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Gluten-free foods - What to consider when it comes to labelling

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Legal regulations and certification options for producers

Dec 2021. Gluten-free foods are increasingly found on retail shelves. In this article, we explain what you, as a producer, need to consider when labelling, certifying and analysing your products with the claim "Gluten-free" and the associated symbol.

Gluten as a food allergen – legal regulations

Even though celiac disease is not an allergy in the classical sense, but an autoimmune disease, gluten is classified as a food allergen in the context of food law. Food law lists 14 allergen classes, which must be pointed out on the packaging. The allergen classes are laid down in Regulation (EU) No 1169/2011, which has been implemented in German law by the Food Information Regulation (LMIV). Besides sulfite, gluten is the only allergen for which a legal maximum level exists. EU Regulation 41/2009 stipulates that foods advertised as "gluten-free" may contain a maximum of 20 mg/kg (20 ppm) gluten. A gluten content of a maximum of 100 mg/kg (100 ppm) may be referred to as a product with "very low gluten content".

Use of the gluten-free symbol

Glutenfrei-Symbol der DGZ

The gluten-free symbol (crossed grain symbol) is recognised throughout Europe and is awarded according to the standard of the Association of European Coeliac Societies (AOECS). In Germany, the German Coeliac Society (DZG) is responsible for awarding the symbol. In order to be allowed to use the gluten-free symbol on food packaging, promotional materials or the company website, it is necessary to conclude a license agreement with the DZG. This requires a successfully completed AOECS audit by an independent certification body and analytical proof that the product in question does not exceed a gluten content of 20 mg/kg. The required maximum content is therefore in line with European legislation. The symbol may not be used for unprocessed products such as milk, eggs, fruit, vegetables, raw meat and fish.

Certification according to AOECS criteria

As mentioned above, AOECS certification provides for a combination of on-site inspection (audit) and analyses. The audit covers the following topics:

  1. document management (AOECS standard preamble 1)
  2. raw materials and suppliers (AOECS Standard 7.4 + 7.5)
  3. the production process, storage and transport (AOECS Standard 7)
  4. controls (AOECS standard 7+8)
  5. identification and traceability (AOECS standard 7.10 + 7.11)
  6. non-conformity and defects (AOECS standard 7.10 + 7.11)
  7. training (AOECS standard 7.8)

Auditing according to the AOECS standard can be excellently combined with another audit (IFS, BRC, FSSC, etc.).

ELISA methods are available for the analytical detection of gluten “freeness". The immunological tests offered by Eurofins Food & Feed Testing laboratories in Germany use R5 antibodies that comply with the recommendation of the Codex Alimentarius Committee on Methods of Analysis and Sampling (CCMAS). In addition, our tests meet all other requirements of the coeliac societies for the analysis of bakery products, dairy and meat products, confectionery, spices and many more.

Successful gluten-free labelling with Eurofins companies

Eurofins Food Control Services GmbH is an approved certification body and can confirm the compliance of your production with the AOECS standard by an audit. In addition, our Eurofins Food & Feed Testing laboratory network in Germany supports you with our comprehensive analyses to ensure compliance with the maximum gluten content. Your account manager and our experts for certification and analysis of gluten-free products are looking forward to your enquiry.