In August 2020, the federal Food & Drug Administration (FDA)
finalized the definition and labeling requirements of gluten-free
fermented and hydrolyzed foods (including beer and other alcoholic
beverages). The ruling provides a clear delineation between
products that are truly gluten-free and products that are not and
how product labels communicate those differences to consumers.  In
the case of beer, the distinction is between naturally gluten-free
beers and barley-based beers processed in an attempt to reduce the

On September 23rd the world’s dedicated gluten-free breweries
gathered for a 2nd annual conference, held virtually this year due
to COVID-19. Holidaily Brewing Company in Golden, Colorado hosted
brewery owners, brewers and staff to share ideas and discuss
technical brewing techniques specific to gluten-free brewing. A
portion of the conference was dedicated to discussion of the FDA
ruling, how it should be interpreted and what consumer risks still

Traditionally, beer is brewed utilizing four main ingredients
– grain, water, yeast and hops. While water and hops are
gluten-free and yeast can be created and/or propagated gluten-free
with general ease, the grain can be a challenge for brewers who aim
to brew a truly gluten-free beer. The most common grains found in
beer are barley and wheat, both of which contain gluten.

In an attempt to find an easy way to provide a safe product for
celiac or gluten-sensitive consumers, breweries have tried
“reducing†or “removing†gluten from traditional beers.  In
this case, brewers produce beer with gluten-containing ingredients
(barley and/or wheat, etc.) and treat the liquid to “removeâ€
gluten with an enzyme. The product must test at 20 ppm of gluten or
lower before packaging and even so, labels cannot reflect
“gluten-free.†The Alcohol and Tobacco Tax and Trade Bureau
(TTB) created a puzzling labeling option for these beers, calling
them gluten-removed.

Why did the TTB not allow these beers to be labeled as

Further research was needed due to two concerns – consumer
complaints and, well…science. Thirsty, gluten-free beer drinkers
trying these “gluten reduced†beers with the promise that they
were testing below 20 ppm were having negative gluten

According to a February 2018 study published in The American
Journal of Clinical Nutrition,

“The average inadvertent exposure to gluten by CD individuals
on a GFD was estimated to be ∼150–400 (mean) and ∼100–150
(median) mg/d using the stool test and ∼300–400 (mean) and
∼150 (median) mg/d using the urine test. The analyses of the
latiglutenase data for CD individuals with moderate to severe
symptoms indicate that patients ingested significantly >200 mg/d
of gluten.†(Syage, Kelly, Dickason, Ramirez, Leon, Dominguez,
Sealey-Voyksner (2018) Determination of gluten consumption in
celiac disease patients on a gluten-free diet.  The American
Journal of Clinical Nutrition, Vol. 107, Issue 2, February 2018,
Pages 201-207)

The study concludes, “these surrogate biomarkers of gluten
ingestion indicate that many individuals following a GFD regularly
consume sufficient gluten to trigger symptoms and perpetuate
intestinal histologic damage.†(Syage et. Al., 2018). The study
was provided to the Gluten-Free Brewer’s Group by Tricia
Thompson, MS, RD, of

Additionally, there are entire groups and pages on social media
with people from all over the world asking why they are getting
sick from gluten-removed beers. One particular group on Facebook is
actually called “We Got Sick Drinking Gluten-Reduced Beersâ€.
These are the consumers who, when the FDA opened up a call for
comments by interested members of the public regarding labeling
beer, responded. The cry by consumers was heard.

Michelle Colgrave, Professor of Food & Agriculture at Csiro
& Cowan University in Australia conducted a study on fragments
of gluten left behind after utilizing the enzyme. Testing with
liquid chromatography-mass spectrometry, Colgrave found that
hydrolyzed gluten was left behind after the enzyme was added.
(Colgrave et al (2017) Liquid chromatography-mass spectrometry
analysis reveals hydrolyzed gluten in beers crafted to remove
gluten. J. Agric. & Food Chem. 65, 9715)

In other words, when beer is created with gluten containing
grains and treated with an enzyme, the gluten protein that was once
one large protein is now broken into smaller fragments. What
consumers were reporting and studies are now showing is that while
the gluten tests available may report the beer is less than 20 ppm,
the components left in the liquid continue to make sensitive
consumers sick. (Akeroyd et al (2017) Journal of American Society
of Brewing Chemists, 74, 91; Allred et al, 2017, Journal of AOAC
International, 100, 485) “To utilize the word ‘removed’ is
actually quite deceiving. The gluten is still in the beer, it’s
just in smaller pieces than before,†says Laura Ukowich, VP of
Operations at Holidaily Brewing in Golden, Colorado. “This is why
sensitive consumers are still getting sick.†The testing that
occurs now has room for improvement. The FDA claims “we know of
no scientifically valid analytical method effective in detection
and quantifying with precision to the protein content in fermented
or hydrolyzed food in terms of equivalent amounts of intact

Despite maintaining high standards for quality control as an
industry, individual breweries are still prone to mistakes. 
According to the results of a 2016 TTB Alcohol Beverage Sampling
Program conducted by the federal alcohol regulating body a random
selection of 53 malt beverages were tested for adherence labeling
compliance regulations. One of the tests checked to see if the
alcohol by volume (ABV) of the liquid inside fell within regulatory
tolerance (+/- 0.3% ABV) of what was claimed on the label.    29 of
the 53 products – 54 % – fell outside of the allowed variance. 

Ultimately, the final ruling by the FDA is that in order for a
beer to be labeled as gluten-free, only gluten-free ingredients
must go into the beer.  “A solution to all of this confusion
already exists,†Doug Foster of Aurochs Brewing in Pittsburgh, PA
discussed. “These dedicated gluten-free breweries address any
issues by creating craft beer made out of naturally gluten-free
ingredients. It eliminates the need to even worry about
gluten-reduced, unsafe products and labeling.â€

There are not shortcuts by the members of the Gluten-Free
Brewer’s Group. These breweries are dedicated to making safe,
quality gluten-free beers for consumers to feel completely safe
drinking. If you see the label gluten-free on a beer, know that it
was made with gluten-free ingredients. If you are sensitive, be
aware that gluten-reduced or gluten-removed may be a risk.

“Just as the only treatment for celiac disease is a completely
gluten-free diet, the only truly safe beer products to consume are
those that are made with 100% gluten free ingredients,†JP Bierly
Founder of Bierly Brewing in McMinnville, Oregon. “Agreed,â€
said Karen Hertz of Holidaily Brewing  â€œwe are glad there is a
difference between the gluten-free and gluten-removed labeling for
beers but ultimately there shouldn’t even be a gluten-removed
category. It’s either gluten-free or it’s not. We will keep
advocating for that as a group.â€

About the Gluten-free Brewers Group

Members of the Gluten-Free Brewers Group are passionate about
crafting high-quality beer that is accessible to all including
those with Celiac Disease and other gluten-related disorders.

There are currently 15 dedicated gluten-free breweries in the
United States. Follow along with the hashtag #getbeercurious to
learn more about gluten-free beer. Breweries interested in joining
the Gluten-free Brewers Group can reach out to Kaitlyn Gipple at
[email protected].

The post
Gluten-Free Brewers Group Responds to FDA Final Rule on Gluten-Free
Claims on Fermented Foods
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