Quarter 4 2021

In this issue
  • Mandatory Public Product List
  • Product & Ingredient Review
  • Ingredient Risk Scores
  • Manufacturer Listing
  • Proficiency Testing 2021 and 2022
  • Certification Mark Update
  • Logo Use Submissions
  • Marketing Update
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. For this reason, beginning with our Quarter 1, 2021 newsletter, we announced that appearance on the public list would be mandatory beginning September 1, 2021. Given our recent issues with email deliverability, we have now adjusted that deadline, and the appearance of all certified products on the public list will become mandatory in January 2022, 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. 

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 January 1, 2022, and an updated Product & Ingredient template will be released later this year 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 Those products will not be published on the list until such time as they are available for sale.
REMINDER: Testing Submissions for the third quarter of 2021 were due on October 10th. Please make sure to submit your data to testing@gluten.org
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.
Product and Ingredient Review
You may notice that GFCO is asking you questions about products and ingredients that have been previously reviewed and approved, or that we have increased the risk scores of some of your ingredients. There are a few reasons for this, and we would like to share a few of the common ones so that you know what to expect.

First, it’s important to remember that GFCO reviews every entry on a Product & Ingredient (P&I) submission, whether or not it has been submitted or approved before. This is done to ensure the accuracy of our records, and to double-check our review process. Here are a couple of the primary reasons that you may see an increased risk score, or a request for new documentation on previously approved items:

  1. The new FDA ruling on fermented or hydrolyzed foods. We are asking for additional documentation on any ingredient or processing aid that appears to be fermented or hydrolyzed. This is being done to ensure that we do not certify a product that the FDA might later find to be ineligible for gluten-free labeling. GFCO is only reviewing these items as they come in on P&I submissions, but all companies should be reviewing any enzymes, cultures or yeast that they use in products labeled gluten-free.
  2. Expiration of documents used to approve ingredients or reduce risk scores. If an ingredient was previously approved, or a risk score assigned, based on the provision of a GFCO certificate, supplier statement, or other document, that approval or risk score may change when that document expires. Expiration dates are set by the date provided on the document. In cases where the document has no expiration date listed, it will be considered to expire one year after it is provided to GFCO. We will not remove approval of an ingredient without first reaching out for updated documentation, but risk scores may be increased without prior notice. When this happens, updated documents may be submitted for a new risk reduction review.
  3. New information about existing ingredients. GFCO is constantly reviewing industry information and scientific studies to ensure that our approval and risking of products and ingredients is based on the latest information. This may result in the increase or decrease of ingredient risk scores, and in rare occasions, the need to remove approval of certain ingredients. Again, we will not remove approval of an ingredient without reaching out, and we will provide time and flexibility to keep the related products on your certificate.

Please remember that you always have 30 days before being required to implement any changes on your product and ingredient list. This time can be used to collect and submit any needed documentation.
Oat Supply Shortages
GFCO has seen the shortage in the oat supply begin to affect some of the companies that make certified products. As we are a consumer-safety certification, GFCO is unable to adjust its threshold of 10 ppm in ingredients and finished products to accommodate this issue. But we do want to help our clients find access to any safe, gluten-free oats that are available. Towards that end we would like to ask that:

  1. If you are a supplier of gluten-free oats that meet the GFCO standard, please reach out to laura.allred@gluten.org and let us know if you are able to handle additional customers. Any information you can provide on your oats, including the types of food products they are best suited for, would be extremely helpful. Please also provide the best contact information for your company.
  2. If you are a manufacturer in need of gluten-free oats that meet the GFCO standard please also reach out to laura.allred@gluten.org and we will see if we are able to match you with an appropriate supplier.

If manufacturers are unable to source oats that meet the GFCO 10 ppm threshold, it may become necessary to temporarily remove the related products from their certification. This can be done by submitting an updated Product & Ingredient template to gfco.clientsupport@gluten.org. While we typically don’t approve the use of stickers to cover over the GFCO logo on uncertified products, we understand that obtaining new packaging is difficult at the moment, and will approve the use of stickers where there is no other option.

If manufacturers choose to use oats that are not certified by GFCO, please be aware that those will come with a risk factor of 4. At this risk level, it is expected that you will test each container of oats that you receive. If it is an oat flour, this can be done with one test per container. For whole intact oats, this testing can be done by visual examination (see page 22 of the GFCO Certification Manual). But for rolled, flaked or cut oats, you will use antibody-based testing.

To perform antibody-based testing for large-particle-size samples, for each container being tested, use an appropriate sampling tool (trier, slot sampler, or lance). For small containers (50 lb bags or smaller), take one sample from throughout the bag; for large containers such as totes, take six representative samples per container – one near each corner of the container and two near the center. Reduce each sample to 100g using a Boerner divider or by coning and quartering, and grind them individually to the consistency of a flour. Individually test each sample (do not composite) for gluten using a GFCO approved method, or the services of an ISO 17025 accredited laboratory. Keep the remainder of each samples separate, and store them in the event that further testing is required. In the event of a confirmed positive (> 10 ppm) result from a rapid (lateral flow) test method, the remaining portion of each sample must be tested individually using a quantitative method at an ISO 17025 accredited testing laboratory. If the gluten value of any sample plus the laboratory’s measurement uncertainty estimate (or plus two standard deviations) is greater than 10.0 ppm, the entire ingredient lot cannot be used in certified Product.

We would recommend against the use of uncertified oats, and especially against the use of any oats not sold as gluten-free, as the chance of rejecting each lot will be very high.
Ingredient Risk Scores

For confidentiality reasons, GFCO can only provide copies of reviewed/risked Product & Ingredient lists back to the person who submitted the list, or on request to other persons designated by the submitter. For that reason, it is the responsibility of the person receiving the reviewed/risked P&I to ensure that information regarding product approval and ingredient risk scores is communicated to the manufacturing facilities, to ensure that they are packaging and testing correctly.

GFCO Manufacturer Listing
Last quarter, GFCO launched its public listing of approved GFCO manufacturers. This listing can be accessed from the www.gfco.org homepage by clicking on the “Manufacturer Listing button, or directly at www.gfco.org/manufacturer-listing.

Requests for help in finding manufacturers who make GFCO certified products was the number one question we answered at this year’s Natural Products Expo East convention in Philadelphia, and we were very happy to be able to direct people to our manufacturer listing, which is designed to help them find manufacturers that have successfully completed the GFCO certification process for other products. Please remember that GFCO has not “certified” these facilities, and that GFCO certification only applies to specific products made by approved manufacturers.

To help brand owners find your facility, the list is searchable by plant name, manufacturing category, city, state, and the type of manufacturing available (co-manufacturing or private label). This is all information that is gathered during the plant registration process.

This list does not connect any facility to the brands or products being currently made there. Rather, it shows facilities that are currently compliant with the GFCO Standard.

If you have not yet given your permission to have your facility appear on our public product list, you can either check the appropriate box the next time you register your plant, or you can contact gfco.clientsupport@gluten.org at any time to let us know.
Proficiency Testing 2021 and 2022
Sign-ups for the 2021 proficiency testing (PT) round ended on November 30th, and all results must be received by December 31st. No results can be accepted after that date. The final reports for the 2021 round will be sent in January.
If you missed signing up for our 2021 PT round, don’t despair, because we will begin taking sign-ups for our 2022 PT round (Wheat Gluten in Chocolate Brownie Mix) in January, and will begin shipping samples in January as well. As with this year, preliminary reports will be provided within two weeks of result submission. The preliminary report is sufficient to meet our requirements for proof of participation in a PT round at least once every four years. The final report for the round will be issued in January of the following year, which will provide you with information about the exact sample composition, the reason the sample matrix was chosen, results of all participants, and a summary of the round.

GFCO Certification Mark Updates

The GFCO global certification mark was announced in March of 2020, and all GFCO clients must change to the new mark on their packaging and advertising by March 31, 2022. 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, Israel, Mexico, and Peru. The mark can, and should, be used with the ® registration mark in these countries at your next packaging redesign. all other countries, or if you use the same packaging in these countries as well as others not listed, the mark should be used with the TM symbol.

There are still no bilingual versions of the new mark available, but you may continue to use the old bilingual mark where required by law.

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 gfco.branding@gluten.org.

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.
Marketing Update

During this season of giving, we have big news and a big ask of you!
Food insecurity affects 1 in 6 people who need to eat gluten-free. 75% are simply unable to be compliant with their diet because of the cost.
Yes, being able to afford the gluten-free diet is one of the greatest challenges our community faces today. Of course, we also recognize the expense of making safe gluten-free products is a cost burden on manufactures like you.  At GIG, we are committed to addressing the needs of our gluten-free community while also supporting the brands that have earned GFCO-certification. That is why…
The Gluten Intolerance Group (GIG) is proud to announce the formation of GIG Cares, a new nonprofit organization with grassroots efforts that will provide assistance for those with food insecurity. Through a monthly care package full of GFCO-certified gluten-free products, GIG Cares will provide food relief for individuals and families who can’t afford the diet they need. As a partner in the efforts, GIG will provide financial support to this new organization.
Will you help us feed those who are hungry with a product donation?
Only GFCO-Certified products will be included in the GIG Cares food relief efforts. At this time, we require shelf-stable products only.

Special thanks to the following brands for donating
GFCO-certified products for the December boxes:

Regulatory Manager
Laura Allred

GFCO Certification Manager
Paul Vachris
Testing Submissions

Logo Submissions

Positive Results

Gluten Intolerance Group of NA
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.