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My original posting wondered how much comfort should be taken from a Brach's ingredient label which did not have an allergen warning or wheat labeled as an ingredient, in view of my personal experience that this company has not been forthcoming in explaining whether or not wheat was used in their production processes or as an ingredient in their products.

I received many responses explaining that the labeling law was only effective for products made or packaged after the first of the year.  In view of the long shelf life of many foods and the use of "expiration dates" rather than dates of manufacture, it may be quite some time before products manufactured in 2005 are no longer on store shelves.  And, we may have to guess for a while, so the law may be more useful in telling us to avoid certain things than as an indicator that some products are safe.

I also received responses reminding me that oats, rye, and barley are not at this time "allergens" requiring disclosure.

Apparently, should I discover at some future date that this law is not being followed, the FDA is the appropriate enforcement agency.

Finally, it was interesting that as a sidebar, many of the responders expressed frustration with Brach's.  Apparently, my experience with their lack of cooperation is widespread.  I think success will be achieved when companies see us as a market, or an opportunity, rather than a nuisance.  Brach's apparently is the horse that is led to water but refuses to drink.

Thanks very much, everyone who was willing to share a thought on this topic.

Andy Thomson
Chicago, IL

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