Standard and Manual Update

This is the official announcement of the release of GFCO Standard rev.2024 and of the GFCO Manual rev. 2024.

Thank you to the stakeholders who offered comments for the 2024 revision of the GFCO Standard. These comments and GIG’s own changes have been incorporated into the official version of the GFCO Standard, which is found at the end of the GFCO Manual. A summary of the Standard changes is provided below, and an unofficial copy of the Standard requirements with the redlined changes can be viewed at www.gfco.org/standard-update. A summary of the changes to the GFCO Manual for 2024 is found at the end of the Manual, which you can download at www.gfco.org/certification.

Changes to the Standard will become effective December 1, 2024, while any other changes to the Manual will become effective August 1, 2024.

Summary of GFCO Standard Updates

• Throughout
• Made it clear when we are talking about certified products vs any other gluten-free products in the plant, either by adding the word “certified” or through the use of the capital P “Product”, which by definition means a certified product.
• Substituting “documentation” for “list”, to help make it clear that these requirements can be met through physical or electronic records, and that the information may not necessarily be kept in one place as a single list.
• Took out references to “the certifying body” and replaced with GFCO
• Inserted the term “Publicly Sold” in place of simply “sold”. The definition of Publicly Sold is found in the GFCO Manual.
• Requirement 5: Replaced the word “or” with “and”, to make it clear that we expect all staff whose work is related to certified Products to be trained on gluten and its risks.
• Requirement 9: Edited to make it clear that GFCO may ask for a list of retailers, for example when we are looking for a product for independent testing. GFCO does not expect the Brand Owner to keep a complete list at all times.
•  Requirement 12: This requirement was edited to make it clear that manufacturing sites are responsible for having information on the country of sale for each certified product, and the gluten-free labeling regulations in those countries, even if the Brand Owner is the one responsible for packaging design. The Plant must request this information from the Brand Owner as needed.
• Requirement 15: Included the requirement for annual plant registration.
• Requirements 21 and 22: These requirements were reworded to make them more straightforward to audit, and to include specifics on certain topics that need to be covered, namely gluten sources and risks, and how to report suspected contamination. Previously, both requirements asked for training and evaluation, but now requirement 21 asks for training (which would be shown via training records), and requirement 22 asks for evidence that the training was effective.
• Requirement 33: This requirement was edited to make it clear that the Plant not only needs to have documentation of all of the ingredients being used in certified products, they must also know the risk factors for each of those ingredients, as assigned by GFCO. The Plant is responsible for requesting this information from the Brand Owner, if the Plant is not the one submitting P&I updates.
• Requirement 41: Similar to requirement 33, this requirement was edited to make it clear that the Plant needs to have documentation regarding which Products are currently certified, and not simply rely on packaging provided by the Brand Owner. The Plant is responsible for requesting this information from the Brand Owner, if the Plant is not the one submitting P&I updates or receiving copies of the certificates.
• Requirement 50: This requirement was edited to remove a duplicated requirement – previously both requirements 45 and 50 had wording that required procedures for ensuring that the correct packaging is used on each lot. That requirement is now left in only requirement 45. Additionally, requirement 50 was reworded to make it clear what is meant when “packaging occurs separately” – it is now worded as “when packaging occurs on a separate line”, that is when separate cleaning and sequencing instructions are needed.
• Requirement 52: This requirement previously only referred to “rework”, but given the specific definitions of that term, it has been expanded to include reclaimed and recycled materials. Examples of what is meant by these terms are provided under this requirement in the Manual. There is now also a specific requirement for a policy prohibiting rework, recycling or reclaiming of materials, in plants where this is not allowed.
• Requirement 53: The term “sequestering” was removed from this requirement, due to some specific definitions of that term.
• Requirement 54: Wording was added to this requirement that calls for a specific written policy to prohibit purging as a cleaning method, in facilities where purging is not used.
• Requirement 55: This requirement was updated to require that the plant perform a risk assessment for dust, and to take dust control measures as needed. Expectations under this update include documentation of the risk assessment and its regular review under the Gluten Program (per requirement 23), as well as actual dust control measures where needed.
• Requirement 69: This requirement was updated to incorporate requirements for the step-down schedule and cleaning validation protocol given in the GFCO Manual.
• Requirement 75: The term “staff” was replaced with “agents”, as our contracted auditors are not technically GFCO staff.



Positive Release Programs

Last month, Food Safety Magazine published an article on the importance of using a positive release program to ensure food safety. In a positive release program, products are not released for distribution or sale until all related testing and safety checks have been completed and reviewed. GFCO expects all of our manufacturers to be using the principles of a positive release program for their finished products, and to also incorporate this concept into your required raw material testing. Risk level 3 and 4 ingredients are required to be tested before they are used in any certified product, and the results of that testing should be reviewed before production begins. Using the positive release principle for raw ingredients and finished products can help companies save money and their reputations by preventing market withdrawals and recalls.