<<Disclaimer: Verify this information before applying it to your situation.>>
 
Hi all,
 
Got a number of  emails regarding the Codex Alimentarius GF standard and I
concluded that it might be helpful to explain the status of Codex and about
what it is up to. In addition I did write down some thoughts on GF foods
that may be of interest to you. I will deal with three categories in
separate postings.
 
-     Foods officially labeled as "gluten free"
-     Foods from a gluten free shopping list
-     Foods which do not fall within the above categories
 
With respect to the first category:
 
   In the EU there is a Directive on foods for special dietary uses
(89/398/EEG), and this directive is the basis for all national legislation in
the countries of the European Union.  Though the directive deals with
glutenfree foods there is no assigned limiting level of gluten for GF food
yet, so it is up to the national regulatory bodies of the member states to
set their own level.  There is however an international body handling this
matters:  Codex Alimentarius.
 
   Codex Alimentarius is a Geneva based International organization jointly
run by the WHO and the FAO, and its aim is to establish world-wide standards
for foods in the most broadest sense.  Food legislation in many countries is
based on Codex Standards, although it is not mandatory to implement them in
all cases.  There are Codex committees producing standards on food labeling,
on hygiene, on composition etc., etc.  There is a committee on Foods for
Special Dietary Uses (FSDU) and ... there is a Standard on Glutenfree Food!
 
   The oldest Standard dates from 1981 and it says that foods may be labeled
as "glutenfree" if the nitrogen content of the protein derived from wheat is
less than 50 mg N/100 gm on dry matter, which may be equivalent to about
20-30 mg gliadin in wheat starch (The calculation is quite complicated by the
fact that most of the protein in wheat starch is "starch granule protein" and
not gluten (If you are interested in getting a more detailed explanation,
please send me an e-mail).
 
   There is a new Codex Standard in preparation and there is a proposal to
set the limiting level of gluten to 200 mg gluten/kg (20 mg/100 g) glutenfree
food on dry matter (If we assume that half of the gluten is gliadin, this
equals 10 mg gliadin/100 g o.d.m., so the level has gone down by a factor two
in comparison to the "old" standard).  If accepted, the new standard will be
valid for end products and not for raw materials.  In my previous posting I
already mentioned that there are comments on the proposal from Sweden (<20
ppm "GF" and <200 ppm for "gluten reduced"), and from the European celiac
societies <40 ppm for "GF").  Another proposition was to change the units
again to mg/100 g rather than ppm's (mg/kg).
 
   One of the reasons why the level in the Standard has not yet been effected
(the proposal has been dealt with already two years ago) is that there is no
validated analytical method (ring-tested) available to check compliance to
this level.  Though it might look rather simple to analyse gluten (it is in
general done with an Enzyme Linked Immuno Sorbent Assay - ELISA), this is a
very tricky method for gluten, especially as the term gluten is very
imprecise:  gluten is a mixture of gliadin and glutenin - each composed of
several sub-fractions - and its composition with respect to sub-fractions is
cultivar dependent.  There is also an effect of heat processing of the food
on the recovery and although excellent work has been done by dr Skerrit of
CSIRO in Australia to circumvent this problem by designing a method based on
omega gliadin, which is the most heat stable gliadin fraction, there is a
feeling that this method still needs to be improved.  Remember that agencies
charged with enforcement of food laws must be able to bring suits against
producers of non-complying GF foods.  So analytical methods needs to be
robust and accurate.
 
   Codex Alimentarius bases its standard on scientific facts and that's why
there is no zero tolerance: there is simply no scientific evidence that
this is required (at least there is no concordant view among scientists
about the maximum tolerable gluten intake), and it is reasoned that any
unduly reduction in the permissive level will reduce the number of GF food
available unnecessary.
 
   Though Codex Alimentarius has been criticized in the past for being a food
producer driven body (in 1993 the National Food Alliance (an UK NGO) produced
a report titled "Cracking the Codex" in which it was stated that even though
the voting in Codex is nation-wise - and quite often by consensus, there is a
large impact of the producer lobby, especially in the preliminary stages of
decision making), it is the only world-wide forum for food standards, and its
role within the framework of the GATT and WTO makes its work of sterling
importance in settling trade disputes.
 
   Even though there is no implemented standard in national legislation many
countries will stick to the Codex Standard.  The conclusion is that in many
countries food labeled as "gluten free" will almost definitely contain gluten
as regulatory agencies of most countries will not press charges against
producers of GF foods if the level is below the Codex Standard limit (though,
as said, some countries may have lower regulatory levels, Codex Standards do
not have the status of national laws).
 
Frederik Willem Janssen, Zutphen, The Netherlands.