Shopping for safe gluten-free products should have become easier since the FDA’s gluten-free food labeling rule went into effect in 2014. In my experience as someone with celiac disease, reading and interpreting labels has, in many ways, grown more complicated.
After speaking at The Food Allergy Blogger’s Conference in Denver, Colorado, I wrote this piece to help readers understand how to shop for safe gluten-free foods and how to read food labels. I encouraged fellow bloggers—many of whom are food allergy advocates—to help educate their audiences about choosing products that are genuinely safe for those avoiding gluten.
Even among food allergy bloggers, there was confusion about the difference between products that are independently certified gluten-free and those that are simply labeled “gluten-free” by the manufacturer. That confusion is common and understandable.
How Does the FDA Regulate Gluten Free Food Labels?
What Does Less Than 20 Parts Per Million Mean?
The FDA gluten-free labeling regulations that followed advocacy efforts went into effect in August 2014. These rules require manufacturers who label products as “gluten-free” to assert that the product contains less than 20 parts per million (ppm) gluten. To put that in perspective, 20 ppm is a very small amount—comparable to a tiny trace in a large volume of food.
In the U.S. There Is No Requirement to Test for Gluten
Surprisingly, manufacturers are not required by the FDA to test their products for gluten, nor are they required to use a particular testing method or frequency. This regulatory gap allows variance in how manufacturers verify their gluten-free claims.
“May Contain Wheat” Statements / “Made in a Facility” Claims (PALS — Precautionary Allergen Statements)
Manufacturers can label products gluten-free even if those products are made in facilities or on equipment that also process gluten-containing ingredients. They may choose to include precautionary statements such as “may contain” or “made in a facility with” or may omit those statements entirely. That inconsistency means two similar products—both made on equipment that handles wheat—might be labeled differently, causing confusion for consumers.
These precautionary allergen statements (PALS) are primarily legal protections for manufacturers and are not standardized, so they don’t convey consistent meaning between brands. Because of that, PALS are unreliable indicators of actual risk.
Understanding this helps explain why gluten-free labeling remains confusing despite federal rules.
Example: Gluten Mislabeling Due to Misunderstandings
Some manufacturers label products gluten-free without fully understanding what gluten is or how the FDA rules apply. That can lead to serious mislabeling, such as products that include wheat-derived ingredients that still contain gluten despite processing methods like fermentation.
Example: Not Gluten-Free Cheerios
High-profile examples show how these gaps can harm consumers. General Mills labeled Cheerios® as gluten-free in the United States, but concerns and recalls related to elevated gluten levels have highlighted the limits of self-declaration. Other countries have different labeling outcomes, underscoring the inconsistency that can occur without independent verification.
Gluten-Free Manufacturers Doing It Right Are Certified Gluten Free By Outside, Independent Agencies
Fortunately, many manufacturers choose independent, third-party gluten-free certifiers to verify and audit their facilities and products. Independent certification adds meaningful oversight: certifiers audit facilities, review ingredient sourcing, test finished products for gluten, and can require recalls or relabeling if a product fails to meet standards.
Independent, Third-Party Gluten Free Certification Organizations
A certifier vouches for the authenticity of a claim. In the U.S., there are several recognized independent certifiers for gluten-free products. These agencies generally require end-product testing, ingredient review, employee training, and audits of cleaning practices and cross-contact controls. They typically test to limits at or below the FDA’s 20 ppm standard and have enforcement mechanisms beyond what self-declaration provides.
SHOPPING TIP: If you want products independently tested, look for the words “CERTIFIED GLUTEN FREE” or “CERTIFICATION” and a recognized certifier’s symbol on the packaging.
What Are the Gluten-Free Certifiers in the U.S.?*
1) Gluten Free Certification Organization (GFCO) — One of the best-known programs; GFCO tests to a tighter standard (typically under 10 ppm) and certifies many products domestically and internationally.
2) Kitchens with Confidence by MenuTrinfo — A leading auditor for allergens and gluten, certifying products and foodservice operations, generally to 10 ppm or less.
3) National Celiac Association / Gluten-Free Food Program — Historically involved in a strict testing program; program ownership and labeling have evolved over time.
4) Beyond Celiac Gluten Free Certification Program — Partnered with a Canadian certification program and certifies brands and products across North America.
5) NSF International — Offers gluten-free certification aligned with the FDA rule, testing products to under 15 ppm gluten.
6) Scientific Certification Systems (SCS) — An established certifier in other spaces that added gluten-free certification and typically requires testing to 10 ppm or less.
While standards vary among agencies, these certifiers provide independent testing, auditing, and oversight that help protect consumers and increase confidence in labeled products.
Note: Some certified products may still be produced in facilities that handle gluten in other lines, so consumers should remain aware of precautionary statements and certifier specifics.
“Gluten Free” Labels Which Do NOT Indicate Independent Certification and Testing
Be cautious of logos or claims that look like certification but are actually manufacturer self-designations. These “soft claims” do not guarantee independent testing or audits. Likewise, products made in dedicated gluten-free facilities can offer strong protection, but independent testing of ingredients and finished products is still the safest assurance.
How Do I Tell If a Product Is Really Gluten Free?
If you’re unsure about a product’s gluten-free status, contact the manufacturer and ask about ingredient sourcing, cross-contact prevention, and testing protocols. Encourage manufacturers to pursue independent certification from a recognized agency—this oversight demonstrates a stronger commitment to safety for gluten-free consumers.
How Do I Tell If a Product Is Really Allergen Free? (Peanut Free, Tree Nut Free, Dairy Free, Egg Free, Sesame Free, etc.)
For foods free from other allergens, look for independent “Certified Free From” labels. These seals indicate testing and oversight by a third party and provide higher assurance than a manufacturer’s unverified claim. Independent certification programs also enable immediate recall and corrective action if a product is found to be unsafe.
My own products were among those early to earn independent seals for being free from major allergens, reflecting the protections these programs offer consumers.
In Conclusion …
READ EVERY LABEL, EVERY TIME.
Ingredients and labels change, and traces of gluten can appear in unexpected products. When possible, choose products that are certified gluten-free by an independent organization. Independent certification increases the likelihood that a product has been tested, audited, and verified to meet strict standards and that corrective actions will be taken promptly if problems arise.
Oats deserve special mention: unless they follow a trusted purity protocol, oats are an inherently risky ingredient because of cross-contact during growing, transport, or processing.
Without independent certifiers, manufacturers can choose whether or not to test, recall, or report problems. Although the FDA provides oversight, independent third-party certification adds a practical layer of protection that helps prevent contaminated products from reaching consumers and enables faster responses when issues are identified.
No system is perfect, but using products certified by reputable independent agencies gives those of us who must avoid gluten a better chance of staying safe.