33. The Committee considered the Proposed Draft section by section and made the following amendments.
34. Some delegations and the Observer from AOECS, as well as some written comments, supported the definition covering all gluten free foods. Other delegations stressed that the standard should apply exclusively to cereal-based foods and that it was not necessary to include products which were gluten-free by nature.
35. The Committee decided to specify that all Triticum species were covered, mentioning specifically Triticum polonicum (kamut), spelt and durum wheat as examples. The Committee did not accept a proposal to delete oats from the list of gluten containing species, as no conclusive evidence from longterm studies and reliable medical data existed at this stage, and the reference to oats was put in square brackets for further comments.
36. Some delegations proposed that gluten free foods should contain no detectable gluten, while others pointed out that there were varying degrees of intolerance and that celiacs did ingest very low amounts of gluten in their diets. The Observer from AOECS expressed the view that the level of 200 ppm of gluten on a dry matter basis for all gluten-free foods was too high to protect coeliacs and that the gluten level should refer to the end-product for better consumer information.
37. After an extensive discussion, the Committee agreed to define three groups according to their gluten content in the end product, with all figures in square brackets for further comments:
- naturally gluten free foods (20 ppm of gluten),38. The Committee recognized the difficulty of defining and enforcing any limits in the absence of reliable validated methods for the quantification of gluten, although qualitative detection at low levels was possible, and noted that specific methods were used in practice, especially the AOAC immuno assay method and qualitative tests with limits of detection between 5 and 30 ppm.
- products which had been rendered "gluten free" (200 ppm)
- any mixture of the two ingredients (200 ppm).
39. The Committee agreed to transfer the definition of "gluten free" in 2.2.2 to section 3.1 as it belonged more adequately in the provisions on Composition and should not be repeated.
40. The Committee noted a proposal for distinct claims for "gluten free" and "low or reduced in gluten", as it would reflect more accurately the current definitions. The Committee deleted section 5.2 (gluten-free by nature) as it was covered by the amended definition in section 2.
Status of the Proposed Draft Revised Standard for Gluten Free Foods
41. The Committee agreed to advance the Proposed Draft Standard to Step 5 of the Procedure for adoption by the 22nd Session of the Commission (see Appendix V).