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The Mystical World of Gluten Free Labeling – is it Lying?

November 28, 2025

Odds are, as a consumer you’ve likely glanced at a food label in your lifetime. Though, for some, more than a quick glimpse is necessary, as the intricate details can be the difference between health or illness. This really applies to any allergy, as ingredients and wording can easily veil allergens. Specifically, this can be a regular practice for those avoiding gluten, as just a microscopic amount can have macroscopic repercussions. 

 

What is gluten?

Gluten is a protein found in wheat, primarily present as gliadin and glutenin. Synonymous proteins are present in rye as secalin, barley as hordein, and oats as avenins (Biesiekierski, 2017). Gluten is used as an umbrella term to describe each of the proteins, as each behave and interact in similar ways. Most commonly found in breads, pastas, and other dough based products, gluten acts as a binding agent. This means its presence impacts texture, elasticity, and even taste (Biesiekierski, 2017). These factors cause gluten to be found in less obvious products like seasonings, dressing, and even the remoistenable seal of an envelope. 

 

To be or to not be free of gluten

With the possibility of gluten being present in so many different forms, tracking its presence is crucial for those trying to avoid it. As declared by the Food and Drug Administration, for something to be labeled gluten free it must meet specific criteria to be considered not misbranded. The official ruling defines ‘gluten free’ as an item that doesn’t have a gluten containing grain, is not derived from a gluten containing grain, and an item with less than 20 parts per million of gluten (ppm) (Food and Drug Administration, 2013). The parts per million decree is pertinent when a gluten containing grain has been specifically adapted to contain not gluten. It essentially means that for every 1,000,000 grams of a substance, less than 20 of them are able to actually contain gluten. This microscopic amount pales in comparison to a single bread crumb or speck of flour, causing issue to another form of gluten possession, cross contamination. 

 

Items naturally free of gluten such as meat or rice cannot confidently be deemed gluten free due to cross contamination. Cross contamination occurs when one substance is unknowingly transferred to another, in this case that substance is gluten. Transfer of gluten from a containing substance to supposedly gluten free product can happen at any point in the development process of a product (Damasceno et al., 2024). A single speck of wheat flour would be enough to contaminate a gluten free product. This means shared equipment, such as a conveyor belt holding glutenous food being used on a gluten free product could easily result in the surpassing of the 20 ppm maximum.

 

External Certifications

Beyond just an FDA approved gluten free marking on a product, there are many different types of certifications that may each follow their own thresholds for what is considered gluten free. Globally, these 3rd party certification processes vary in their guidelines to be included, with different organizations such as Beyond Celiac’s ‘Gluten-Free Certification Program’, Gluten Intolerance Group’s ‘Certified Gluten Free’ Stamp, or National Celiac Association’s gluten free certification. Each of these listings require different ppm of gluten, with one even having a maximum of 5 ppm, which is significantly lower than the FDA regulation (Dennis, 2018). The certifications can provide more comfort to consumers avoiding gluten, as they require more extensive testing of the products to confirm their gluten ppm. While the FDA decree sets limits for a company to legally consider its product gluten free, it does not necessarily require the manufacturer to test the product to confirm that (Thompson & Simpson, 2014). 

 

How to Read a Label – A Guide from First Hand Experience

As someone with Celiac Disease, with its only treatment being a strict gluten free diet, over the past 9 years of my diagnosis I’ve learned a few tricks along the way. Most notably, I would say being a conscious consumer has been the most impactful thing for my safety when selecting food items. If a product does not have a specific certification, meaning it is  just generally labeled gluten free or has no label at all, my first step is to read the ingredients. In my experience, there are a few specific keywords to look out for. In the process of scanning an ingredient list, if I notice words like wheat, barley, malt, or rye, off the bat the product can be considered not gluten free. Additionally, gluten can be hidden in certain ingredients like corn syrups, oats, yeasts, and some seasonings. These items aren’t inherently glutenous, but particular processes may make them unsafe. 

 

In some cases, a search online is beneficial for me as well. Frequently, even though a label does not guarantee an item to be gluten free, the company will disclose on their website that their products are free of gluten. Oftentimes, the company will not officially disclose anything due to concern for cross contamination. The actual extent to which this is possible though varies by company. This is where the list at the bottom of a product saying ‘may contain wheat’ is notable. For some, ‘may contain’ could mean direct use of shared equipment, but for others it’s a disclaimer that the factory also makes gluten items. Research or contact with the company is sometimes the best option as it clarifies this uncertainty, and allows for a decision by the consumer depending on the extent of the allergy/sensitivity. Lastly, an item cannot just be deemed gluten free if it lacks a note saying it ‘contains wheat’, as that does not ensure it does not contain barley or rye, which are also gluten containing grains. 

 

References

Biesiekierski, J. R. (2017, February 28). What is gluten? – biesiekierski – 2017 – Journal of Gastroenterology … Wiley Online Library. http://onlinelibrary.wiley.com/doi/10.1111/jgh.13703/full

Damasceno, R. P. B., Zandonadi, R. P., Mendes, M., Cunha Junior, L. C., Raposo, A., Teixeira-Lemos, E., Chaves, C., & Farage, P. (2024, April 18). Risk of gluten cross-contamination due to food handling practices: A mini-review. MDPI. https://www.mdpi.com/2072-6643/16/8/1198

Dennis, M. (2018). Third Party certification of Gluten Free Foods. BIDMC of Boston. https://www.bidmc.org/centers-and-departments/digestive-disease-center/services-and-programs/celiac-center/celiacnow/nutrition-and-the-gluten-free-diet/label-reading/third-party-certification-of-gluten-free-foods

Food and Drug Administration. (2013, August 5). Food Labeling; Gluten-Free Labeling of Foods. Federal Register – National Archives. https://www.federalregister.gov/documents/2013/08/05/2013-18813/food-labeling-gluten-free-labeling-of-foods

Thompson, T., & Simpson, S. (2014, October 1). A comparison of gluten levels in labeled gluten-free and certified gluten-free foods sold in the United States. Nature News. https://www.nature.com/articles/ejcn2014211 

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About Author

Chloe is an undergraduate 2nd year Psychology major and Industrial Design minor. She has a particular interesting in human-factors design, engineering psychology, and behavioral analysis. In her free time, Chloe loves listening to punk and alternative rock, reading and watching any form of media, and baking.

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  Timothy Durham was convicted of rape when a test showed his DNA genotype matched the DNA recovered from the crime scene. Eye witnesses testified that Durham was in a different state at the time of the incident, but he wasn’t exonerated from his 3000 year sentence until follow up DNA analysis showed that the preliminary forensic analysis used in the trial was misinterpreted (Thomas et al.). DNA testing serves an invaluable part in our criminal justice system, but it comes with complications and bias that can lead to wrongful convictions and misinformed juries.  

Background:

Forensic genetics aims to identify the origin of a biological sample. It can be traced back to Karl Landsteiner who discovered human ABO blood groups. With blood groups, suspects could be eliminated based on their blood type. For example, if a suspect had type A blood and there was type B blood left at the scene by the perpetrator, the investigators could rule out the suspect. Unfortunately, the reverse didn’t work. If the suspect and perpetrator both had the same blood type, it can’t be concluded that the suspect was guilty. Blood identifiers evolved into 8 distinct categories which improved the ability to eliminate suspects, but could only conclude that (if the system matched) it might be the perpetrator or this person might be related to the perpetrator (Jobling and Gill). The field evolved in the 1980s with the discovery of Minisatellites, lines of repetitive DNA that don’t encode proteins. Minisatellite patterns in DNA create what we know today as the DNA fingerprint, and it has a much higher accuracy rate than previous methods (Augustyn et al.). Around the same time, a breakthrough for victims of sexual assault was discovered. In the case of assault, bodily fluids of both the victim and the assaulter can get mixed. A process called differential lysis was created which could selectively increase the concentration of sperm in a fluid sample thereby allowing for accurate DNA testing (Jobling and Gill). Forensics evolved to use single-locus probe testing after several years because of its ease of interpretation. It looked at specific minisatellites that had high variability between subjects. This was the first DNA-based method to be used in a criminal investigation. Two murder homicides from several years apart were connected using DNA evidence. The evidence was then used to exonerate an innocent man, and the guilty party was found when he tried to evade mandatory DNA testing for all men in the small town. His guilt was then reinforced when the DNA profiles matched, and he gave a confession (Jobling and Gill). Finding DNA at a crime scene doesn’t guarantee that you’ll find a murderer. There are issues with non-pure samples and limited samples that make DNA work difficult, and accreditation of facilities and new techniques and take time (Jobling and Gill).  

Subjectivity of DNA Interpretation:

In a 2009 publication, the National Academy of Science discusses the possibility for subjective influence in lab based forensics. The interpretation bias happens in complex cases where, for example, there could be a mixture of DNA. A study published in 2011 looked specifically at this issue. A gang rape happened in Georgia, and the mixture in DNA from the case was used to prosecute one suspect after another suspect took a plea bargain to testify against him. With DNA mixtures, there are three possible conclusions: suspect excluded, suspect cannot be excluded, and inconclusive. If the suspect is excluded, it means that there’s little to no possibility that his DNA is part of the sample. If the suspect cannot be excluded, it means that there’s a possibility that his DNA is part of the sample. In the trial, the DNA examiners who knew the context of the case concluded that the suspect being prosecuted could not be excluded. The 2011 study gave the DNA evidence from this case and the DNA profiles of the suspects to 17 forensic examiners. These examiners had no context of the case, and they all worked independently. Of the 17, only 1 came to the same conclusion (suspect cannot be excluded) as the examiners who knew the context of the case. Twelve of the 17 concluded that the suspect who was prosecuted and convicted had no relation to the DNA found in the sample. Not only does this show that subjectivity occurs due to the context of the case, but the 17 examiners came up with different findings based on their past experiences meaning that not all DNA analysis is objective. Some organizations like the Scientific Working Group on DNA Analysis Methods say that quantitative statistical evidence should be presented with every categorical conclusion, but the US doesn’t require this (Dror and Hampikian).

False Positives:

There are two categories that cause wrongful identification in a DNA report: coincidental matches and false positives. Coincidental matches are DNA matches between two unrelated people. The probability of these matches is about 1 to 500,000 for white individuals and about 1 to 350,000 for black individuals. This small probability of coincidental matches makes people feel confident in DNA evidence. False positives, on the other hand, are matches between DNA and test DNA that result from issues in the forensics lab. There have been multiple cases of forensics labs accidentally switching victim and suspected rapist DNA which lead to convictions that were later overturned when the lab realized the error. There are also cases of misreading or misunderstanding a sample. In a case from 1993, a man was convicted of rape because someone interpreted a mixed sample of victim and perpetrator DNA as an individual sample. The conviction was again overturned. To prevent false convictions, retesting DNA is allowed, but it’s not an efficient solution. Many people are pushing for statistical information on the probability of false positives, so that the jurors can make accurate judgements based on DNA evidence (Thomas et al.).  

Conclusion:

DNA analysis is a useful tool for the criminal justice system, but subjectivity can be an issue in forensic testing. To combat wrongful convictions, there are organizations like The Innocence Project who use DNA testing to free the innocent, but reformed forensic testing standards should be put in place to prevent subjectivity and to ensure juries are correctly informed during trials. https://www.innocenceproject.org/    

Citation:

Augustyn , Adam, et al. “DNA Finerprinting.” Encyclopedia Britannica , 26 Apr. 2018, www.britannica.com/science/DNA-fingerprinting#ref153186. Dror, Itiel E., and Greg Hampikian. “Subjectivity and Bias in Forensic DNA Mixture Interpretation.” Science & Justice, vol. 51, no. 4, 2011, pp. 204–208., doi:10.1016/j.scijus.2011.08.004. Jobling, Mark A., and Peter Gill. “Encoded Evidence: DNA in Forensic Analysis.” Nature Reviews: Genetics, vol. 5, no. 10, Oct. 2004, pp. 739–751., doi:10.1038/nrg1455. Thompson, William C, et al. “How the Probability of a False Positive Affects the Value of DNA Evidence.” Journal of Forensic Sciences, vol. 48, no. 1, Jan. 2003, pp. 1–8., doi:10.1520/jfs2001171.