Reading Labels Part 2

Last week’s post on reading labels gives you good basic information, but I want to carry the discussion a bit farther.  This week and next I want to talk about two aspects of label reading in the United States a little more in depth.


Food Allergen Labeling and Consumer Protection Act (FALCPA)

As a result of FALCPA, food labeling changes went into effect on January 1, 2006.  This law requires that the top eight allergens, wheat, milk, egg, peanuts, tree nuts, fish, Crustacean shellfish, and soy, be listed by it’s common name. It must be listed if it is an ingredient or part of an ingredient.

The allergens can be stated in the ingredients list or in a “contains” statement at the end of the list.  Some manufacturers do both.

What’s Important to Remember

Gluten is not one of the top eight allergens.  While wheat is, rye, barley and contaminated oats are not part of that list.  That means those gluten-containing ingredients will not be listed as part of a “contains” statement.  You must read the ingredient list to look for those items, and keep in mind that they may not be clearly labeled.  Malt is the best example of this because it is usually made from barley, but barley is not necessarily listed.

How I Read a Label

“Contains” statements are usually easier to read than the list of ingredients.  They are often bolded and are easy to find at the end of the list of ingredients, so I start there.  If the product has a “contains” statement I read that looking for wheat.

If wheat is listed in the “contains” statement then I know it is not gluten free and I put it right back on the shelf.

If wheat is not listed (or if there is no “contains” statement), I know it might be gluten free.  I then start reading the ingredients looking for rye, barley (which often shows up as malt) or oats (knowing that unless certified gluten free oats are used, they are likely contaminated).

If no gluten containing ingredients are listed, I know it is probably gluten-free.

I say probably because there can still be issues of cross contamination.  I will talk more about that next week.

Be Diligent

It is important that you don’t rely on reading only the “contains” statements.  Besides the fact that gluten is not one of the top eight allergens, I have seen cases where an allergen was not listed in the “contains” statement (though other allergens were) but it was listed in the ingredients.

“Contains” statements should only be used as a quick way to rule out a product, not as a quick way to determine if it is safe.

Always read labels, even on items you use all the time.  Ingredients can change.

Further Reading

Part  3 Cross Contamination and Warning Statements

You can find more information about FALCPA at the American Celiac Disease Alliance web site.

This post may contain affiliate links. See my disclosure policy for more information.


  1. says

    Linda, I may be misinterpreting what you are saying, but manufacturers are NOT required to include gluten ingredients except wheat on the ingredients label, even in the entire ingredients listing. The FALCPA only requires that manufacturers show wheat (and it’s their option to show that in either a Contains: statement or in the complete listing). So one can read the complete label and think the product is safe because it does not show any gluten ingredients, but it still may contain gluten and therefore, not be safe. Manufacturers are ONLY required to show wheat either in the entire listing, Contains: statement, or both. While it’s true that most major manufacturers (e.g., Kraft) will show ALL gluten on the ingredients label, the FALCPA does not require it. That’s another reason the next step in labeling, the “gluten-free” label is so critical.


    • says

      Hi Shirley,
      I thought I made it clear that wheat is the only gluten-containing ingredient that is required to be listed. I did add a little more to my “What’s Important to Remember” paragraph to clarify. I’m not sure what ingredients you’re thinking of that would contain rye or barley and not be stated as such other than malt. Even the ACDA fact sheet states, “Read the ingredients list. Is there Barley, Rye or Malt listed?*” with the asterisk referring to a note about oats. What am I missing?

      • says

        Hey Linda–This is such a tough topic to explain without there still being questions. I’m truly not pointing fingers, but I still thinks there’s a bit of room for confusion. I’m specifically looking at this statement below:

        “While wheat is, rye, barley and contaminated oats are not part of that list. That means those gluten-containing ingredients will not be listed as part of a “contains” statement. You must read the ingredient list to look for those items, and keep in mind that they may not be clearly labeled. Malt is the best example of this because it is usually made from barley, but barley is not necessarily listed.”

        You state that you must read the ingredient list to look for rye, barley, and oats and that they may not be clearly labeled. I’m saying there is NO requirement for them to be labeled at all. The only requirement per the FALCPA for the Contains statement OR the ingredient listing is wheat. And it’s up to the manufacturer which method they choose to indicate the 8 major allergens.

        Tricia Thompson (Gluten-Free Dietitian), who has been involved in the formulation of these laws from the beginning talks about that more here:

        The following is an excerpt of that article and I’ve adding bolding for emphasis:

        “FALCPA does not apply to barley, rye, and oats but most ingredients that were questionable in the past were suspect because of the possibility they contained wheat. If barley is contained in a food product the ingredient name will almost always include the word “barley” or “malt”. Ingredients that contain rye and oats will generally include the words “rye” and “oats”.

        That ACDA fact sheet is unfortunate because it implies that if those words are not there, then the product does not contain them and it’s not necessarily true. It is indeed highly likely as Tricia states by using “almost always” and “generally” but it’s not a given. It varies by company. Again most major food manufacturers do label for all know gluten ingredients, but that’s not true of every food manufacturer and it’s not required by the FALCPA.

        Hope that makes sense and forgive me for being seemingly dogmatic on the topic. I so appreciate you bringing up this topic from time to time as folks get complacent and forget what we are supposed to be looking for. Thanks!


  2. says

    Great post topic! How I read a label: If there is a paragraph on the ingredients list, I put it back. Michael Pollan and things I cannot pronounce aside, I have found it is just too easy to overlook something with gluten when the list is too long.

    • says

      Margaret, all types of wheat must be listed and the common name of “wheat” must be used rather than something like semolina or kamut.

  3. says

    Label reading can be very confusing, so I have to give major kudos to Linda for tackling this issue.

    To distill this issue down to the major points folks need to understand, we only need to really worry about barley, rye, oats (uncertified) and malt, as the four non-wheat sources of gluten that are ingredients in our foods. Fortunately, they must be labeled in the ingredients, just as any other ingredient must be labeled.

    The only thing I can think of anymore that could contain gluten and not have to be listed on the ingredients under one of those four terms is Brewer’s Yeast (some derive from gluten/barley, some do not). Caramel coloring, food starches … these are either no longer made with wheat or must be listed as “Made with wheat” on the label. Even “flavorings” are really only an issue if there is some kind of undistilled grain alcohol in it, and I haven’t found any instances of that in years.

    As far as food labeling laws go, ALL ingredients must be listed on the ingredient label. Where people get tripped up is that they don’t see “barley” listed, but they see malt and they don’t know what that is. For example, if “spices” are listed, they cannot somehow have flour in and amongst them without it being listed. Dried pineapple dusted with flour must have that listed on the label as an ingredient. As with anything in life, nothing is perfect, and it is always possible for a manufacturer to neglect to list an ingredient; however, the ingredients are all supposed to be listed by law.

    *(In Pharmaceuticals, it’s a whole other issue, since they do not have to have their inert ingredients listed. Things like Dextrins, Dextri-maltose and some starches need to be confirmed with the manufacturer that they are made from GF ingredients.)

    SO, the real problem we face reading labels is that there is no provision for testing amounts of gluten to determine if “gluten-free” can be put on the label. Thus, we have a situation where a manufacturer looks at its product, says to himself, “I didn’t put any gluten into the product as an ingredient, so I’m going to label it Gluten Free,” when he has no idea if it’s been contaminated. Consumers then see the “GF” designation and stop reading. Since contamination has the potential to render a product quite full of gluten, consumers are left in the dark about true food product safety – the real risk coming from with cross-contamination, not because ingredients are included on a label.

    Our movement,, was established to push the FDA to set a “gluten-free” standard for food labeling. To date, the FDA has not established that standard, so consumers are left wondering just how “gluten-free” products are, when they are labeled by the manufacturer as being “GF”. Hence, certifications from GFCO, CSA and now NFCA/QAI are, at this point, the only real means of assuring that a product is gluten-free.

    ~jules shepard
    author, The First Year: Celiac Disease and Living Gluten Free

  4. says

    Thanks for the post on a great topic, Linda! Shirley of GFE gave me the heads up because we’d had this discussion when I posted a video teaching label reading. One exception to the rules (as I understand) is that dates can be dusted with oats and not necessarily clearly labeled. It’s mentioned in Shelley Case’s book on the GF diet, and in dietetics publications as well If that’s somehow incorrect, I would really appreciate source info!
    Also, not all foods fall under FALCPA. Meat, egg, fish products are have only voluntary labeling.
    It seems like it should be so simple, and yet it’s so easy to get caught. I’m with you, eating simple foods is the easiest way to make it and make it healthy!
    Thanks so much for tackling the topic.

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