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About "gluten-free"

Processed foods using rice flour, etc. and labeled as “gluten-free” are being imported these years. Similarly, other products besides rice flour also have such labeling.
The standards for the labeling of mentions like "gluten-free" in western countries are different from the ones applied for the allergen labeling system in Japan (which is based on the Food Labeling Standard). Therefore, I would like to discuss this topic following the issue of an awareness-raising brochure titled "About efforts for optimizing food labeling", published by the Consumers Affairs Agency (CAA).

What is Gluten?

In the US, the Food and Drug Administration (FDA) enforced rules related to gluten-free labeling in 2013 based on the Food Allergen Labeling and Consumer Protection Act (FALCP). According to these rules, the term "gluten" is defined as "protein naturally produced from grains containing gluten and likely to negatively affect the health of patients with celiac disease". In this definition, "grains containing gluten" means grains like wheat, barley, and rye, and prolamin and glutelin are examples of protein produced from grains containing gluten.

The standards for "gluten-free labeling" in EU, USA, etc. are different from the ones for allergen labeling in Japan.

Regarding mentions that will not be considered as an "ingredient-name-labeled", the following examples are listed, as "labeling which are less likely to be requested to provide information".

Gluten-free labeling in EU, USA, etc.

  • In order to contribute and facilitate product selection for people with celiac disease, a "gluten-free"; labeling is possible.
  • When using this labeling, the gluten concentration should be less than 20ppm.

Allergen labeling in Japan

  • Since even a very small amount of allergen can trigger food allergies, it is fundamentally necessary for food containing such materials (specified in Japan) like wheat, to display those components on the label and this even when they are not used intentionally as ingredients in the product.
  • In a situation where the total amount of wheat protein exceeds a few ppm's , the labeling of the wheat allergen must be displayed on the container or package.
  • Besides, in cases where the contamination of a product by an allergen is inevitable/ ineliminable, it is recommended to put an awareness-raising statement for people with food allergies.

There is no standard for “gluten-free” labeling in Japan. It is possible to use such labeling, but even in cases where a ”gluten-free” labeling is used (based on the 20ppm standard used overseas), it is thought to be necessary to put a (disclaimer) note such as “This labeling does not mean the product does not include wheat allergen”.

When "gluten-free" is claimed in a labeling for food including wheat allergen, it is likely that consumers will assume that the wheat allergen is not included, so following the rules of the Act against Unjustifiable Premiums and Misleading Representations, it is likely to become an issue and attention must be paid to this point.

Also, in Japan, the"Guidelines for labeling promulgating rice flour products", which state that rice flour containing "1ppm or less" of gluten should be labeled as "non-gluten", were established and published 2 years ago. It is a lower standard than the ones in the EU, USA, etc. which requires (for such labeling) “less than 20ppm”, so we think that it can be used as a valuable point of reference in regards to this matter.

Reference:
About efforts for optimizing food labeling
Guidelines for labeling promulgating rice flour products

June 2019