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Source Ingredient Labeling:
Meaningful, Verifiable and Consistent
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by Mary Schluckebier
CSA Executive Director
Reprinted from Lifeline Fall 2003 |
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Living with a special diet would be much simpler if ingredient sources were clearly identified on all food labels.
The source of the ingredient should be listed on the label no matter what the level of content in the product or processing environment. Some examples on today's labels are "modified wheat starch" or " ... product made in a factory also processing peanuts." At this time, any such detail is a voluntary disclosure by the manufacturer.
Food and food labeling are of great interest to those with celiac disease and dermatitis herpetiformis. To help understand CSA's position with regard to source ingredient labeling, it is necessary to start with a bit of history.
In 1990, food labeling was set for major changes. CSA's promotion better labeling helped unify the celiac community resulting in the formation of many new CSA chapters. Work was initiated to include "gluten" in the 1990 labeling law. The cover article in the 1990 Fall Lifeline urged members to write to their congressional representatives and the United States Food and Drug Administration for better food labeling. But alas, the change was not to be.
As was noted at the time by government officials, workable laws require that the same terminology must mean the same thing to everyone. The Nutrition Labeling and Education Act enacted in November 1990 defined such terms as "lite" and "free" (example "calorie-free" ) but did not include gluten. Then, as now, "gluten" and "gluten-free" are terms with multiple meanings.
In the 1990's, Volunteer Allergen Labeling guidelines were adopted by many food manufacturers and distributors noting, "For sensitive individuals, the presence of allergens in food is potentially life-threatening." The ingredients identified as responsible for 90 percent of allergenic responses are milk, eggs, fish, crustaceans (shellfish), tree nuts, WHEAT, peanuts, soybeans, and derivatives of these products. These are appearing more frequently on food labels in the United States today and may be rightly described as the first step in source ingredient labeling.
The next step in source ingredient labeling is to have full disclosure on food labels become mandatory. A full disclosure of an ingredient's source should appear when it has been shown to affect a significant number of people. |
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Current Food Label: |
Expanded Food Label: |
Ingredients: Flour, sugar, whole eggs, whole
milk solids, vegetable oil, glucose syrup, emulsifier, modified food starch, flavoring, caramel color. |
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Ingredients: Whole grain flour (wheat), sugar (beet), whole eggs, whole milk solids, vegetable oil (safflower), glucose syrup (wheat), emulsifier (wheat starch), modified food starch (corn), flavoring (almond oil), caramel color (barley). |
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Source of each ingredient IS NOT identified |
Source of each ingredient IS identified |
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Why is source ingredient labeling on foods so helpful to those with CD/DH? Source labeling fulfills the three requirements of label information for anyone on a special diet by providing information that is meaningful, verifiable and consistent.
Let's look at those three words as they pertain to food labels. A food label is meaningful if it provides adequate information for any individual to make personal, healthy food choices. To determine if a label is meaningful, ask, "Do all the words have one, and only one, specific meaning? Can anyone who needs the information understand the words? Would an old-timer or a newly-diagnosed celiac patient understand the words? Would the uninitiated, such as friends, neighbors, caretakers, hospital or prison purchasing agents, preschool operators, nursing home kitchen staff, and restaurant staff, understand the words?" With the source ingredients clearly identified, the label becomes meaningful.
A food label is verifiable if the manufacturer, distributor, or an independent third party has provided documentation about the contents. Source identification provides useful information for people with CD/DH for several reasons:
- First, the minimum toxic level of wheat, rye, barley or oats that a celiac patient may consume without evoking an immune reaction is unknown. In the absence of any defined minimal toxic level, the only risk-free choice for a person with CD/DH is a zero-level, that is, no wheat, rye, barley or oats listed as an ingredient.
- Second, no testing method can measure zero-level of wheat, rye, barley or oats in a given food product. In the absence of a known lower limit of toxicity, CSA does not support the assumption that any detectable limit, no matter how low, is a safe amount.
- Third, today's testing methods, while getting simpler, more accurate, and more consistent, for economic reasons are not practical for use in a variety of high volume manufacturing operations. Until such a test becomes available, the source ingredient listing on a food label is the only practical, verifiable information available to consumers on special diets.
A food label is consistent if the same criteria are used to apply the same information, in the same way, to all labels from batch to batch and product to product. Source ingredients such as wheat, barley, rye and oats (W-BRO), are consistent when listed on a label. That is, wheat, barley, rye and oats have the same meaning on any label of any brand in any industry-food, pharmaceutical, cosmetics, and others-anywhere in the world. They mean either the specific grain or a derivative of that grain. There is no confusion.
Source labeling will allow those with CD/DH to have useable product information indicating the existence of toxic ingredients in any product at the point of purchase. A trip through the grocery aisles will become less daunting. No longer would it be necessary to put a promising product back on the shelf. The indecision vanishes with the presence of product labels which are consistent, meaningful and verifiable.
Getting Involved: Try this!
One CSA member, who attended the 2003 CSA Conference in Buffalo, offered this suggestion: After calling a food processor for clarification, write a letter of thanks and include a format for a "celiac-friendly" ingredient label, such as the expanded food label previously mentioned.
If all of us send even one food processor a "celiac-friendly" label, we are truly being "Celiacs Helping Celiacs."
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