The GFCO Quarterly Q2 2021

Quarter 2 2021

In this issue

FDA Fermented & Hydrolyzed Regulation
Public Product List
Marketing Update
Logo Use Submission
GIG Announcement
2021 Proficiency Testing
Certification Mark Update

FDA Regulation on Fermented

& Hydrolyzed Products

The FDA final rule on gluten-free labeling of fermented and hydrolyzed foods goes into effect on August 31 of this year. This rule impacts all GFCO clients who use any materials processed by or derived from live cultures, including yeast, bacterially-grown enzymes and probiotics.

For all cultures, enzymes and probiotics that are reported to GFCO as ingredients or processing aids in certified products, we are requesting information on the growth media used. We understand that the new FDA regulation is a change, and we do not plan to withdraw certification for any currently certified products. Our aim is to provide information to help people meet the new FDA regulation. However, we do not enforce the FDA regulation, and we cannot guarantee that our suggestions will meet the FDA requirements.

GFCO recommends that all of our clients using these types of materials from live cultures begin to obtain information from their suppliers on the growth media being used. GFCO will soon be releasing a form to help record this information. Also, gather specific information, including the protein concentration of the product as supplied, the purity (for enzymes in particular), and internal information on how much of the culture product is present in the final product. The FDA regulation is not clear in regards to how enzymes and cultures made in gluten-containing media should be handled, and in fact only mention them in the comments, but they do suggest that the amount of enzyme used will be a consideration as to whether they can be used in a product labeled gluten-free when they say “An important consideration is the amount of potential carryover and how much of the enzyme ingredient is used in the production of the final food product.” They also make it clear throughout that they expect manufacturers to be able to meet these new requirements via documentation, which is why we are suggesting that companies begin to collect these documents now.

Once you gather your documents, if you need any help reviewing them, or in determining potential gluten contamination based on the information you receive, please contact [email protected].

If you are able to share any of the information you receive from your suppliers, or any of your internal information about how much of a cultured material you use in finished products, please also contact [email protected]. The more information we can collect regarding the very low potential of gluten contamination in typical use, the better we will be able to provide guidance for everyone.

REMINDER: Testing Submissions for the first quarter of 2021 were due on April 10th. Please make sure to submit your data to [email protected]

Automated reminders will now be sent 30 days after the testing due date, to any client who has not submitted testing data or a notice that they did not produce certified products during the previous quarter. Testing and the submission of testing data are a requirement for certification, and the failure to submit testing data, or a notice that no certified products were produced, may result in the reduction, probation or withdrawal of certification.

Public Product List

In 2020, GFCO introduced an online list of certified products, which could be accessed by consumers to find products by brand name or product name. The goal of the list is to help consumers and manufacturers find safe products and raw materials, and to direct buyers towards products that are certified by GFCO. We have had great public feedback about the list, and the ways in which it helps people to find safe products. We have also heard that consumers felt frustration and confusion, because not all certified products were available on this list. As the GFCO product directory has become a reference point for consumers confirming certification status, GFCO has determined that providing for the consumer is the priority. For these reasons, the appearance of all certified products on the public list will become mandatory on September 1, 2021, regardless of whether clients have previously chosen to opt out. We are confident that this change will benefit not only consumers but also our GFCO clients, who have invested a great deal of time and effort into earning and maintaining their certification. This will be a win-win for all.

The public product list, which can be viewed at www.gfco.org/product-directory, does not display any confidential information. The current entries are the brand name and product name, but the next phase of our public product list development may include upgrades, including a display of UPC codes and product photos.

As mentioned, there will no longer be an opportunity to opt out of having certified products appear on the public list as of September 1, and an updated Product & Ingredient template will be released in the summer to reflect this change. The only exception will be made for products that are being submitted for certification, but which have a future release date. Those products may be kept off of the list until such time as they are available for sale.

Marketing Update

GIG is your connection to the gluten-free consumer! As a non-profit organization celebrating its 47^th year in service to the gluten-free community, our bonds with the gluten-free consumer are strong – and this is to your benefit. Here are two FREE ways that your brand get involved in our efforts today.

Got stickers. swag, or samples?

GIG and its Generation GF program have a number of activities/events coming up this summer including camps, a teen summit, and virtual influencer, leader and support group meetings. Get your brand in front of GIG's constituents. APPLY

We need you to help us Cut Costs! Be included in our Celebrate Gluten Free on a Budget magazine.

GIG is launching a new initiative to cut costs for those who are struggling with food insecurity. Can you offer a manufacturers coupon? Can you provide a promo code for your website? Let's work together to make living gluten-free a little easier. SIGN UP

Want to get more involved? Sponsorship opportunities, which offer a significant value, are available. Email [email protected] for more info!

REMINDER: Submission of Logo Usage

All GFCO clients are required to submit examples of any use of the GFCO certification mark for review and approval prior to use, by sending them to [email protected]

This includes the use of the logo on packaging, as well as in advertising and on any websites.

Types of submissions could include packaging proof pdf files, screenshots from websites, brochure or advertising files, or photos of products, webpages or materials.

Please make sure you are submitting this evidence prior to any use of the GFCO logo.

GIG Announcement

The Gluten Intolerance Group is proud to announce a new initiative launching in 2021 that will address food insecurity in the gluten-free community. Read about the announcement here.

Can we count on your brand’s support in this effort? GIG asking for assistance from GFCO clients to help those in need. Click the link above for information on how to provide:

Coupons
Product Donations
Matching Donations/Fundraisers

2021 Proficiency Testing Round

The 2021 GFCO Proficiency Testing round, Wheat and Barley Gluten in Pancake Mix, is now open. You may sign up at www.gluten.org/proficiency-registration. Preliminary reports will be issued all year, within 2 weeks of result submission. The deadline to sign up is November 30, 2021, and all results must be received by December 31, 2021.

GFCO Certification Mark Updates

The GFCO global certification mark was announced last year, and all GFCO clients must change to the new mark on their packaging and advertising by March 31, 2022. Since its release, the mark has achieved registered status in a few countries, and some clients have requested bilingual versions of the mark.

The following is an update on the status of the mark:

The full and consolidated English versions of the mark have been registered and approved in the United States, Brazil and Israel, and the full English version has been registered and approved in Peru. The mark can, and should, be used with the ® registration mark in these countries at your next packaging redesign. In all other countries, the mark should be used with the TM symbol.

A bilingual French-English mark has been submitted for review in Canada, but has not yet received initial approval. Due to coronavirus-related backlogs, the Canadian patent office is reporting a delay of 22-24 months for review. We cannot release the mark for use prior to this review, and given the legal requirements in Quebec, we are allowing clients to continue to use the previous French-English bilingual logo until the new bilingual mark is available. Once the new bilingual mark receives initial approval, clients will have two years to remove the old bilingual logo and switch to the new one.

GFCO is also in the process of developing a Spanish-English version of the certification mark, but it has not yet been submitted for review in any country. As GFCO is not aware of any countries where a Spanish-English bilingual mark is required, we request that companies use the new English mark until the bilingual mark is available. However, as with the French-English mark, we will also allow companies to use the old Spanish-English bilingual mark until the new version is available, at which point clients will have two years to remove the old bilingual logo and switch to the new one.