Food and Drug Administration (FDA) Proposed Rule for
CSA Official Submitted Comments by Executive Director Larry Brauer
CSA Complementary Submitted Comments by VP Education and Outreach Mary Schluckebier, BS, MA
The National Confectioners Association (NCA) that the proposed rule might have the unintended consequence of prohibiting cocoa and chocolate products from bearing a gluten-free claim. Cocoa beans, the source of cocoa and chocolate products, are indigenously fermented immediately after harvest on small remote tropical farms. Comments on Docket No. FDA-2014-D-1021 Attachment on cocoa
The Food Allergy Research & Resource Program and its co-Directors, Prof. Steve L. Taylor and Prof. Joseph L. Baumert, comments on Docket No. FDA-2014-D-1021 added: "Beyond supporting the NCA comment on cocoa bean fermentation, FARRP also wishes to urge FDA to examine whether there are any other products where, like cocoa beans, the fermentation is accomplished in a remote geographical area with unlikely contamination with gluten where the pre-fermentation application of analytical methods for gluten would be cumbersome and unlikely. If so, FARRP would urge FDA to also consider exempting these fermentations from the envisioned provisions on gluten-free claims for fermented, hydrolyzed and distilled foods. In our own assessment, we believe that vanilla beans may undergo a similar fermentation and that the exemption of vanilla beans would also be warranted "