Coeliac Australia

Submission from Coeliac Australia

28 July 2011

On behalf of Coeliac Australia I wish to make a submission to the National Food Plan Issues Paper Consultation Questions with specific reference to Chapter 1, Question 10.

Q 10. What regulation or regulatory regime poses the greatest burden on the food industry along the food supply chain? What could be done to reduce this burden?

The regulation with regard to the definition of ‘Gluten Free’ in relation to food ingredient claims poses a significant burden on the food industry. The adoption of the internationally accepted definition of Gluten Free under Codex, being Gluten Free is defined as less than 20ppm gluten, would dramatically reduce this burden.

Coeliac Disease is an autoimmune disease whereby the body cannot tolerate gluten (the protein found in wheat, rye, barley and oats). When gluten is ingested, the small bowel becomes inflamed and food is not absorbed properly.

Typical symptoms of Coeliac Disease are diarrhoea, wind, bloating although other symptoms can occur in response to lack of absorption of nutrients – anaemia, lethargy etc. Serious long term consequences of non-diagnosis of coeliac disease are osteoporosis and cancer.

The only treatment for Coeliac Disease is a gluten free diet for life. Accordingly people with Coeliac Disease rely on suitable labelling of products in order to make correct and safe food choices.

The definition of the term “gluten free” under internationally accepted standards (Codex) has established that less than 20ppm is an appropriate and safe standard by European countries. The USA is still moving towards finalisation of a gluten free standard but it appears 20ppm will be accepted.

In Canada, the definition of gluten free is “no ingredient derived from wheat, rye, barley and oats”, but contamination up to 20ppm is allowed.

This level of 20ppm has been endorsed as a safe level of gluten consumption by Dr Robert Anderson who is leading a team of researchers in developing a vaccine for coeliac disease. Coeliac Australia also supports a level of 20ppm as gluten free and endorses products at this level.

In Australia, the Food Standards Code defines gluten free as “no detectable gluten” and “no ingredient derived from oats or malt”. (The latter requirement is related to poor analytical methods for detecting gluten in oats or malt).

The testing methods for gluten have improved dramatically in recent years and the limit of detection is now 3ppm. So for a product to be labelled gluten free in Australia it must contain less than 3ppm. Accordingly products labelled gluten free in Europe may not necessarily be gluten free in Australia.

Of more concern is the fact that as analytical testing becomes more sensitive, the level of detection may decrease to 1ppm and below and it may be difficult, because of cross contact, for any product to be labelled gluten free. Coeliac Australia is concerned that the term gluten free may disappear altogether and we will be the only country not to be able to supply gluten free foods. This would seem to be an unfortunate outcome for a food standard developed to assist people with Coeliac Disease.

As well as the concerns of Coeliac Australia, there are costs and constraints imposed on manufacturers in complying with a standard that is more restrictive than is required. These would include –

1. Additional costs of obtaining raw material (both in Australia and internationally) that have been processed sufficiently and segregated to the point where they can be confidently used in gluten free foods.

2. Additional costs in ensuring that manufacturing processes and equipment do not allow for cross contamination to the point of exceeding the level of detection.

3. The concern over product recalls when cross contamination may exceed the level of detection but not be picked up by random testing.

A product in Victoria taken from supermarket shelves for routine audit testing by the Health Department of a local council showed 8ppm gluten and a nationwide withdrawal was required because of the supermarket’s fear of a false and misleading claim.

This is in spite of the fact that the product would be acceptable anywhere else in the world as gluten free and indeed would be endorsed by Coeliac Australia as suitable for people with Coeliac Disease..

Naturally, manufacturers, particularly small ones, are most concerned that despite procedures to ensure production to a gluten free standard, contamination can lead to the situation when the product is deemed unsuitable.

As manufacturers pass these additional costs on to the selling price of gluten free foods, this will impose a further burden on coeliacs and the gluten intolerant who are already paying extra for essential food items such as bread and cereal.

Coeliac Australia has approached FSANZ and the ACCC with the aim of altering the gluten free standard to less than 20ppm.

To date this has been unsuccessful, and this submission is made in a further attempt to have the gluten free standard changed to a level in line with international practice and one which is still suitable as a treatment for people with Coeliac Disease.

[Signature removed]

David Sullivan
NATIONAL BUSINESS DEVELOPMENT MANAGER
COELIAC AUSTRALIA