Oats are delicious – oats are nutritious – they contain high levels of vitamins, minerals and antioxidants and are an excellent source of fibre – they do not contain the protein gliadin, the gluten fraction that coeliacs need to avoid – they add texture to gluten free baking and are easy to cook with. Few Scots would be without them. So what is the issue? Sadly, there are two.
Avenin versus gliadin and wheat contamination
Although oats do not contain gliadin they do contain avenin, a protein very similar to gliadin. While the majority of coeliacs do not appear to react to avenin, a small minority do. A rather larger minority are concerned that although they have no obvious and immediate reactions to eating oats, there could be some low level damage to their gut and therefore they prefer to avoid them.
The concern for coeliacs who are happy to eat oats is that oats are often grown, and even more often milled, very close to or in the same facilities as wheat. Given the size of the grains it is impossible, if this is the case, to achieve the kind of separation that would avoid the oats being contaminated with at least low levels of wheat. Levels that would be quite high enough to exceed the 20 parts per million level allowed in gluten-free products, and that would certainly be high enough to spark a reaction in even a moderately sensitive coeliac.
However, given how valuable an addition oats are to a gluten free diet, there has been significant investment over the last 20 years in creating sources of gluten-free oats, grown and milled far away from wheat and therefore contamination free. These are labelled and flagged on products as ‘gluten free oats’. And this gives rise to issue number two – labelling.
The labelling regulations
The Food Information for Consumers (FIC) regulations which came into force in 2011 provided very welcome clarification for the food industry and the allergic consumer on the labelling of allergens in pre-packed foods. It set a list of 14 ‘major’ allergens – the 14 foods or groups of foods that are the most likely to cause a serious allergic reaction and that therefore need to be clearly highlighted on pack. The first of these is ‘Cereals containing gluten, namely: wheat (such as spelt and khorasan wheat), rye, barley, oats or their hybridised strains’.
The problem is that the regulators, for totally understandable reasons, were trying to cover two conditions – food allergy and coeliac disease – in the one regulation. But the two conditions are neither the same nor are they compatible.
Wheat, oats, rye and barley are not ‘major’ allergens – eg a large number of people in Europe do not suffer immune mediated reactions to any of them. There are a small number of people who do – but there are a small number of people who suffer IgE mediated reactions to almost every/any food in existence.
However, wheat, barley and rye do contain gliadin, crucial information as far as a coeliac is concerned. Oats contain avenin, possibly relevant for some coeliacs. That is something entirely different. Still absolutely to be highlighted – but not as an allergen. But, as far as labelling regulations are concerned, an allergen they are – even though the gluten that is highlighted does not trigger an allergic reaction, although it can make gluten sensitives very ill. Add to that the issue that not all oats will be gluten (gliadin) free, but some will, and you end up with a very confusing label.
To be legal a product which includes oats which have been certified to have under 20 ppm of gluten and are therefore ‘gluten free’ will still need its labelling to highlight (bold) the oats as an allergen while specifying that they are ‘gluten-free’. eg – ‘gluten free oats‘
So who is confused?
As Alex G (with whom I have argued this issue many times) points out ‘in terms of ‘confusion’, I don’t think the coeliac consumer really suffers – and this issue is mostly about them. For those who don’t need to avoid GF oats, bolding/not bolding is a non-issue; those who do need to avoid them (and we’re talking, what … 5% of coeliacs so 0.05% of the population) know that they are sometimes emphasised, sometimes not emphasised. They may be confused by this, but from my experience of speaking to them online, they know that that is the situation, and take care to stay on their guard when label reading to read every word anyway.’
However, the issue does cause considerable grief to ‘freefrom’ manufacturers wanting to provide accurate and complete information to potential purchasers but also wanting to promote their products as allergen free.
If they use gluten free oats in an otherwise allergen-free product they are not able to promote it as ‘major/top 14 allergen free’ as the regulations say that they have to highlight the oats as an allergen – even though oats are not a major allergen and their oats do not contain gluten! Or else they have to ignore the regulations and risk being called out and possibly even having to recall a product which threatens no one.
Happy, if distanced, Christmas!