The CCA joined with a number of celiac support groups to submit a joint comment on the proposed rule on gluten-free claims. The ‘joint group’ included Gluten Intolerant Group of North America (GIG), Celiac Sprue Association (CSA), Celiac Disease Foundation (CDF), and the National Foundation for Celiac Awareness (NFCA) along with the CCA.
The body of the statement is as follows:
Submission for Docket # FDA-2005-N-0404.
October 2, 2011
As patient non-profit organizations working within the gluten-free community, the Gluten Intolerance Group of North America (GIG), Canadian Celiac Association (CCA), Celiac Sprue Association (CSA), Celiac Disease Foundation (CDF) and National Foundation for Celiac Awareness (NFCA), praise the efforts of the FDA on the regulation for the voluntary use of the term gluten-free on food product labels.
Jointly we submit the following:
- A preference for a single definition of gluten-free. A dual definition of gluten-free and low gluten would be confusing.
- Support for the use of the term “gluten-free” on naturally or inherently gluten-free products, in light of real and potential cross contamination issues. The message is clear for the term “gluten-free”, minus any conditional wording. We agree the term “gluten-free” is appropriate for a food product whether it is a single ingredient, such as oats or a processed product with multiple ingredients.
- The consideration of the term “specific” grains rather than “prohibited” grains throughout the regulation.
- As this regulation addresses food safety and not a matter of dietary choice or preference, we expect the provisions of the FDA Food Safety Modernization Act (FMSA) to address emergent safety issues promptly and to be fully applied. At the very least, respecting the current pace of research in celiac disease, other gluten-induced conditions, and food science, we recommend a regulatory review no later than 2017 and on a mandated regular basis thereafter.
- In anticipation for implementation of the final regulation, we are poised for the education role which we will all share as the regulation is implemented. Our patient centered organizations have established voluntary communication venues and tools valuable to the celiac community, world-wide.
Respectfully submitted,
Gluten Intolerance Group of North America
Canadian Celiac Association
Celiac Sprue Association
Celiac Disease Foundation
National Foundation for Celiac Awareness
(Joint submission by organizations listed in chronological order)