<<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.