Celiac Support Association

CSA Comments to the FDA Docket - 

Regulations.gov - Your Voice in Federal Decision Making

Food and Drug Administration (FDA) Proposed Rule for

Food Labeling; Gluten-Free Labeling of Fermented or Hydrolyzed Foods;   Spring 2016

 CSA advocates for industry wide MEANINGFUL VERIFIABLE, and CONSISTENT gluten-free labeling definitions. 

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CSA Official Submitted Comments by Executive Director Larry Brauer  

CSA Complementary Submitted Comments by VP Education and Outreach Mary Schluckebier, BS, MA

Unofficial Submission from CSA Beer Survey on  CSA website  -  Discussion:  Naturally Gluten-free Beers and Traditional Beers with Reduced Gluten


Should there be an exemption for items like Cocoa beans and vanilla beans?

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 "

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