What was agreed?
The adopted guidelines establish several important principles:
- Food Business Operators should minimise cross-contamination wherever possible.
- Precautionary allergen labelling should only be used when a risk assessment shows there is a genuine risk above established action levels.
- The widespread overuse of PAL statements should be reduced.
- Cereals containing gluten are now specifically included within the framework, with a reference dose of 4 mg of gluten.
- Products carrying a precautionary statement for gluten can never simultaneously carry a gluten-free claim.
- The standard wording for PAL remains "may contain".
- Oats do not need to be labelled in a PAL statement. The guidelines recognise that concerns around oats relate primarily to potential cross-contamination with gluten-containing cereals.
One particularly important achievement for AOECS was securing clarification that precautionary allergen labelling and gluten-free claims serve entirely different purposes.
A PAL statement indicates a potential risk. A gluten-free claim indicates that a product has been specifically produced and assessed to meet gluten-free requirements. These are fundamentally different messages and must remain clearly separated.
Understanding the Difference Between PAL and Gluten-Free
One of the more technical discussions concerned the reference dose for gluten. The adopted guidelines use a reference dose of 4 mg of gluten, based on advice from international experts.
It is important to understand that this is not the same as the 20 mg/kg threshold used for gluten-free claims. The PAL system is based on the total amount of gluten a consumer may ingest from a typical serving, whereas the gluten-free standard is based on the concentration of gluten in a product. These are different approaches designed for different purposes, which is why the numerical values cannot be directly compared.
Behind the scenes
Many of the most important discussions took place long before delegates arrived in Ottawa.
AOECS established a global task force that met regularly to prepare positions and coordinate actions. Special thanks go to Alex Costigliola from Coeliac UK, whose technical expertise and ability to bridge the gap between scientific experts and patient organisations were invaluable throughout the process.
We also benefited from close cooperation with representatives from the allergy community, national authorities and other stakeholders who helped build support for the inclusion of coeliac disease within the guidelines.
Looking ahead
Although the adoption of these guidelines represents a major achievement, it is only one step in a longer process.
The next challenge is implementation. National and regional authorities will now need to consider how the Codex guidance can be reflected in legislation. For many AOECS member societies, this work will primarily take place at European Union level and is expected to take several years.
AOECS will continue to engage with regulators and policymakers throughout this process to ensure that the interests of people with coeliac disease remain fully represented.
CCFL49 demonstrated what can be achieved when patient organisations, scientists and regulators work together. The inclusion of coeliac disease and gluten within these global guidelines is an important step towards clearer labelling, better consumer information and greater safety for people living with coeliac disease around the world.
Floris van Overveld
Chair, AOECS