Gluten Free Guerrillas
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Confused about Coeliac food labelling? Well it's changing again - soon!

Confused about Coeliac food labelling? Well it's changing again - soon!

Regular Coeliacs will know that we welcomed the recent EU legislation that shifted the classification for 'gluten free' from 200ppm to 20ppm or less. At last - a lower level of 'gluten free' that can only be good for all Coeliacs we thought. And so it was. However, at the same time we had a nagging doubt - would retailers bother to pay to get their products re-tested to see if they conformed to the new levels? Would they make the effort to shout loudly and proudly that their products were 'gluten free'.

Sadly our niggly doubts were confirmed. Doritos removed their 'suitable for coeliacs' label. Walkers likewise. Many of M&S products that were formally 'gluten free' were now 'unsuitable for coeliacs due to the manufacturing methods'. You get the idea. 'Thanks for the honesty retailers' we thought but bugger - you've left us with less choice than before. Luckily some great new businesses emerged like @perkierfoods @sweetmandarins and trusty @burtscrisps continued to embrace their gluten free labelling and shout it from the rooftops.

However, all was not simple. No. For there emerged a new gluten free label on the block known by the street name 'NGCI' (or rather 'no gluten containing ingredients'). Hmm. What does this mean we mused? We googled, we read the FSA website we consulted EU Coeliac Societies and we gathered a fuller picture of what NGCI really stood for.

Can you guess?

Well many of our friends simply thought it meant it was safe for ingredients i.e no gluten inside was how they read it. Many newbie Coeliacs told us on our Facebook page that they thought it meant Gluten Free. Yet the FSA website ( clearly stated it wasn't a legal term and it didn't mean an item was gluten free. No instead it was devised after much lobbying by Coeliac UK & suppliers to the FSA as a,

'new statement which could appear on packaging, menus or product lists to highlight that a product does not contain cereals containing gluten as an ingredient.'

Oh and the FSA also undertook research..

'A qualitative approach was used on this project, with thirty-four respondents'. Yes that's right just 34 respondents were interviewed. Hmm. Not exactly a strong sample size was it?

So back to our point, NGCI wasn't ever meant to be included on product labelling?

'No' said the FSA official when we rang to research this in January, 'the statement was so that 'sensitive' Coeliacs have some extra reassurance when they are eating out. As often catering food supplies aren't labelled gluten free. Instead product lists or catering packages to pubs and restaurants can indicate that they are NGCI, so giving Coeliacs extra choice and reassurance'.

When we explained that we'd regularly seen products labelled as this in our local supermarkets instead the FSA recommended we email them the details and pictures.

'We'll happily contact the producers and explain how the labelling is meant to be used'. So we did.


So if you're already confused by all of this how do you feel about a new law that plans to shake up food and nutritional labelling?

The European Commission has published information on a new Food Information Regulation to make food labelling easier to understand for consumers. It's been in consultation phase and many Coeliac Societies are involved. So if you want your voice heard to avoid future 'bad decisions' then start email your local Coeliac society with your viewpoint. Although the consultation period finished on 30 Jan you can still steer and shape the negotiations that follow!

Read up on these links below so you understand the key changes for yourself. Oh and yes there are a few. You see sadly the new Coalition Government took many of the consumer food & safety responsibilities and policy and split them between DEFRA and the FSA. Wonder if that is why the horsemeat scandal is such a mess - errr we digress!



EU Journal:

The new regulation, called Food Information to Consumers Regulation (FIC), includes many rules on food and nutrition labelling into a single EU regulation and covers areas like:

>making labelling clearer by setting a minimum text size

(this might make it easier to read ingredient labels handy for all Coeliacs)

> highlighting allergens in the ingredients list, rather than allergen boxes

(The FSA explained that too many mistakes by food producers led to allergens missing from the allergen box but being included in the full ingredient list which not everyone read. So reasoning is that scrapping the allergen box will remove this risk. We wonder if this will work? The new approach is that everyone will have to 'bold' allergens in the labelling list.)

>needing nutritional information on most foods

Note: many of the requirements will not apply until 2014, while nutritional labelling must happen by 2016.

Hmm time to get emailing and making your voice heard to the FSA & your EU Coeliac Society.


Further information can be found on the Food Standards Agency website, in the Journal of the European Union and on the Department for Environment, Food and Rural Affairs (DEFRA) website.

Note: There will are further, separate consultations in Northern Ireland, Scotland and Wales. So if you're based there you still have time to contact your authorities during the consultation period.

Got all that?!

22 Replies

Thanks Fiona for pointing this out I am confused and have been since last March when I started the GF diet. I came into the world of gluten free after last years labelling changes came into effect. I have been constantly baffled in M&S by foods that appear in the CUK book don't have gluten products on the ingredients list but state 'Not suitable for Coeliacs due to manufacturing methods' on the labels. I look at products and have decided that if their is no mention of a gluten product on the ingredients listed and no warning about suitability I will eat it - have I got this right? Bit loathe to email anyone at the moment when I feel unsure of the rules as they are now.

I find that quite often there are rogue ingredients in the ingredients list and no mention of gluten as an allergen in the allergen box so you need to read the ingredients list all the time. Only disadvantage is that the ingredients list seems to be smaller text and harder to see I'll soon be shopping with a magnifying glass LOL


Hi Jan. Glad you found it useful.

In a nutshell currently under the existing EU GF / Codex law:

- items can only be labelled gluten free if they are less than 20ppm and have testing to prove it

- the term 'suitable for coeliacs' is still allowed but so many retailers/ producers are confused by it that they have removed it and replaced it with NGCI (which doesn't mean gluten free) which only adds to the confusion!

- M&S is actually the only retailer we've seen with honest labelling and when we see 'not suitable for coeliacs due to manufacturing methods' we curse a little in our heads but also thank them for being transparent and avoid these items as there is a risk they were cross contaminated with gluten during production.

- We like the allergen box - as it stands- as it provides an at a glance alert of whether the item contains any nasties like gluten. However, we always force ourselves to also read the full ingredients list (as we know retailers make mistakes)

- in terms of foods that aren't labelled 'gluten free' or 'suitable for coeliacs' there's a kind of gamble i.e. we consider 'what is the item' for example a bar of chocolate or spices or packet of crisps, 'what's the likelihood it's made in a an environment with gluten?' - bear in mind that if an item contains gluten they legally have to state it. However, if it's made on in an environment with gluten and other allergens that's more of a grey area.

You're right that the ingredient lists seem to be getting smaller (how tiny can they print on chocolate bars!). I think we need to create to some credit card GFG magnifying glasses ; )


Why for hells sake don,t they just do what NZ Australia do and make it mandatory to show allergens. Simplify,s it so much. Then you decide if you eat it or not. Not rocket science is it.


Completely agree with you, everything is made complicated in the UK. I wish we had the same strict rules as NZ and Australia for ppm I can't trust Coeliac UK book. They list cereals with barley malt extract as ok, have been ill from eating these. I spend my time reading labels and do a lot of cooking/baking from scratch.


The problem is that you could have identical three bags of crisps made in the same factory but with different packaging.

One has the ingredients potatoes, sunflower oil, salt

One has the same ingredients but has the 'no gluten containing ingredients' label

One has the same ingredients but says 'Not suitable for Coeliacs due to manufacturing methods'

I'd probably eat the first two but avoid the last one even though they could potentially all have the same product and risks. Whether any of them cause a reaction is unknown until you eat them.

The NGCI label is pretty pointless as it doesn't bring any further information. I can see it being useful on a menu where you don't get an ingredients list but I've never seen it used in this way.


I also check out the carbohydrate values of foods because I need to know for my type 1 diabetes. There are almost always inaccuracies as retailers tend to overstate the carb values - I think in their minds to be safe. M&S is particularly bad for this and until I learned I got caught out a few times after taking too much insulin. The carb value per pack seems to be an average so I now just judge by eye. Food labelling does make life so complicated.


Having been coeliac for 27 yrs now, I still follow the mantra "when in doubt - leave it out". I know it's a pain, buy having no symptoms ie the aftermath of bring glutened far outways the five minutes pleasure of eating something u like. I bake 3 to 4 times a week, not just cakes but savoury food. It's far nicer, you can adjust salt and sugar plus no risk. Lets face it an hour to bake here or there for your own healthsake.

Can we all email gf guerrillas on some sort if petition to forward to the powers that be ??


Yes you can Fisher123 our contact details are here:


With the current horsemeat scare to reduce all the fancy names in allergen box's why not just put the origin? Maltodextrin= Wheat or potato or anything else, one word is only necessary. You do not need scientific opinions or research to be invovled if it comes from wheat it should be labeled as wheat in the ingredients


That is exactly how the EU law is they must state where any starch used is from. In America Maltodextrin tends to be from potato or corn over in the EU it's normally wheat.


I would be inclined to check out Commission Directive 2007/68/EC Annex IIIa where you will find that not only Maltodextrin but other gluten containing ingredients are exempted from labelling.

Also worth a look at the European Food Safety Authority site putting gluten in the search box the results are there for those who have continued health issues.


Did anyone ask her about legislation?

Thank you for your email. As I am responsible for the legislation related to gluten labelling at the European Commission, I was asked to answer to your request.

I understand your concerns and difficulties to deal with a condition such as celiac disease on a daily basis.

It is a fact that different people with intolerance to gluten may tolerate variable small amounts of gluten within a restricted range. In order to enable individuals to find on the market a variety of foodstuffs appropriate for their needs and for their level of sensitivity, it is important that a choice of products is possible within a restricted range.

As you may know, the removal of gluten from gluten-containing grains presents considerable technical difficulties and therefore the manufacture of totally gluten-free food is difficult.

The new legislation regarding food labelling you are referring to is Commission Regulation (EC) No 41/2009 which harmonises and establishes specific requirements according to which foods may be voluntarily labelled as 'gluten-free' (when the gluten content is not higher than 20 mg/kg) and 'very low gluten' (when the gluten content is not higher than 100 mg/kg). As you noted, the new legislation will fully apply as from the 1 January 2012. These new harmonised thresholds are much lower that the previous threshold of 200 ppm that applied in most Member States before the introduction of these new rules.

But let me refer also to the allergens labelling rules: Directive 2000/13/EC establishes a list of ingredients that cause intolerance and allergies and which must always be labelled. Cereals containing gluten are included in that list. If wheat, for example, is used in the production of a food and is still present in the finished product, then it must be mentioned in the list of ingredients even if the level of gluten is less than 20 mg/kg.

Consequently, the combination of these two legislations allows for appropriate labelling information and consumer protection.

I understand you have health issues even with amounts of gluten less than 20 ppm. The EFSA opinions you listed in your e-mail conclude that products such as wheat based glucose syrup are unlikely to cause an adverse reaction in susceptible persons. However, such considerations can never preclude individual reactions.

With kind regards,

Ariane Vander Stappen

Ariane Vander Stappen

Unit Food Law, nutrition and labelling (E4)

Foods for particular nutritional uses 'dietetic foods'

F 101 08/58 - 1040 Bruxelles

Tel: +32 2 295 21 58


Pretender - when did you send this mail & to whom? It's not clear from the start of your comment. Thanks.


This was sent in 2010 to the EU, as you can read Ariane.Vander-Strappen was the person responsible in the EU.

Worth noting is the last sentence starting "However,etc etc"


There's obviously big money behind all this, otherwise it would just be so plain and simple: label all products with their correct and ACTUAL ingredients, instead of a fuzzy 'glucose syrup' which doesn't tell you what it's made of, or similarly with 'maltodextrin' or many other items. Personally I can't tolerate products which are labelled 'no gluten containing ingredients' so I don't buy them. However, well-meaning friends buy some of these products especially for me, and then I have to p*** on their parade when I tell them, "Sorry, I can't have that" and they look at me like I'm impossible!

As for the change in labelling 'restricting' our choices, well I'd rather know for sure what it is I'm about to ingest than go with a fuzzy may be safe/may not be safe option.

They do seem to be making it more complicated and confusing than it needs to be.


Exactly Lexy - and don't worry I regularly **ss on their parade. At my b'day they brought along crisps labelled NGCI and they were incredulous when they discovered from me that this didn't mean they were gluten free. Labelling is overly complicated. Even more so when you buy beef but you may end up with horse! It does make you wonder who is behind all of this...


As i said earlier go to full disclosure for any allergens on the ingredients label.


Unfortunately the problem isn't just for processed foods. I eat only naturally GF foods but have great difficulty finding sources of raw nuts, ground almonds, spices etc where they can confirm they pack in factories that don't use gluten or where the wash down practices are reassuringly clear. I've written to most companies selling these products and get a standard reply saying if you're very sensitive to gluten we suggest you avoid them just in case of cross contamination. If we can't even trust these basic foods it's really hard. I now soak all my nuts and seeds which is good for them anyway but means a lot more work. I'd love Coeliac Uk to look into this sort of thing, there must be good practices out there and it would be great to know which brands / manufacturers are least risky.....and then there are supplements!



This is all so complicated. I'm so thankful that intolerance is all I have to deal with.

Nickyr, that's awful, I wrongly assumed that if buying raw ingredients that were naturally GF they would be safe! I think the whole food industry is just messed up beyond belief now :( the horsemeat scandal has really gone to prove that.


Full disclosure of ingredient origins will not happen in the EU.

What is so complicated can be so easy..if Maltodextrin is made from wheat then wheat should be on the label, the same as if made from potato.

The big question is why will they not do the simple thing and reduce costs for all?


I read NGCI as can't be bothered to get the proper checks done and I can't be bothered to buy it and take the risk. I'll vote with my wallet. Always remember that liquorice has no gluten containing ingredients but is still made on lines that use flour to stop it sticking.

Someone said M&S were the only ones using the not suitable due to methods of manufacture. This is wrong as it turns up on Sainsbury stuff too - incredulously it's on their beansprouts!

Nickyr, you're so right - I've found May Contains on rice, lentils, dried fruit, quinoa, endless list. I always avoid unless I can guarantee but it does make life hard.

Please can we just have 3 labels on absolutely everything:

Gluten Free - has been checked and certified,

Contains - has gluten in it,

May Contain Traces - doesn't have gluten ingredients in it but not checked.

That way us sensitives can go for certified, avoiders can have their variety, and none of us get accidentally glutened.


Menu for coeliacs at local hospital says NGCI. I was glutened twice, the last time very severe. Only had hospital food.


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