BA Urges FDA to Maintain Current Gluten Labeling Framework

Earlier this month, the Brewers Association (BA) submitted comments to the U.S. Food and Drug Administration (FDA) in response to the agency's request for information on labeling and preventing cross-contact of gluten in packaged food. The BA urged the agency not to expand existing gluten disclosure requirements and emphasized that the current federal framework already provides clarity for both consumers and industry.

Any new gluten-related requirements should be clearly grounded in federal law and should not blur the distinction between food allergen labeling and the existing federal rules for "gluten-free" claims. Since celiac disease is an autoimmune condition and not a food allergy, that distinction is important when FDA considers whether additional labeling requirements are appropriate.

The FDA should maintain its long-standing 20 parts per million (ppm) gluten threshold for foods labeled "gluten-free", noting that the industry has substantial investments in reliance on that standard. Changing it without compelling scientific evidence would create avoidable regulatory and operational disruption.

For alcohol beverages, additional FDA action is unnecessary because the Alcohol and Tobacco Tax and Trade Bureau (TTB) already has a separate framework governing gluten content statements. Additionally, TTB is considering allergen labeling through its ongoing rulemaking process and new FDA action could duplicate or interfere with that work.

Any additional federal action risks creating overlap, confusion, and unnecessary burden rather than a meaningful public-health benefit.

Read the Brewers Association's full comments here.