Understanding the "May Contain Gluten" Label

The "May Contain Gluten" label deserves serious consideration for coeliacs and gluten free consumers

Hey gluten free fam! 

There’s one topic today which deserves a closer look, figuratively and literally: food labels. For a gluten free diet, this detail is a tricky and divisive one.

You walk into a supermarket or shop, find what you think is a safe gluten free product, only to then flip over the packaging and see the three words: ‘may contain gluten'.

What does that even mean? Should you risk it or find something else? For many living gluten free, especially those with coeliac disease, this is a source of constant stress and confusion.

In episode 105 of A Gluten Free Podcast , Ben had the chance to speak with Penny Dellsperger, a Dietitian and Health Advocacy Officer for Coeliac Australia, to help unpack this issue. 

She provided some valuable insights into what these labels really mean and how gluten free shoppers can make more informed decisions.

What Does the May Contain Label Mean?

One of the biggest sources of confusion is understanding what the "may contain gluten" label is actually saying. According to Dellsperger, food manufacturers will use ‘may contain’ statements or a variation of ‘may contain.’ "We call them cross-contact statements as the overall banner," she told Ben. "But it could appear as ‘may contain,’ made on the same line, manufactured in the same facility, amongst others.”

These labels are not telling you that gluten is an ingredient in the product, but that there may be a chance of cross-contact. Cross-contact can happen due to contaminated ingredients, or due to shared facilities or equipment. It’s a precaution with labelling requirements, but it doesn’t mean the product definitely has traces in it.

Dellsperger continued: “There is a risk of cross-contact with gluten or wheat, depending on what is mentioned on the label. It's not an ingredient of the product. It's a risk of cross-contact due to the incoming ingredients or the way the product is manufactured on a shared line—a cross-contact risk that they can't control.”

Current-Day Complications with Labels

It sounds straightforward, right? But the challenge for us sticking to a strict gluten free diet doesn’t end there. One of the main issues, as Dellsperger explained, is that “You’ve got your gluten free claims which are well defined in food legislation and you've got your statement of ingredients where it is mandatory to declare when ingredients are gluten derived. They are a mandatory aspect of labelling. Your cross-contact statements, on the other hand, they're not mentioned in legislation.”

What does that mean for you as a gluten free shopper? Put simply, there’s no consistent legal requirement for how these cross-contact labels should be applied.

That lack of standardisation makes it frustrating to know when you’re really at risk. Some brands, especially smaller businesses, might not fully understand when or how to apply the labels correctly.

Challenges for Small Brands and Manufacturers

Local manufacturers have the biggest challenges adhering to strict labelling standards

We expect big things from the big brands, and rightfully so. With their extensive resources, food companies on scale should deliver products with correct gluten free labelling. For local suppliers without the same resources, there are complications.

“There's no standard way that they must be used,” Dellsperger explained. “The issue that we have is that not all manufacturers, especially your smaller and medium-sized manufacturers that have a lot on their plate for a smaller business, understand how to apply them. (That requirement) often is a bit harder.”

This inconsistency leaves us wondering whether the risk of exposure is real or just an overly cautious warning. How do we know when a product is actually gluten free? How do we avoid products and gluten-containing ingredients in this type of environment?

Overuse of the Label

One of the surprising points Dellsperger highlighted was how often these labels are overused. “There is often a concern that perhaps there should be a ‘may contain’ statement when there's not. But what we usually find is the opposite. We usually find they're unnecessarily overused when there isn't a genuine risk of cross-contact.”

Clearly there are challenges for food companies who have to do the right thing by the customer with every food label. While it’s great to incorporate naturally gluten free foods as a basis for our diet, prepackaged foods still have their place. The public health significance of label reading comes into stark focus to avoid cross contamination.

Truth in the Statistics

Dellsperger referenced a study that reviewed how often cross-contact statements are used and whether they are always necessary. The results were eye-opening: “(They) looked at the use of cross-contact statements. It found 65% of products in the supermarket would use a cross-contact statement of some kind. Of those that used a cross-contact statement, less than 90% actually had any detectable allergen in them at all.”

This tells us that many manufacturers err on the side of caution. They often use the label even when there’s no real risk. While this might provide legal protection for the company, it leaves gluten free consumers in a state of uncertainty with our food safety needs.

What gluten free products can we trust? With so many packaged food product options available, shoppers living with coeliac disease or who are gluten free for other health reasons deserve to know what items are gluten free and conversely what remains off limits.

Reviewing Gluten Levels: The PPM Paradigm

The PPM details can be your definitive guide for safety assurance

To help make sense of it all, Dellsperger explained the concept of PPM, or parts per million, which measures the level of gluten in a product.“In terms of the amounts that we're talking about, once you get up around the 100, 200 parts per million of gluten, for example, that's when the industry recommendations start talking about actually including it as an ingredient.”

If contamination is kept to a minimum, manufacturers may not be required to list gluten as an ingredient on their food labels. But if the levels are high enough (around 100-200 PPM), then the product should either be labelled as containing gluten or the manufacturer needs to rethink how the product is made.

“If you've got cross contamination at those high levels, that's uncontrolled and consistent. That's when the recommendation is to look at changing how you do things to manage it better, or actually look at putting it on as an ingredient,” Dellsperger said. For customers in the United States, the FDA regulated < 20 ppm as the criteria for food labels meeting the gluten free definition. According to Coeliac Australia that ppm figure is zero. No detectable gluten is permitted in a gluten free product within Australia.

Making Informed Consumer Decisions

So, where does all that leave shoppers with gluten free labelling? The key takeaway from Ben’s conversation with Dellsperger was to trust the packaging first and foremost. She explained, “When you find inconsistent information on websites, it definitely gives you that element of ‘can I trust what's on the pack here?’”

While it’s tempting to look online for advice, the most reliable information will always be right there on the packaging. “The most current and accurate information must be on the packaging of the product. So that should be the source of truth. You should be able to rely on that packaging,” Dellsperger advised.

Follow Trusted Gluten Free Advice

However, if you’re ever unsure about what something on a label means, Dellsperger recommends reaching out for help. “Coeliac Australia has resources and support to help with label reading. We can also provide guidance as to what to do if there is a problem with a label. Seeing a dietitian with experience in coeliac disease is also important to receive tailored information.”

Former podcast guest and coeliac disease specialising dietitian, Kristina Richardson provides helpful user guides which allow us to recognise when a label is trustworthy and when it should be scrutinised.

Follow trusted advice on may contain labels 

If you see the gluten free certification label from a trusted organisation, this can help simplify the process of identifying suitable products for a gluten free diet. 

Conclusion: Trust the Label, But Stay Cautious

At the end of the day, "may contain gluten" labels are a bit of a gamble. This voluntary statement may be on there for good reason but it also may be there to simply cover a food company. Sometimes it’s underused and sometimes it’s overused.

While inconsistency in food labels makes shopping for gluten free items frustrating, we hope this article has cleared things up and helped you to make more informed choices. It’s about knowing there’s a risk but you must take into account whether you’re willing to take that risk or not.

When you’re educated and fully aware of the risks involved in purchasing and consuming ‘may contain gluten’ products, then you’re ready to make a decision which works for you and your own unique lifestyle. What works for one person with coeliac disease won’t work for the next, so please don’t judge someone who is making an informed and educated decision.

Remember: read the ingredients and statements carefully, refer to Coeliac Australia’s advice which is “ While the ‘safest’ approach is to avoid foods that use PAL (cross-contact statements), each individual should use their discretion when deciding whether to use such products.” Stick to trusted brands, rely on the packaging, and if in doubt, don’t hesitate to ask for expert advice.

Happy label reading gluten free fam!