To be able to label an item with that illustrious “GF” declaration, it needs to get sent to a lab, go through a testing, and come back with the results showing that it contains less than 20 ppm (parts per million) of gluten to get gluten-free certified. That is by FDA standards. For Celiac Association standards, I heard it should be less than 5 ppm (my items passed that too).
If an item is gluten-free because there are no gluten containing ingredients but hasn’t been through the official testing and certifying process, the gluten-free claim shouldn’t be on label. Instead, it can be labeled with “no gluten containing ingredients”. If you have gluten-sensitivity, are you super strict about the “GF” claims? I know that it all varies with how sensitive a person is to gluten.
I recently had a WTF moment with all this. I had some of my GF items certified (and was continuing to add to the list) and some print materials with that “GF” claim. And then just a couple of weeks ago, someone notices my GF claims and tells me that I probably shouldn’t be making the claims because although the items are certified, the facility is not. This was truly puzzling because no one had said anything to me about the facility also needing to be certified as well before I got my items certified. I asked around and was hearing mixed info on this. I contacted the lab to get answers. I figured, they’d probably be the ones to have the most legit answers to this. And they told me, “the FDA does not require a facility to be ‘certified gluten-free’ in order to label a product as gluten-free. I was given the green light to carry on. Thank goodness. But it was recommended that I also include “made in a facility that uses wheat” as well. I read somewhere that including this is optional. Maybe this statement might turn away certain buyers with gluten intolerance. Other times, it may be the safety measure a person with extremely high gluten tolerance may need. Even breathing in bits of gluten remnants from the air may cause a reaction. There is such a thing as airborne gluten. And getting someone sick is the last thing I’d want to do!
Taking it back to when I had the State inspection, when I spoke to the inspector on the phone, the day before my scheduled State inspection, she asked if I had any items labeled as “gluten-free” or “organic”. I told her I had some gluten-free items but none that were labeled as organic. I only learned that day from the phone call that when labeling an item as “gluten-free” that the items would need to be certified. And my inspection was the next day. There wasn’t exactly enough time get my items certified when my inspection was the next day.
So in the evaluation report of my inspection, this gluten-free claim was one of the things that I had to fix. I was new to all this and was still learning. And like I said before, there is no step by step instruction check list! At least not one I have found yet. This is one of the reasons that I started journaling my steps. It’s a reference for myself and I hope that it can also be a reference for others, though things may vary greatly by each state and county.
My gluten-free items are “made with a shared equipment that uses wheat”. During the State inspection, the order in which I made the items was a bit frowned upon. I planned out the production of the items so that it made sense in efficiency. I made the vegan tahini chocolate chunk cookie dough first so that it’d have time to chill. Even though I did a thorough job of washing, rinsing, sanitizing the equipment after use before proceeding to make the gluten-free item (vegan flourless tahini brownie), I was told that it might be suggested that I make the gluten-free items first to be extra safe.
Since I was not certified (because, again, I had no idea about such thing and this was one of the things I learned as I went), I was then told that I either had to remove the “GF” on my label or change it to “no gluten containing ingredients”. I ended up getting my items certified. It’s not cheap! I was recommended to Food Microbiological Laboratories, Inc. (by a fellow local foodpreneur). This is in Orange County, CA. I understand that it once used to be $50 per item. When I went, it was $135 per item! There’s more ease of mind having had the items tested and certified.
If you see gluten-free items without the “GF” claim on my menu, know that it’s typically going to be because they’re newly added and I may still be getting a feel of it to see if I want to bring it on board to the official “GF” club. My orange (no gluten) pound cake is an example. Only a limited few have tried it so far. The response has been excellent and I personally LOVE it! It’s even almost keto. It’s the orange that makes it not keto. Other than the orange, pretty much all the ingredients are keto. When I start testing to get more in-depth feedback, I will look into getting it certified to add to my gluten-free list.
If you follow my IG, you’ve probably seen Kevin of Steve and Kevin. They’re my VIP customers and are both gluten-free. Kevin was diagnosed with celiac disease back in 2014. He told me that there are certain items that he dearly misses since he cannot have gluten anymore.
With Kevin being the most gluten sensitive person that I know, he became the head taste tester of my products when I was experimenting and trying to decide what will go on my menu. So you can thank Kevin in part for what you see on my menu today.
For more videos of Steve and Kevin, my gluten-free taste testers:
Vegan gluten-free banana bread (yes, they can be made gluten-free upon request)