Gluten labeling under review: GFCO on FDA’s Request for Information

On January 21, 2026, the Food and Drug Administration announced it was taking steps to increase transparency surrounding food labels and gluten through a Request for Information (RFI). The RFI aims to collect information on adverse reactions from non-wheat gluten-containing grains (GCGs) including rye, barley, and oats that are in contact with GCGs. The FDA is gathering information on products that do not disclose rye or barley contents, allergic reactions to rye and barley, and concerns surrounding the gluten content of cross-contaminated oats.

Laura Allred, PhD, regulatory manager at the Gluten-Free Certification Organization (GFCO), shares insights into the FDA’s move, commenting on the data and information needed to fill regulatory gaps.

Transcript

Erin McEvoy: So to start us off, the FDA recent RFI suggests a need to modernize gluten labeling in packaged foods. From your perspective at GFCO, what are some of the most significant gaps in the current FDA regulations that you feel this RFI is likely trying to address?

Laura Allred: Yeah, so the main things they're trying to cover in this RFI, looks like, from our reading of it, is labeling of rye and barley and then oat safety, both of which have been super long standing concerns for the gluten-free community, and we're very much on board with adding rye and barley to mandatory labeling requirements. I think that's a great idea. We'll just have to see what they're looking to do with the oat information. For right now, it just looks like a lot of information gathering.

McEvoy: So that kind of goes right into my next question. So how does GFCO intend to participate in the RFI process? What specific data points do you think are most critical for them to consider, or what do they most need to look at?

Allred: Yeah, I mean, again, from our reading of the RFI, it looks like they're actually looking for a lot of clinical data. Actual reactions people have had to rye and barley that they can show have been to rye and barley, both things that are IgE-mediated, so, celiac reactions, allergic reactions, both. And then on the oat side, they're looking for data about levels of commingling of gluten grains with oats, seems to be the main things that they're asking for.

For our part, because we don't work in the medical realm, and we're not oat processors, really, but we've done we've done it studies with oats, and we can certainly share that data. But really for us, we're going to participate by advocacy. It's a big part, our parent organization is the Gluten Intolerance Group we've got on here, so they've been a consumer support organization for over 50 years. We do a lot of advocacy work, and we actually did, along with all the other large celiac groups, work with Center for Science in the Public Interest back in 2023 to try to get rye and barley labeling added to the Food Labeling Modernization Act. That Act has not passed. It's still out there, but we're glad to see them bring this topic up again. But in terms of gathering information, a lot of the stuff they're asking for about rye and barley seems like would come from medical literature, researchers, things like that. And then the oat data, you're going to get a lot of that from oat processors, hopefully. The trick is looking at commingling, and oats changes from truckload to truckload, so it's hard to get a consistent estimate, I guess, but yeah, hopefully they can get some good information. And like I said, we've done some work. We've published on doing grain counts, looking at levels of gluten containing grains, proper sampling plans for that. We can certainly share that data, but I think our primary role is going to be advocacy.

McEvoy: Were you surprised at what they were asking for? Were you surprised that they were mostly asking for clinical data, or that this RFI came about at all?

Allred: I guess I'm not surprised that the RFI came about, because, like I said, the community has been asking for some of this stuff for a while. It's interesting that it's a public call for information when a lot of it seems like stuff that might come from the research community or the medical literature, things like that, you'll certainly get a lot of anecdotal information from the public, and you can get a lot of good information from that. You can find out a lot of interesting trends from that. So, not opposed that it went out as a call for public comment. But I would believe there's also some behind the scenes research being done at FDA to pull some of their – because they have a lot of data themselves, and they've done a lot of data consolidation over the years looking at those.