Big Changes from 20th July 2016!!

I’m sure you have been asked a 100 times in recent months about “Gluten Free” menu items and/or “Is this meal gluten free”? The term ‘Gluten Free’ has become so common on menus, signs and labels that we are surprised when dishes sometimes DO contain gluten. In 2014, the EU published rules for businesses to follow on the absence and/or reduced presence of gluten in food.

You thought the Gluten saga ended in 2014?? Not likely!!
The purpose of my blog is to tell you that unfortunately there is another set of legislation winging your way in the near future relating to gluten.
From 20th July 2016 the 2014 rules will become null and void with a new set coming into play. If you have items on your menu that you think are suitable for those that are gluten intolerant and/or you have ‘Gluten Free’ highlighted on your food items; THIS is the blog for you!

Statements and conditions set out in Regulations are:

‘Gluten – Free’
The statement ‘Gluten – Free’ may only be made where the food as sold to the final customer contains no more that 20mg/kg of gluten.

‘Very Low Gluten’
The statement ‘very – low gluten’ may only be made where the food, consisting of/containing one or more ingredients made from wheat, rye, barley, oats or their crossbred varieties which have been specially processed to reduce the gluten content, contains no more than 100mg/kg of gluten in the food as sold to the final consumer.

How can we decide if the foods are indeed Gluten Free/ very low gluten?
Well unfortunately unless you can get the finished product tested you cannot be 100% sure if the food meets the criteria or not.
A word to the wise in relation to laboratories that you use. Make sure the lab is INAB (Irish National Accreditation Board) accredited. www.inab.ie

In addition there are requirements for food containing oats:
Oats in food presented as either ‘Gluten Free’ or ‘very low gluten’ must be processed/prepared in a way that avoids contamination with wheat, rye, barley and/or their crossbred. Their gluten content cannot exceed 20mg/kg.

If you can prove your oat containing foods are compliant you can include the statements:
‘Suitable for coeliacs’ or ‘suitable for people intolerant to gluten’.

If you can prove that the food you are selling has been produced, prepared and/or processed to:
A. Reduce the gluten content of one or more gluten – containing ingredients
or
B. Substitute the gluten containing ingredients with other ingredients naturally free from gluten.

You can use the following statements:
‘Specifically formulated for coeliacs’ or ‘Specifically formulated for people intolerant to gluten’

Now if that seems like an awful lot of information, my advice to you is:

1. Make your dish as you would normally within the confines of your kitchen.

2. Send product to an external INAB lab and ask them to test the gluten content of the finished product.

3. If your product comes back with a result <20mg/kg or >20mg/kg THEN you can decide what information/ terminology you can place on the labels/signs/menus etc.

This new regulation also ties in with the FIC (Food Information to the Consumer) regulations that came into force in December 2014 and you the business owner must make sure that the information to customers is not misleading in any way.

Misleading according to the legislation would be deemed as:

‘’Suggesting that the food possesses special characteristics when in fact all similar foods possess such characteristics, in particular by specifically emphasising the presence or absence of certain ingredients and/or nutrients.’’

This is where businesses get caught using the term ‘Gluten Free’ incorrectly. If a food doesn’t contain gluten naturally then it is misleading to claim your milk has special characteristics as being ‘Gluten Free’ as all milk is the same and all therefore Gluten Free!!

In summary the main concern is that if your business has ‘Gluten – Free’ mentioned on menus, recipes etc. then you have to ensure that the food you give to the customer is indeed gluten free.
Even if you are using ingredients not containing gluten etc., the atmosphere that the food is produced in may lend itself to cross contamination i.e. Using gluten free gravy mix to make gravy in kitchen but there is flour and other ‘gluten ingredients’ readily available and used in the same prep area and kitchen.

That’s why the legislation states you must test the final product that you are providing to the consumer.

Further information is readily available on www.fsai.ie and also guidance Note 24: Legislation on ‘Gluten – Free’ foods and avoidance of cross contamination during manufacture of ‘Gluten Free’ or ‘very low gluten’ products may be useful.

If you have any queries or would like to discuss this new amend to legislation in further detail please feel free to contact info@catercare.ie
So guys, get your skates on, get testing those food products and be ahead of the 20th July 2016 deadline.