Food In Canada

Cartoon by Sam Hockstra

Gluten-free has spread like wildfire. In hot pursuit of sales, brand owners are jumping on the bandwagon and gluten-free products appear to have taken over the grocery aisles.

Through participation in Canadian Celiac Association (CCA) conferences, I have learned a great deal about the gluten problem and, as a result, am concerned about the reliability of gluten-free claims.

In conversations with food processors and brand owners who make gluten-free claims, it is clear that many do not understand the risks behind manufacturing gluten-free products in compliance with Health Canada regulations. They do not know, what they do not know. And that puts their brand and customers at risk.


The Regulations

In Canada, gluten-free foods are classified as “Foods for Special Dietary Use”. Section B.24.018. of the Food and Drug Regulations states: “It is prohibited to label, package, sell or advertise a food in a manner likely to create an impression that it is a gluten-free food if the food contains any gluten protein or modified gluten protein, including any gluten protein fraction, referred to in the definition “gluten”… ”

They go on to define “gluten” as:

“(a) any gluten protein from the grain of any of the following cereals or the grain of a hybridized strain created from at least one of the following cereals: barley,
 rye, triticale, or 
wheat, kamut or spelt; or

(b) any modified gluten protein, including any gluten protein fraction, that is derived from the grain of any of the cereals referred to in subparagraphs [above] or the grain of a hybridized strain referred to in paragraph (a).”

Note that oats are included in the definition. I still see brands at trade shows advertising products with oats as “gluten-free”. Even when made with “pure uncontaminated oats”, Canada does not permit a gluten-free claim.

Unfortunately, Health Canada’s rules do not specify the threshold for gluten. For that, we must look to the CFIA (Canadian Food Inspection Agency) who is responsible for enforcement. When making a gluten-free claim on a product, its gluten content must be LESS THAN 20 ppm (parts per million). To help you visualize how minute this is, consider the following example: a typical flat screen TV has 2 million pixels; 20 ppm is equivalent to only 40 pixels. That’s a scary thought for anyone with celiac disease.


The Watch-Out

Contrary to popular belief, just because a food does not inherently contain gluten, like rice for example, does not mean it is gluten-free.


The Culprits

#1. Cross-contamination can come from anywhere in the supply chain, from the field to the fork.

Major risk areas include raw ingredients, manufacturing facilities, packaging, transportation and storage. Take a look at our grain handling system. Wheat and other grains are stored in the same elevators and transported in the same trucks, unless they are handled by grain companies certified under the Canadian Identity Preserved Recognition System (CIPRS).

#2.  Common ingredients used in food processing, such as additives, seasonings and sauces, can be hidden sources of gluten. Even packaging materials and adhesives may contain gluten.


What are the risks?

  • Subjecting your customers to illness.
  • Your product could be the cause of a costly recall that will spread through the supply chain. CFIA tests products labelled as “gluten-free”. Those with 20 or more ppm of gluten could be recalled. That means paying the costs of withdrawing the product from the market, designing and printing new labels, re-labelling, re-distribution, reimbursing retailers, paying penalties and losing sales in the meantime. Is it worth the risk?
  • Negative publicity that will damage the brand’s reputation, erode customer trust and ultimately result in lost sales.


How can “less than 20 ppm” be detected?

There are a number of scientific tests to detect the presence of gluten. But, according to medical doctors speaking at the CCA conference, these tests are not 100% reliable.

Photomontage by Birgit Blain

How do consumers know what brands to trust?

There is a plethora of “gluten-free” symbols in the market. Many are self-declarations; in other words, the brand owner created the “certification mark”. Some “gluten-free certifications” are based entirely on end product testing. However, that’s not good enough. CFIA states “manufacturers and importers should have good manufacturing/importing practices (GMP/GIP) in place to achieve the lowest levels of gluten possible to avoid cross-contamination.”


The Solution

Making a gluten-free claim can be a minefield in the absence of preventive control measures. The solution is a HACCP-based gluten-free management system for food processing facilities. That’s the principle behind the Canadian Celiac Association’s Gluten-Free Certification Program (GFCP), which is based on Canadian regulations. To ensure compliance with GFCP requirements, annual audits from independent third party auditors are required.


Building Trust in Your Brand

The Gluten-Free Certification Program is an investment that goes beyond protecting your brand. Products prominently displaying the GFCP mark stand out on shelf, are differentiated from competitors and build trust in your brand.



Check out these links to learn more about Canadian regulations and the Gluten-Free Certification Program.


Birgit Blain is president of Birgit Blain & Associates Inc., food business specialists, helping brand owners break down barriers and position their brands for growth. Her experience includes 17 years in the grocery trade with Loblaw Companies and President’s Choice. Her extensive knowledge base spans product management, account management and food retailing. Contact her at

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