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There seems to be a general lack of knowledge about what is happening on
the international level to harmonise legislation on gluten-free products.
These work is being done in the framework of the Codex Alimentarius and the
results may of importance in international trade. In fact it may be
difficult for a country to reject imports if the product complies to Codex
standards. In that case the recieving country should proof that the food
are not safe, which might be very difficult (compare the difficulty the
European Union has to ban the US hormone treated beef!).
Please... when reading the following, take into consideration that the
proposed Codex Styandard on Gluten-free food will only apply to food
products labelled as "glutenfree" and not to normal food (which may contain
hidden gluten as a constituent of an ingredient) and to contamination of
common food with wheat flour.

Now about Codex...
Codex Alimentarius is a world wide forum in which more than 160 member
countries participate. Codex is jointly run by the WHO and the FAO and its
mission is to exchange information on food safety and international trade
and to establish standards which are instrumental in facilitating
international trade. The most important role of Codex lies in the framework
of the World Trade Organisation WTO in which Codex Standards are important
references to settle international trading disputes.
Codex has two types of committees: general subject committees, dealing with
aspects like food labelling, food hygiene, methods of analysis and sampling
etc. and commodity committees - of which many have adjourned sine die -
like the committee on cereals, pulses and legumes, edible ices, sugars etc.
Standards to be adopted proceed through an eight step procedure which
provides optimal occasion for national countries and interested parties to
comment on a subject.
The elaboration of a Codex standard for gluten free products is a task of
the Codex Committee of Nutrition and Food for Special Dietary Uses,
CXNFSDU.

The first Standard on gluten free food was adopted in 1981 (Codex Stan
118-1981). It defined the cereals which are toxic to celiacs (wheat, rye,
barley and oats and crossbred varieties) and set a limit for the maximal
amount of gluten allowed in flour to be used as raw material in the
production of GF food. Because at that moment no convenient method was
available to measure the gluten content of flour directly, this limit was
set at 50 mg nitrogen/100 g. This limit was not dictated by patient need
but by the wheat starch industry. In some countries the wheat starch
industry at that time did not have the equipment and facilities to produce
wheat starch with a lower nitrogen level, and by consequence lower gluten
content. One should emphasize that this 50 mg nitrogen/100 g cannot be
"translated" into 312,5 mg gluten/100 g  (using a conversion factor
protein/nitrogen of 6.25) because most of the protein present in wheat
starch is present as so called starch granule protein (SGP), a wheat
protein fraction which envelopes the starch granule and which is not
related to gluten.
With techniques enabling the direct determination of gluten it has been
found that the gluten content of starch with 50 mg nitrogen/100 g is
approximately 25 mg gluten / 100 g, i.e. 250 ppm.

A revision of this GF standard is now well under way. During its twentieth
session, at the meeting of the Codex Committee on Nutrition and Food for
Special Dietary Uses in 1996 it was decided to proceeded a draft standard
to step 5, which implies that it will be send to governments and
international bodies for comment.
The most striking differences between the old Codex Standard and the
proposed new standard are that whereas the old Standard is restricted to
ingredients to be used in the preparation of GF food and not to
end-products, the proposed new standard applies to foodstuffs as well as
ingredients having been processed especially to meet the dietary need of
persons intolerant to gluten.

The proposed draft revised standard presents a tiered definition of "gluten
free" according to the following groups:

-  those gluten-free foods that consist of ingredients which do not contain
any prolamin from wheat or Triticum species such as spelt, kamut or durum
wheat, rye, barley, [oats] or their crossbred varieties with a gluten level
not exceeding [20] ppm
-  those consisting of the above ingredients which have been rendered
"gluten-free" with a gluten level not exceeding [200] ppm
-  a mixture of the two ingredients listed above with a gluten level not
exceeding [200] ppm.

(The meaning of having oats between [] is that in the opinion of the Codex
Committee there is not yet sufficient information to decide on its status.
Pending the adoption of an appropriate method the limiting values were also
placed between [].

In the subsidiary definitions gluten is defined as the protein fraction of
wheat, rye, barley [oats] or their crossbred varieties and derivatives
thereof and that is insoluble in water and 0.5M NaCl. This is in fact the
old Osborne definition which dates back to 1888. In a further subsidiary
definition the prolamin content of gluten is set (by default) at 50% (which
is in general correct). This prolamin fraction is regarded as the most
toxic fraction to celiacs.
It is stated that the product should be prepared with special care under
Good manufacturing Practice (GMP) to avoid contamination with prolamins.

In September 1998 the CC NFSDU had a meeting in Berlin to discuss the
draft. I will communicate the conclusions of this meeting asap in a
separate posting.

Frederik Willem Janssen, Zutphen, The Netherlands