AOECS position on Precautionary Allergen Labelling
Version 1 / 2024
Summary
It would be detrimental to millions of consumers not to include all cereals containing gluten (and products thereof) from the CCFL PAL Guidelines due to a ‘lack of evidence’ for gluten toxicity or the absence of a reference dose for gluten.
Codex has had a Standard for foods for special dietary use for persons intolerant to gluten (CXS 118-1979) and a safe threshold of no more than 20 mg/kg for many years. Hence there is an established reference concentration for gluten anchored in a Codex Standard.
We welcome the Electronic Working Group acknowledging coeliac disease in the latest revised guidelines on the use of precautionary allergen labelling under the Purpose section; we now urge CCFL to consider all cereals containing gluten and the existing gluten threshold.
Call for action
We urgently request that the level of gluten not exceeding 20 mg/kg in total and the needs of the coeliac community are considered alongside the needs of people with IgE-mediated allergies; and that all cereals containing gluten be included in the proposed draft guidelines.
Facts
- The gluten found in the cereals wheat (i.e. all Triticum species, such as durum wheat, spelt, and khorasan wheat), barley and rye (collectively referred to as cereals containing gluten) triggers an autoimmune reaction in people with coeliac disease.
- Proteins in wheat can cause, in some people, IgE-mediated allergic
reactions (wheat allergy). - In the case of Unintended Allergen Presence (UAP) and any Precautionary Allergen Labelling (PAL), people with coeliac disease rely on a concentration of gluten (i.e. portion independent); for people with an IgE mediated food allergy the proposal suggests an action level/reference dose (per portion). This causes a discrepancy.
- People with coeliac disease and people with IgE mediated allergies both rely on the correct labelling of foods — including PAL — to make safe food choices.
What are the issues?
Safety
For smaller food portions (< 200 g), the presence of wheat protein at 5 mg or less is unlikely to trigger the presence of PAL for wheat; however, there is a risk of high concentrations of gluten, above the 20 mg/kg threshold, posing a risk for people with coeliac disease. Potentially harmful concentrations of other cereals containing gluten such as spelt, barley and rye would be ignored altogether. See yellow section in the table.
Choice
For bigger portions (> 200 g), a presence of wheat protein at 5 mg or above, is likely to trigger PAL for wheat (as RfD is based on serving size); however, the concentration of gluten is likely to be very low and therefore not cause a problem for people with coeliac disease.
A PAL for wheat would deter people with coeliac disease to consume these foods although they are safe for them and therefore reduce choice. See blue section in the table.
Regulatory
The existing Standard for foods for special dietary use for persons intolerant to gluten (CXS 118-1979) – where the gluten concentration in foods must not exceed 20 mg/kg (20 ppm) – has not been considered in the CODEX draft proposal for PAL. This creates a discrepancy and it’s unclear how the proposal and the standard can sit alongside each other. The standard is based on a concentration, the proposal to use a RfD, is based on a serving size.
Safety
For smaller food portions (< 200 g), the presence of wheat protein at 5 mg or less is unlikely to trigger the presence of PAL for wheat; however, there is a risk of high concentrations of gluten, above the 20 mg/kg threshold, posing a risk for people with coeliac disease.
Choice
For bigger portions (> 200 g), a presence of wheat protein at 5 mg or above, is likely to trigger PAL for wheat (as the RfD is based on the serving size); however, the concentration of gluten is likely to be very low and therefore not cause a problem for people with coeliac disease. A PAL for wheat would deter people with coeliac disease to consume these foods although they may potentially be safe for them to consume (reducing choice).
Download the full position paper for a more detailed reading.