No Gluten Containing Ingredients and the law

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

Nearly ten months on and the term NGCI (No Gluten Containing Ingredients) is still misunderstood. Just to clarify the FSA have issued this guide 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.

Is a gluten free three course meal so hard to provide

Recently I revisited a pub for Sunday lunch, where previously I had the most fantastic gluten free lunch, despite the pub being really busy on a sunny autumn afternoon. A starter, main and dessert were provided and all were delicious. So fast forward and we were in the area again, so we decided to eat at the same pub. Sadly the second experience was not as good as the first.

The pub in question had a week’s notice that I was a coeliac and I would require a gluten free meal. The response from the person who took the booking was chirpy and confirmed that yes I could be catered for.

Gluten free roast beef for Sunday lunch
Gluten free roast beef for Sunday lunch

However, when we arrived and made ourselves known, it wasn’t as good an offering as I first thought. I was told that she was sure all the Yorkshire puddings were made with a gluten free flour, but would I like her to check – errrrr yes please! Sadly upon checking, they had run out of gluten free flour that week so the Yorkies weren’t gluten free (they were aware that a coeliac was coming to eat on Sunday, so you would have thought that they would have ensured that they had a stock of gluten free flour?). No problem – I’ll have the roast without the Yorkies and can you make sure the gravy is gluten free. Of course, when my lunch was served there was a huge, gluten containing Yorkshire pudding on top of my beef. So I returned the meal and she offered to replace the plate. I did emphasise that I would need a completely fresh serving as the beef would be contaminated. That was sorted quickly and efficiently, so fair play to them, but what if I had ordered something else that required cooking fresh again? Either my hubby’s food would of gone cold or else we would have both ended up effectively eating alone. So, obviously my gluten free order wasn’t communicated properly to the kitchen.

Anyway the food was lovely, so onto dessert. We enquired and to what on the dessert menu was gluten free. The lovely waitress checked with the chef and he stated nothing – although he could do a cheese board for me, without obviously the crackers. That would be just cheese then?

Now I’m sorry, but if you have been given a whole week’s notice and confirmed that you can cater for a coeliac, then I’m really not sure that providing a starter without the bread or only cheese for dessert is acceptable really. Having said that the food I did have was very good, but I won’t be returning because if you say you can provide a gluten free lunch, then you should. 🙁