Approaching Gluten Free Label Reading from an Expert’s Perspective
Dr. Kim Faulkner-Hogg breaks down the essentials of reading ingredient lists for gluten free consumers
Reading food labels can feel overwhelming when you have coeliac disease. With hidden ingredients, confusing ‘may contain’ statements, and changing food labelling laws, it’s hard to know what’s truly safe.
Even when you’re strictly gluten free, you might still experience symptoms that feel like you’ve been glutened, but could something else be going on?
Dr. Kim Faulkner Hogg appeared on Episode 164 of A Gluten Free Podcast to discuss this very topic. The doctor operates as an experienced dietitian specialising in coeliac disease and food intolerances.
With years of research in gluten ingestion, nutrient deficiencies, and the science behind gluten free food labelling, Dr. Faulkner-Hogg brings clarity to the challenges many of us face on a daily basis. Dr. Faulkner Hogg is now Senior Dietitian and Health Advocacy Officer at Coeliac Australia.
If you've ever struggled with label reading, this is an opportunity to learn more and protect yourself.
Education Matters with Gluten Free Label Reading
Many of us have been forced into a ‘sink or swim’ position when it comes to safe label reading. Without the guidance of others in the gluten free and coeliac space, you’re left in the supermarket aisle alone. From Dr. Faulkner-Hogg’s point of view, she’s coaching dietitians how to educate their clientele about the basics of label reading from the outset.
“I like (people) to be taught by somebody,” she told the podcast. “When I give student lectures, I teach dietitians how to read a food label for gluten. It's really important you take people through how to read a food label so they understand what they're looking for. A lot of people do (identify) wheat, but there's an equal number who don't (recognise) rye, barley, and oats.”
These four components will act as the focus for the dietitian, shaping which brands are safe while demonstrating what should be deemed off limits.
Starting with the B.R.O.W Principle
As confusing as this whole process is for gluten free consumers, especially at the beginning, there is one simple rule Dr. Faulkner-Hogg applies. By remembering a single acronym, you recognise which ingredients carry the gluten risk.
“If people think about their BROW,” the dietitian explains, “B for barley, R for rye, O for oats, and W is for wheat. They're the four grains that need to be declared for gluten.”
The doctor clarified a number of facts during the episode which highlight a level of industry inconsistencies. For instance, some ingredients are so refined, they contain no detectable gluten and indeed are suitable for coeliacs, but won’t appear so at first glance.
Oats remain a controversial ingredient in Australia for coeliacs, something we covered in more depth in 2024.
New Label Regulations Under PEAL
For all the advice that was forthcoming from the dietitian, it would be the allergen statement which came into sharper focus during the discussion. Under the Plain English Allergen Labelling (PEAL) regulations introduced in 2021, this particular statement is where you achieve clarity across the board.
“Even though gluten is not technically an allergen, it's recognised that people with coeliac disease need to know about this,” said the doctor. “It's been put onto the allergy statement. So if the food at the end product contains gluten, the contains statement has to tell you it's there.
“What we're trying to teach people with this new incoming PEAL labelling, is if gluten is not declared in the allergen statement, then it's not present in the product.”
This is great news. Not only will the B.R.O.W principle still apply, but you can scan the allergen statement to see in clear detail whether or not any gluten is present through that declaration.
Red Flagging Old Labels Prior to 2024
Take note of ingredient list dates before determining gluten free safety
PEAL would begin their regulations in 2021, but they would not officially be put into practice until February of 2024. In short? Any new product manufactured from this date on supermarket shelves will have the updated labelling included.
With this being said, there remains a note of caution for those items still stocked before the new provisions were implemented. The doctor warned consumers to be wary of brands that may have been labelled prior to the latest rollout.
“I don't teach people just how to read a new label,” she said. “I'm also telling them how to read an old label so they understand what is on the label and understand the gluten free foods… We still have some old products on the shelf, I've noticed one or two where that level of detail has not yet made the label.”
It may only be an issue for the short-term in 2025, but it can be the difference between suffering from cross-contamination or being safe.
“I'm still encouraging everybody,” the doctor advised, “have a look to see what the ingredients are. You need to understand (if it) doesn't have any detectable gluten in it… If a product was packaged in December 2023, it can still have a two-year shelf life.”
Clarifying the May Contain vs. Allergen Statements
It’s beneficial to separate two categories of labels at this juncture: the allergen statement, and the ‘may contain’ statement. In terms of the latter, there is very little oversight about how this is actually regulated, creating further headache for coeliacs.
“The ‘may contain’ statement is not governed by PEAL at all,” Dr. Faulkner-Hogg remarked. “PEAL has no input on what words need to be used in that. I know that has confused people who understood wheat and gluten are going to be in the allergen statement.”
Put simply, different rules apply for the allergen and the ‘may contain’ statement. The first offers a clear and direct edict, while the second is left ambiguous.
“(Customers have) understood if there's an absence of using the word gluten in the allergen statement, it means there's no gluten as an ingredient,” the doctor outlined. “That wording (is) for PEAL, but for the ‘may contain’ statement, there is no legislation.”
Former Coeliac Australia Health Advocacy Officer, Penny Dellsperger delved into the ‘may contain’ statement with us before, helping to shed light on what this information really means for gluten free shoppers.
Understanding Risks Without the “Gluten Free” Label
For context, it’s important to underline how little regulation is applied to manufacturers and sellers across the Australian market. Unlike other parts of the world where strict label laws apply, coeliacs are left exposed in an industry that leaves much of the decision-making up to the companies as far as gluten detection is concerned.
“In (almost) any product that's not officially labelled gluten free, it's up to the company or the business to put it on there,” Dr. Faulkner-Hogg detailed. “It's not mandatory for those businesses to do it… The ‘may contain’ statement is voluntary.”
Another note of caution for the dietitian is located within the factory environment itself. While the ‘may contain’ statement might indicate one thing, any traces of wheat within a factory should be a moment to pause before making the purchase.
“If they say it's made in a factory that contains wheat, then in a ‘may contain’ statement, that also means gluten is possibly there,” explained the doctor. “Just because they haven't put the word ‘may contain wheat and gluten’ in that statement, gluten could (still) be there. You need to be aware of it.”
Making the Personal Choice
How would Dr. Faulkner-Hogg summarise the main takeaways when it comes to tracking gluten on labels? From her experience, there is no one-size-fits-all approach. For those diagnosed as coeliac, they must be aware of the finer packaging details. For others, it’s really up to interpretation and preference.
“Some will react at the tiniest amount,” the doctor observed. “(Others) can eat a bowl of pasta and (not experience any) symptoms. About 20 percent of people with coeliac disease don't get symptoms… It comes back to each person.”
As an experienced dietitian who sees coeliac disease and gluten intolerance up close, it’s important to reflect on your personal status as a consumer. Dr. Faulkner-Hogg reiterated that asymptomatic coeliacs still suffer critical villi damage, but judging appropriate levels of risk is ultimately a subjective exercise.
“I don't tell clients to just outright avoid (gluten),” she explained to Ben. “I always say, this comes back to you. This is (your) personal decision. Some are 100% risk averse and will never do something. Others tell me I can eat (gluten). I get the full range.”
You can listen to the entire episode with Dr. Kim Faulkner-Hogg on Episode 164 of A Gluten Free Podcast right here.
They cover the doctor’s journey in dietetics, her research on small gluten ingestion, how gluten free food standards changed in the 1990s, what PEAL means for declarations, highly processed food risks, key nutrients at risk on a gluten-free diet, how to get enough calcium and fibre, gluten symptoms and more.
You can connect directly with Dr. Faulkner-Hogg here: https://glutenfreenutrition.com.au/
Dr. Faulkner Hogg is now Senior Dietitian and Health Advocacy Officer at Coeliac Australia.
