Extension of Comment Period for Proposed Rule for Gluten-Free Labeling of Fermented or Hydrolyzed Foods

The FDA has extended the comment period for its “Proposed Rule for Gluten-Free Labeling of Fermented or Hydrolyzed Foods“. (Thanks to Virginie for the link)! It’s a little difficult for me to translate the political speak here, but I think what they are proposing is to extend their rules for gluten-free labeling of food to fermented or hydrolyzed foods. Fermented foods includes BEER! Some of the points of the proposal as far as I can tell are:

  • The”August 5, 2013 final rule” is where the FDA established section 101.91 to define the term “gluten-free” for voluntary use in the labeling of foods
  • The 2013 rule is voluntary and this new rule for fermented & hydrolyzed foods is voluntary too
  • The 2013 rule’s definition of “gluten-free,” is that foods are either inherently gluten-free or they do not include any of the following:
    • Ingredients that are gluten-containing grains
    • Ingredients derived from a gluten-containing grain that have not been processed to remove gluten
    • Ingredients derived from a gluten-containing grain that have been processed to remove gluten if use of that ingredient results in the presence of 20 parts per million (ppm) or more gluten in the food
    • In either case, any unavoidable presence of gluten must be less than 20 ppm.

If I am reading this correctly, that first item would be important for g-f beers. Gluten-reduced beers contain barley, which is a gluten-containing grain. So according to this, the gluten-reduced beers would not be able to be labeled gluten-free. But I have a really bad feeling that I am reading that wrong, and they will allow the g-f label if the manufacturer maintains records showing that the product had gluten removed down to the 20 ppm level. This is the same policy that currently regulates g-f labeling of food.  If it has less than 20ppm of gluten, it can be labeled g-f.

Personally, I think that food and drink containing grains that contain gluten should not be allowed to be labeled g-f, no matter how processed to remove gluten they are. (I have seen voluntary labeling of these foods as “Gluten-Reduced”, which I think is the proper way to label these products). I also don’t think that food and drink that contains up to 20 ppm of gluten should be allowed to be labeled g-f, but again, that’s my opinion. Personally, I am trying to switch to eating and drinking 100% certified g-f products, as in no gluten whatsoever goes in my body. Not gluten-contaminated food, not gluten-reduced food, not up to 20 ppm of gluten food. Call me picky, but I have a disease that requires I don’t eat any gluten, and I want to feel better already, damn-it!

But no matter what your opinion, the point of my post (sorry if it’s not clear) is that we can all express our opinions to the FDA. You have until April 25th!  Here’s the link:

Food Labeling; Gluten-Free Labeling of Fermented or Hydrolyzed Foods; Reopening of the Comment Period


I’m Sara, and I’m a celiac. (Insert – “Hi Sara!”)  I was diagnosed over a year ago. Celiac disease is “when eating certain types of grains sets off an immune mediated response that causes measurable damage to the small intestine. This, in turn, interferes with the small intestine’s ability to absorb nutrients in food, leading to malnutrition and a variety of other complications.” Blah blah blah – it sucks. Big time. No wheat. No rye. No barley ever again. Not even a molecule.

The one thing I really, really, really (I’m using the word “really” here three times. Really. A lot. Really.) did not want to give up was beer. I’ve been a beer geek, since I was 18, errrr, I mean 21. Almost thirty years later, I’d guess I’ve tasted more beer than most people taste in a lifetime. I even brewed my own! Since I have quite a few health issues, including my worst – chronic daily migraine – I decided to go completely gluten-free for the rest of my life. Period. Good-bye bread, good-bye pasta, and gulp. Good-bye beer. I packed up my brewing equipment and was ready to sell it on Craig’s List.

But wait! Along with other wonderful, new gluten-free foods (including bread (sort-of) and pasta), there is a burgeoning gluten-free beer industry that reminds me of the craft brewing days of the 80’s and 90’s. Experimental brewers who create beer like you’ve never tasted before! Some really good, and some really bad. Many questions bubbled up into my mind while trying these, um, interesting brews. What the hell is sorghum? Can a celiac drink gluten-free beer made from barley? Is sorghum malt just like barley malt? Some of us may wonder just how beer is made in the first place. And most importantly, can we ever drink beer again that adheres to the Reinheitsgebot? Ummmm, WTF? (The answer is no. I think.)

Here starts my gluten-free beer quest for knowledge. Hopefully I’ll be able to taste g-f beers from around the world! You know that the best way to research beer is to drink as much of it as possible, right? I hope you’ll join me on this intriguing voyage. Let me know if you have questions along the way, and I will try to find the answers. And most exciting of all, let’s get back to drinking some good beer.



Please see my “About” page for great g-f links