Quarter 3 - 2019
In this issue
  • 2019 Proficiency Testing Registration
  • Fermented/Hydrolyzed Ingredients
  • CBD Products
  • GFCO and GIG’s Mission
  • Certification Updates
  • GFCO Contact Information
2019 Proficiency
Testing Registration
Registration for GFCO’s 2019 Gluten Proficiency Testing (PT) round will begin on September 1, 2019. 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. See pages 21-22 of the GFCO Scheme Manual for other PT programs that are accepted to meet this requirement.
Beginning September 1, register by going to https://www.gluten.org/proficiency-registration/
REMINDER: Testing Submissions for the second quarter of 2019 were due on July 10th. Please make sure you have submitted your data to testing@gluten.org .
Hydrolysis, Fermentation and Distillation
Some ingredients and products made from gluten-containing grains are fermented or hydrolyzed as part of their processing. Common examples of this are soy sauce, beer, and protein hydrolysates. Fermentation and hydrolysis are both processes that break carbohydrates and proteins down into their simpler component parts. Fermentation is typically performed by microorganisms such as yeast and bacteria, while hydrolysis can be done with the use of chemicals or enzymes. Fermentation and hydrolysis are used to develop desirable properties in ingredients, such as alcohol content, flavor, or texture.
Because fermentation and hydrolysis can break down proteins, they can affect the structure of gluten. This can mean that the gluten proteins are no longer visible to the test kits on the market. Unfortunately, we do not have simple methods to determine if there are gluten fragments remaining that are hazardous for persons with Celiac Disease, but are not detected by the test kits. A study published last year by GFCO indicated that there are still gluten fragments that are recognized by the antibodies of persons with Celiac Disease in beer that has been treated with an enzyme designed to remove residual proteins. However, this is just one type of hydrolysis, and it is unknown if this antibody recognition results in disease progression.
Because of this uncertainty about detecting residual gluten in fermented and hydrolyzed materials, the FDA released a proposed rule regarding gluten-free labeling of fermented and hydrolyzed foods. This rule, which is in line with GFCO’s requirements for certifying fermented or hydrolyzed products, states that in order to make a gluten-free claim on an ingredient or product, the starting materials must be gluten free before the fermentation or hydrolysis begins. This means that a product like soy sauce cannot include wheat as an ingredient, and that the soy beans used in the soy sauce should be confirmed as being gluten free (not cross-contaminated) before use. It also means that a traditional beer, brewed from barley, or any hydrolyzed protein made from a gluten-containing grain, can never bear a gluten-free claim, or the GFCO logo, regardless of the results of testing performed with the test kits that are currently on the market.
One fermented product that is an exception to this rule for GFCO certification is distilled alcohols. Distilled alcohols are regulated by the Alcohol and Tobacco Tax and Trade Bureau (TTB), rather than the FDA, and therefore do not fall under the FDA gluten-free labeling regulation. The TTB is developing their own policies regarding gluten-free labeling of the products they regulate.
Distillation is a process used to remove water from a fermented liquid, thereby increasing the alcohol concentration. Distillation uses heat to vaporize the least-dense components of a liquid—the alcohols—and then collects these vapors and re-condenses them into a liquid. In this process, the “heavier” fractions of the liquid are left behind, including the proteins. This process results in the removal of gluten, even from products that start from gluten-containing grains. For this reason, GFCO allows distilled alcohols made from gluten-containing grains to be certified gluten-free, and also allows ingredients that contain distilled alcohols to be used in certified products. The most common place you will see this is in flavoring extracts, such as vanilla, which are commonly extracted in grain alcohols.

CBD Products and Certification
In March of 2017, the U.S. Drug Enforcement Agency (DEA) clarified its stance on hemp and hemp-derived products (that is, products containing cannabidiol (“CBD”)), stating that where the CBD is derived exclusively from the portions of the marijuana plant that are not made illegal under the Federal Controlled Substances Act (such as the mature stalk of the cannabis plant), it is no longer illegal under federal law (see reference  here ). However, consumable (edible) CBD and hemp-containing products are still not clearly legal under federal law. The FDA and Alcohol and Tobacco Tax and Trade Bureau have both recently said they will not grant approval to food products containing hemp or hemp-derived products .   For this reason, the vast majority (if not all) of the CBD/hemp-containing products that would be eligible for certification under the GFCO Scheme are not clearly legal under federal law. GFCO does not certify goods and services offered in violation of any federal law, and does not permit its certification marks to be used on goods and services offered in violation of any federal law. Therefore, it is currently GFCO policy that we do not allow the gluten-free certification of CBD/hemp-containing products.

GFCO and the Mission of GIG
GFCO is a very unique gluten-free certification program, in that it is owned and operated by a consumer-focused non-profit organization, the Gluten Intolerance Group (GIG). GIG was founded over 40 years ago to support the gluten-free community, and the GFCO certification program was an outgrowth of that mission.
Funds generated by the GFCO certification program are used to help GIG empower the gluten-free community through consumer support, advocacy and education. GIG does this through their publications, support groups, and events such as Generation GF kids’ camps. GIG’s focus on consumers has made GFCO the most trusted and widely recognized gluten-free certification program, because consumers recognize the intent behind the logo. They know that the program was designed to help them find the safest gluten-free foods.
Whether a company is interested in filling the need for safe gluten-free foods, or has close personal ties to the gluten-free community, all GFCO certification clients are helping GIG fulfill its mission. For those that are interested, GIG also offers donation, sponsorship and advertising options for companies to help support GIG’s goals, while also increasing the company’s visibility with gluten-free consumers.
More information about GIG's sponsorship program and how your company can get involved can be found on the Marketing page of the GIG website. General donations to help support our gluten-free community can be made at gfdonate.org. 
If your company would be interested in learning more about our current and future involvement opportunities, please contact Chris Rich, GIG's VP of Marketing & Development, at chris.rich@gluten.org or at 253-545-1826.

Customer Service
Quality Control
Regulatory Manager

GFCO Program Manager
Testing Submissions —testing@gluten.org

Logo Submissions —gfco.branding@gluten.org

Positive Results —gfco.alerts@gluten.org
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.