No gluten containing ingredients (NGCI) sample menu in respect of the allergen laws July 2016

No Gluten Containing Ingredients and the law

Nearly ten months on and the term NGCI (No Gluten Containing Ingredients) is still misunderstood. Just to clarify the FSA have issued this guide https://www.food.gov.uk/sites/default/files/gluten-guidance.pdf which explains in detail where the term No Gluten Containing Ingredients (NGCI) can be used and where it can’t.

Fundamentally there are two ways in which consumers buy food – pre-packaged and loose. For pre-packaged goods the labelling law is as follows:

Gluten Free

A food item can be labelled gluten free if the manufacturer has conducted tests on the food (or at least batches of it and procedures are in place to ensure the gluten free integrity of the food) and the food contains less than 20 parts per million (ppm) of gluten.

Very Low Gluten

Low gluten means that the pre-packaged food contains between 20 and 100 ppm of gluten. However, it must contain gluten free wheat starch. Again this has to be proven by testing.

Anything above 100 ppm is not considered safe for coeliacs and thus cannot be labelled gluten free.

No Gluten Containing Ingredients

No Gluten Containing Ingredients is used where the food is sold loose – as in say a deli or in a restaurant/cafe/pub etc. situation. It is impossible to label the food gluten free (as it can’t be taken, mushed up and then tested), so the term No Gluten Containing Ingredients was born. Just to clarify to label a menu item gluten free or gf (or any other code/symbol) is not legally allowed – shame most of the food service industry aren’t aware of this!

As of the 20th July 2016, establishments are allowed to either have a separate menu (or a separate specifically labelled section of a menu). They are not allowed to label a specific dish as No Gluten Containing Ingredients on a ‘mixed’ menu unless it is in a separate section. The food service industry must comply with this by 20th February 2018.

What isn’t properly policed though are the processes food establishments take to ensure contamination is minimised. There is so little understanding of gluten, how it can be avoided etc (how many times have I heard that it can be killed by heat – it’s not a bacteria, it is a protein!). Unfortunately Environmental Health and Trading Standards departments are responsible for policing this and they are extremely under-resourced.

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