’s break it down.
Gluten-free market
Understanding the need for gluten-free food products in the market is crucial, as it carries a significant responsibility for manufacturers. Gluten-free products cater to individuals who must avoid gluten for medical reasons (such as coeliac disease, non-coeliac gluten sensitivity, or wheat allergies) or who choose to do so for other reasons. Manufacturers are responsible for upholding the integrity of gluten-free claims by adhering to local regulations, which includes risk-based testing using suitable methods.
Requirements for making a gluten-free claim
According to the South African Regulations Relating to the Labelling and Advertising of Foodstuffs (R.146/2010, as amended), a product can carry a gluten-free claim only if it meets specific criteria.
According to R.146, the claim “gluten-free” shall only be permitted on a foodstuff if the foodstuff does not contain any of the following:
- an ingredient that is any species of the significant cereals;
- an ingredient that is derived from any of the aforementioned significant cereals and that has not been processed to remove gluten;
- an ingredient that is derived from any of the aforementioned significant cereals which has been processed to remove gluten so that the use of that ingredient results in the presence of more than 20 mg/kg (ppm) gluten in the end product; or
- More than 20 mg/kg gluten, where the level of gluten is determined by the R5 Mendez Enzyme-Linked Immunosorbent Assay (ELISA) for gluten (as described in the Guidelines), or other Codex-recommended methods.
Significant cereals mean wheat, rye, barley, oats, and crossbred hybrids of wheat, rye and barley.
Additionally, R.146 states the following about “naturally gluten-free” claims:
A cereal which, by its nature, is suitable for use as part of a gluten-free diet, shall not be designated “special dietary”, “special dietetic” or any other equivalent term, but may bear a statement on the label that “this cereal product is by its nature gluten-free” provided that it complies with Regulation 47(1)(a) and such a statement does not mislead the consumer.
Maintaining the integrity of a gluten-free claim
The onus of ensuring the integrity of a gluten-free claim is on the manufacturer. To ensure consistency across all batches produced, a comprehensive approach is essential, including:
- Supplier verification: Ensure that suppliers have a reliable food safety system in place and demonstrate trustworthiness, a strong understanding of gluten-free practices, and due diligence.
- Raw material sourcing: Identify and manage potential sources of gluten cross-contact in the supply chain.
- Raw material verification: Ensure that all raw materials used to make gluten-free products are gluten-free.
- Process risk assessments: Evaluate and mitigate any risks of cross-contact throughout the production process.
- Continuous due diligence: Ongoing testing and monitoring to confirm that the product remains free from gluten across different batches.
Risk-based testing
Initial product testing to prove a gluten-free claim is compulsory. Determining the right amount of testing afterwards depends entirely on the product, process and level of risk involved. The testing frequency should align with the potential for cross-contact and the overall risk management strategy for your product. For example, gluten-free oats may require frequent testing due to the high risk of agricultural co-mingling. In contrast, a confectionery product made with a minimal number of gluten-free ingredients in a dedicated gluten-free facility may only need annual testing.
It’s important to note that one test does not automatically equate to a gluten-free claim being true for all batches. A one-time test only reflects the gluten content of a specific sample at a single point in time. An initial robust gluten testing programme should provide a true representation of the prevalence or absence of gluten over time. Testing frequency can be adjusted based on factors like risk, changes in suppliers, cross-contact incidents, consumer reaction, etc.
Takeaway message
Manufacturing a gluten-free product comes with significant responsibility, requiring careful attention to ensure consistency and safety for consumers who avoid gluten for medical or dietary reasons. It’s also crucial to use the correct terminology to avoid misleading claims. When making a gluten-free claim, manufacturers should comply with regulatory gluten-free claim requirements and implement transparent risk management practices to ensure product integrity.
At FACTS, we help ensure that your gluten-free products meet regulatory requirements, providing you with testing services, as well as expert advice to guide you through proper risk management strategies. Contact us to learn more.