I received a statement from the Food Standards Agency last week clarifying the use of the term No Gluten Containing Ingredients – NGCI. This is the statement:
NGCI labelling on prepacked foods is being phased out from 20 July 2016.
By 20 February 2018, we expect food businesses to bring their labels into compliance. Until then, food businesses can continue to place on the market prepacked foods with NGCI labels until those label stocks have been exhausted.
We also advise food businesses to share their approaches on reaching compliance with their enforcement officers, especially if it might not be possible to change their labels by 20 February 2018
What’s not changing
NGCI can be used in describing positive lists of everyday foods or a selection of products available for sale in a shop or online.
Within these cases, NGCI can only be used as a factual statement when the business cannot guarantee their foods are gluten-free.
Non-prepacked foods/ menus
A NGCI statement, which relates to any single dish on a menu, is being phased out from 20 July 2016. Descriptions such as “cottage pie: this dish has no gluten containing ingredients” should not be used.
By 20 February 2018, we expect food businesses to bring their menus into compliance. Where this is not possible, we advise food businesses to discuss approaches on reaching compliance with their enforcement officers.
What’s not changing
Food businesses can use NGCI in menus when listing a group of products/ dishes or in menu titles, to indicate that all the items in question do not have gluten containing ingredients. Examples include “(menu title) No gluten containing ingredients menu” or statements such as “All dishes on this menu do not use gluten containing ingredients”.
So, as discussed in my previous blog The Case for No Gluten Containing Ingredients, what this fundamentally means for restaurants is that they will need to have a separate menu (or a least a separate part of the menu) clarifying which dishes do not contain any gluten ingredients if they wish to label the dishes with allergen information relating to gluten.
It’s not just ‘No Gluten Containing Ingredients – NGCI’…
…there are no fewer than seven terms in circulation today. Some can be used on their own, whereas others can only be used in combination with one of the other terms. Here’s a list of the various ‘gluten free’ terms in circulation today:
This should only be used if you can consistently prove that the food item/dish contains less than or equal to 20 parts per million gluten.
‘very low gluten’
This should only be used if you can consistently prove that the food item/dish contains less than or equal to 100 parts per million gluten.
‘no gluten containing ingredients’
This is for non-prepacked foods. “No gluten containing ingredients – NGCI cannot be attributed to a single dish e.g. Cottage pie (NGCI). However, if you have a menu with sections listing starters, main courses and desserts, a section on NGCI choices is permissible. It’s also acceptable to use NGCI in menu titles provided that all the items do not use gluten containing ingredients, such as “No gluten containing ingredients menu” or statements such as “All dishes on this menu do not use gluten containing ingredients”.
The following four statements were introduced as recently as July 2016 and cannot be used on their own, they can only be used in conjunction with either ‘gluten free’ or ‘very low gluten’:
‘suitable for coeliacs’ and ‘suitable for people intolerant to gluten’
These statements can be used for naturally gluten free foods where a consumer might think the food could contain gluten. It would not be appropriate to use these statements for products like tea, fresh fruit and nuts, which do not contain gluten anyway.
‘specifically formulated for coeliacs’ and ‘specifically formulated for people intolerant to gluten’
These statements can be used for specially manufactured foods that have been prepared to reduce the gluten content of one or more ingredients; or a gluten-containing ingredient that has been substituted with one or more naturally free of gluten ingredients, e.g. foods that are available on prescription.
If you run a food business – here’s a PDF explaining the use of the terms ‘gluten free’ and ‘no gluten containing ingredients’, and where they apply: should I be using the term ‘gluten free’ or ‘no gluten containing ingredients’?
What’s in a name?
I’ve been thinking about this a lot recently, and having just returned from a flying visit to London, it really is farcical. Food outlets still advertise gluten free food as ‘gluten free’ and we, as coeliacs, still ask for gluten free food. The clunky ‘No Gluten Containing Ingredients – NGCI’ term rarely gets used by coeliacs and/or food providers. Can we not just accept that the term ‘gluten free’ will always be around and instead of fighting against it, we embrace it?
We all know that food in sealed packaging labelled as gluten free has been tested for the level of gluten and that it can only be labelled as such if it can be proven. However, the term ‘gluten free’ in a restaurant, cafe, etc means something completely different. It should mean (as does ‘No Gluten Containing Ingredients – NGCI’) that processes and procedures are in place to manage the food to minimise contamination, but this is not always the case.
I accept that if someone has used the term ‘No Gluten Containing Ingredients – NGCI’ then it does show some sort of thought process and therefore, one hopes, an understanding of managing the catering of a gluten free diet. However, so many food outlets pay not a jot of attention to it and put up big signs saying ‘gluten free’.
Interestingly, what was significant about my trip to London is how many establishments didn’t know what ingredients were used in their foods/dishes and more worryingly did not have easy access to a full ingredients list. This was made law way back in December 2014 and here we are today and still food outlets don’t have the full information to hand.
However, the biggest issue is – and seemingly will always be – that no matter what terminology is used, there is still inadequate training, understanding and policing of serving gluten free (or No Gluten Containing Ingredients – NGCI) foods. Environmental Health and Trading Standards are stretched beyond their capabilities and thus no-one is able to manage this effectively. In an ideal world, when such statements are made, there should be some sort of reassurance that the assertions are true, however, I can’t think of another way to check the understanding of food establishments other than to ask to see the processes they have in place. Can you imagine, before I sit down I ask to be shown to the kitchen and spend ten minutes going through what ingredients my meal contains and how it is prepared and plated – hmmmm I can see that working!
All I want is that whether an establishment says ‘gluten free’, or ‘No Gluten Containing Ingredients – NGCI’, that they understand what that means and that they take care and attention in preparing it so that the risk of me being ill (and others) is minimised.