How Do We Solve a Problem Like ‘May Contain’

November 2025

By Melissa Secord, Executive Director

Since 2020, the Food and Agriculture Organization (FAO) and the World Health Organization (WHO) have held a series of expert meetings on food allergen risk assessment. This work is part of a broader “Food Code” designed to protect global consumer health and promote fair practices in food trade.

Initially, the committee focused on IgE-mediated allergens such as peanuts, sulphites, and mustard. Wheat was also reviewed under this category.

International celiac advocacy groups, including Celiac Canada, pushed for the simultaneous inclusion of gluten in specific cereal grains (wheat, rye, barley, and cross-contaminated oats) during this review because of its relevance to celiac disease.

As a result of this advocacy, WHO and FAO convened a group of international celiac and food science experts in Rome in early November 2025.

Our main concern is ensuring these international bodies understand that celiac disease is not the same as a food allergy. Wheat allergies impact 1 in 500 Canadians and are often outgrown by adulthood. Celiac disease on the other hand affects 1 in 100 Canadians and is a lifelong condition. Any future label warnings, ingredient thresholds, and standards must respect this difference. Manufacturers need to focus on risk assessments and good manufacturing practices to manage ingredients effectively.

The next international meeting to review these findings will take place in May 2025 at the Codex Committee on Food Labelling (CCFL) in Ottawa.

What’s the Impact of May Contain Statements on Consumers?

Currently, precautionary allergen and gluten statements on labels are voluntary. These statements alert consumers to the “possible inadvertent presence of an allergen in the food.” They usually appear under a “Contains” statement as “May Contain X.”

Over the years, the use of “May Contain” statements has increased, leaving consumers guessing about the risk of gluten contamination—and limiting food choices.

In 2019, we surveyed over 2,300 Canadians with celiac disease. For example, if a product carried a gluten-free claim and a “May Contain wheat” statement, 65% of respondents said they would avoid the product.

The survey collected over 800 comments expressing confusion and concern:

“A product should not be able to label its packaging gluten-free and then you read the ingredients and the ‘may contain’ warning is on there. This is very confusing, misleading, and harmful to those who are celiac—especially the newly diagnosed who are just learning how to read labels.”
— Parent of a child with celiac disease

“The ‘may contain wheat’ and ‘processed in a facility that also processes wheat’ on the label is so frustrating…especially if the ingredients are naturally GF. I won’t take a chance, but doing so sure limits my options.”
— Individual living in Ontario with celiac disease

To help, our Dietitians Working Group has created an extensive Food Labelling Guide to support celiac consumers in making safe choices.

Gluten-free medical nutrition therapy is already challenging and restrictive. Our goal is to ensure consumers have access to the widest range of safe gluten-free foods to support physical and mental health and intestinal healing.

Here is what Celiac Canada is doing:

Raising this issue in our meetings with Health Canada and Ministerial officials
Requesting to be a delegate with Canada at the next CCFL meeting in Ottawa to ensure our community’s voice is heard

Advocating for better manufacturing processes and risk assessments to minimize overuse of precautionary allergen and gluten warnings at food industry meetings and networks