July/August 2018

In this issue
  • 2018 Proficiency Testing Registration
  • FAQs on New Grain Count Requirement
  • Certification Bodies and Plant Registration
  • Mislabeling of GFCO Products
  • Certification Updates
  • GFCO Contact Information

2018 Proficiency Testing Registration  

Registration for GFCO’s 2018 Gluten Proficiency Testing (PT) round will begin on September 1, 2018. This year we plan to allow submission of qualitative and quantitative testing results.
This program provides one way to meet GFCO Standard requirement 72, which requires that all plants who perform their own in-house gluten testing participate in PT at least once every 4 years. Contact GFCO for other PT programs that are accepted to meet this requirement.
Beginning September 1, register by going to www.gluten.org/proficiency-registration/

REMINDER: Testing Submissions for the second quarter of 2018 were due on July 10th. Please make sure you have submitted your data to testing@gluten.org .
FAQs On GFCO’s Grain Count Requirement

On June 1, 2018, GFCO sent notice to all of our Brand Owners and manufacturing Plants that, beginning January 1, 2019, all whole unprocessed grains, beans, seeds, pulses and legumes sold bearing the GFCO logo must contain no more than 0.25 gluten-containing grains per kilogram, in addition to meeting the 10 ppm threshold.
Since the release of that notice, we have received several questions about its meaning and implementation. The following are some of the most frequently asked questions about this new requirement, with answers provided by GFCO.

What does the “0.25” refer to? What is being measured?
This new threshold is measured in the number of wheat, rye or barley grains present within a kilogram of the gluten-free grain, seed, bean, pulse or legume being sold. This number is obtained by examining the gluten-free grain for the presence of inadvertent wheat, rye or barley grains, and determining the average number of these grains per kilogram of gluten-free product. This threshold can also be expressed as “no more than 1 gluten-containing grain per every 4 kg of gluten-free grain”.
What does “unprocessed” mean?
Unprocessed means that the commodity has not been processed beyond basic cleaning, washing, dehulling, deshelling, heating to enhance stability (not for cooking), or drying for storage.
What is meant by “visual inspection”? For example, do the grain counts have to be done only by our staff?
For the purposes of this GFCO requirement, “visual inspection” means the identification of wheat, rye or barley grains within a gluten-free grain, as confirmed by the human eye. This does not mean that all of the sorting and identification have to be done entirely by people, although it can be. Properly validated optical and mechanical methods can also be used to sort grain samples and isolate any potential contamination by wheat, rye or barley. The final identification of any grains flagged by these methods should be made by trained personnel.
Does this new requirement apply to my incoming ingredients?
No. At this time, GFCO is only placing this requirement on manufacturers who sell whole, unprocessed grains, beans, seeds, pulses and legumes bearing the GFCO logo.
Does this requirement apply to spices?
No, whole-seed spices are not expected to meet this new requirement.
Does this requirement include popping corn?
The requirement will apply to bulk popping corn sold for further packaging or processing, but not to popping corn that sold to consumers in any retail packaging, whether seasoned or unseasoned.
What records will GFCO expect to see, to show that we are meeting this new requirement?
In addition to the testing log you have been using to track your in-house gluten testing, or the test results you receive from an independent laboratory, GFCO auditors will also want to see records of the grain counts you have performed on each lot of whole grain, seed, bean, pulse or legume that is sold bearing the GFCO logo. These grain counts should be done using a statistically valid sampling plan, and should show that the average contamination is at a level below 0.25 gluten-containing grains per kilogram of the gluten-free grain, or 1 whole gluten grain per 4 kg of gluten-free grain.
If you have any questions about your company’s certified products, and whether this new requirement applies to any of them, please contact GFCO and we will review your product list.

Certification Bodies and Plant Registration

By the end of 2018, GFCO will be developing partnerships with other ISO 17065 accredited certification bodies, to give manufacturers more options for certification. This will expand the global reach, recognition and value of GFCO certification, which is already the leader in this field. All clients will still have the option to receive their certification directly through the GFCO certification program, but the addition of other certifiers may allow companies with other food safety certifications (SQF, BRC, Organic, etc.) to combine those with their gluten-free certification in one audit visit.
Once these other certification options are available, GFCO will be requiring an annual registration of all manufacturing facilities involved in the production of certified Products. This step is necessary to ensure that GFCO maintains centralized knowledge of all products being sold with the GFCO logo, as we allow other agencies to conduct independent certifications. This registration will require a nominal fee for processing of $100 per facility, but will benefit manufacturers by introducing a publicly-available database of manufacturing plants that are available for private-label or contract manufacturing of GFCO certified products.
All manufacturing plants actively operating under a GFCO certification at the time that this registration is introduced will be automatically included in the plant registration database, with the registration fee waived for the first year. After the first year, plants will need to re-register each year and pay the registration fee. If you do not want your plant listed in the public database, please notify GFCO.
GFCO will be issuing announcements as new certification bodies sign on, and about the launch of the public plant database.

Mislabeling of GFCO Certified Products
GFCO manufacturers have had recent incidents of mislabeling or mispackaging of certified products. In most cases these products presented no actual risk to gluten-free consumers, but were inadvertently labeled to indicate that they contained wheat or barley ingredients.
Because these items did not actually contain gluten, their gluten-free claim and certification mark were accurate, and these products were not recalled. The product manufacturers did not choose to remove the products from the shelf voluntarily.
GFCO understands that this type of mislabeling/mispackaging is confusing for consumers, and would like to encourage manufacturers to remove mislabeled product from retail sale. GFCO has the right to withdraw the certification of any product, but this would not be the first option because it would not take the mislabeled product off of the shelf, and might penalize later production runs that are correctly labeled/packaged.
Instead, GFCO is instituting a new policy that would withdraw a client’s entire certification if there were a second incident of gluten-related mislabeling/
mispackaging in which the manufacturer chose not to voluntarily pull back a mislabeled product from retail shelves, or if there were two actual gluten-related product recalls, during the tenure of the client’s certification. GFCO continues to reserve the right to withdraw certification at any time.
This policy will be posted at the top of GFCO’s Safety Alerts page ( www.gfco.org/safety-alerts ). The Safety Alerts page is used to notify the public of any incidents concerning certified products, and other food safety information of interest to gluten-free consumers.

Certification Updates  
In May, we announced the release of the GFCO Certification Manual. This Manual is now the centralized source for information regarding the GFCO certification process and GFCO policies, and the information in the Manual replaces the following GFCO documents:
  • 3003-P – GFCO Certification FAQs
  • 3009-P – GFCO Audit Agenda
  • 3022-P – GFCO Certified Company-Application Appeals Process
  • 3024-P – GFCO Ingredient Risks and Testing
  • 3029-P – GFCO Certification Reduction, Probation, Withdrawal and Termination
  • 3036-P – GFCO Client Feedback and Complaint Resolution
  • 3044-P – GFCO Impartiality Procedure
  • 3045-P – Explanation of the GFCO Standard Requirements

Please discard or delete any copies of these documents in your possession.
In addition, we have recently updated the GFCO Approved Kit list. Revision 6 of this document is available through the link in the Testing section of the GFCO Certification Manual, which can be accessed at www.gfco.org/process .


Customer Service
For general certification
questions and changes to your certification, including changes to Products, Ingredients and manufacturing facilties.
For questions about payments for certification or audits.
Quality Control
For questions about audit
report findings and contract testing requirements.
Ronni Alicea


Regulatory & Standards
For questions about the GFCO Standard requirements, testing methods, and to report positive gluten test results > 10 ppm in finished product.
Laura Allred
Vice President
Channon Quinn
Gluten Intolerance Group
31214 124th Ave SE Auburn, WA 98092
P: (253) 833-6655
F: (253) 833-6675 
Gluten Intolerance Group of North America® is a 501c3 nonprofit Washington State corporation. 
Tax ID 91-1458226.