Packaging equipment has the potential to cross-contaminate gluten-free products. Labelling is the primary means to inform the consumer about the potential presence of gluten. Gluten containing cereals and their products must always be declared on the label of pre-packaged foodstuffs according to the Codex-Labelling Standard. The trade around the globe must follow these improvements because of the adoption of the Codex Standards by the World Trade Organisation. In the European Union an amendment to council Directive 2000/13/EC on labelling of foodstuffs will be published by the end of 2003 which will make it mandatory to list all potentially allergenic sub-ingredients of compound ingredients, which will mean allergens will no longer be hidden. The directive will be transposed into national legislation in 2004 after which member states will have a transitional period of a year to bring in the legislation so consumers can expect to see allergen labelling on their foodstuffs in 2005. The new legislation will deal with a wide range of food allergens among others cereals containing gluten and products thereof.
Ingredient labels must agree with actual ingredients used (carton or package labels match the formulation).
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Ensure that the labels are used on the correct product. Where the ingredient ‘starch’ (or modified starch) originates from a source that contains gluten, such as starch from wheat, oats, barley or rye, the source of its cereal origin must always be given in the list of ingredients e.g. wheat starch. Advocate the use of terms commonly understood by consumers for gluten within, or in the immediate proximity to, the ingredient declaration, to provide clear communication with coeliacs. Use warning statements to highlight the fact that the food may contain gluten. These warning labels do not only apply to products packed for retail sale but also to products bulk packed for use in catering operations. Supplemental allergen statements are designed to alert coeliac consumers that the product in question may have gluten that they need to avoid. It is recognised that a certain percentage of a given product bearing the supplemental gluten statement may be free of gluten and safe for consumption by coeliac consumers. However, the gluten may be present in some of the foods manufactured on that line, thus, necessitating the use of a supplemental statement that alerts coeliacs to the possible presence of gluten. Precautionary labelling ("may contain") should not be used in lieu of GMP. Each roll, sheet or package of labels should be dedicated to only one product. Conduct label audits and confirm that labels match the finished product. Verify label accuracy when ingredients or formulations change. Discard old labels or packaging materials. Processing aids that contain allergen ingredients must be on the finished product label. Gluten-free food products must always be pre-packed and labelled according to the regulations when sold in shops. This applies to bread and confectionery products. Packing and labelling ensures that ordinary and gluten-free products cannot be mixed. The packaging material in direct contact with the food should be checked to make sure that it does not contain any allergens e.g. foil coated with wheat ingredients as a releasing agent. If a part of manufacturing or packing is done by subcontractor, manufacturer or packer must know the subcontractors’ critical control point system plan for ensuring gluten-free products’ safety.