CCA Advisory Committee Submits Beer Labeling Recommendations

The Canadian Food Inspection Agency is currently conducting a review of beer standards. Below is the full submission of the CCA Professional Advisory Committee seeking to have beer labelling brought into alignment with other food products.

If you are not a member of the CCA, please consider a membership and donation so that important advocacy efforts like this can be effective. No doubt the brewery industry has deep pockets to fund its continued opposition to beer labelling changes.

Director, Consumer Protection and Market Fairness Division
Food Import Export and Consumer Protection Directorate
Canadian Food Inspection Agency
1400 Merivale Road, Tower 2
Ottawa, Ontario K1A 0Y9

 

August 10, 2017

The Canadian Celiac Association appreciates the opportunity to respond to the recent notice of intent to amend the Food and Drug Regulations to update the beer compositional standards. The following outlines our concerns and recommendations:

Allergen, gluten and sulfite labelling
The 1220 — Enhanced Labelling for Food Allergens and Gluten Sources and Added Sulphites Regulations that was passed in 2011 and came into effect in 2012 required priority allergens, gluten sources and added sulphites to be declared in the list of ingredients or “Contains” statement on the label of prepackaged foods and beverages. During the consultation phase, the Canadian Celiac Association, along with many other medical, dietetic and patient advocacy organizations, strongly supported Schedule 1220. However, the Canadian Celiac Association and other groups strongly objected that standardized beer would be exempted from these regulations. Unfortunately, standardized beer did receive the labelling exemption which is a major health and safety concern for those with celiac disease or food allergies as they are unable to discern from the label if the product contains any gluten, major allergens or added sulphites.

This new 2017 consultation on beer compositional standards provides the opportunity to resolve the safety issues for individuals with celiac disease and food allergies.

Recommendation #1

The Canadian Celiac Association strongly recommends that the names of all gluten sources, priority allergens and added sulphites, when used in standardized beers, be declared on each individual container of beer as well as the outside packaging of these products.

Definition of Beer
Individuals with celiac disease must follow a strict, life-long gluten free diet which places significant limitations on food and beverage options. Given the popularity of various types of beer, ale and lager, many individuals with celiac disease are looking for an alternative to gluten-containing beer. The product that they are/will be looking for is one labelled ‘gluten-free beer’.

For beverages fermented from gluten-free grains/other ingredients, the proposed amendments would not permit the use of the term ‘gluten-free beer’ but rather “gluten-free beverage.” This would be very confusing for gluten-free consumers as the term ‘beverage’ could include many different non-beer alternatives such as wine, distilled alcohols, liqueurs, ciders and non- alcoholic beverages (e.g., juice,
milk, smoothies, etc.).

Recommendation #2

To avoid misleading consumers, the Canadian Celiac Association recommends the use of the term ‘gluten- free beer’ for beer-type beverages that utilize gluten-free grains and ingredients such as sorghum, millet, rice, etc. However, there are currently some beers made with malted barley and a special clarifying agent that are labelled “gluten free”. The manufacturers claim these beers are rendered gluten free. Unfortunately, this agent impacts the R5 Competitive ELISA’s ability to accurately detect gluten, thus, a negative test result does not mean the product is indeed safe for individuals with celiac disease. (see references, page 3). It is not known whether these agents can completely remove all toxic fragments from glutencontaining beers and as such, labelling of these products as ‘gluten-free beer’ should not be permitted.

Recommendation #3

Beers made with malted barley and a special clarifying agent should not be lablelled “gluten-free beer” because the clarifying agent interferes with the accuracy of the R5 Competive ELISA that detects gluten contamination.

Thank you for careful consideration of our three recommendations.

Respectfully submitted,

The Professional Advisory Committee, Canadian Celiac Association
Dr. Don Duerksen(Chair), Dr. Premsyl Bercik, Dr. Decker Butzner, Shelley Case, RD, Adrianna Smallwood, RD, Joyce Schnetzler, RD, Dr. Justine Turner, Dr. Elena Verdú, Dr. Jennifer Zelin.

 

References
Tanner GJ, Colgrave ML, Blundell MJ, Goswami HP, Howitt CA. Measuring hordein (gluten) in beer–a comparison of ELISA and mass spectrometry. PLoS One. 2013;8(2):e56452. doi: 10.1371/journal.pone.0056452. Epub 2013 Feb28.

Allred LK, Lesko K, McKiernan D, Kupper C, Guandalini S. The Celiac Patient Antibody Response to Conventional and Gluten-Removed Beer. J AOAC Int. 2017 Mar 1;100(2):485-491. doi: 10.5740/jaoacint.16-0184. Epub 2016 Dec 16.

Colgrave ML, Goswami H, Blundell M, Howitt CA, Tanner GJ. Using mass spectrometry to detect hydrolysed gluten in beer that is responsible for false negatives by ELISA. J Chromatogr A. 2014 Nov 28;1370:105-14. doi: 10.1016/j.chroma.2014.10.033. Epub 2014 Oct 18.

Don’t Listen to your Bartender

beer-not-gluten-free

By CCA Board of Directors
For many people, bartenders have become experts about gluten in beer. After all, they are educated by brewery representatives who have a job selling beer, not those dietitians and doctors who seem to just make your life miserable and unfulfilling! Over a period of four weeks we were told by CCA members and other celiacs that at least 12 different mainstream beers are “OK for people with celiac disease”.

beer-not-gluten-freeDespite the obvious appeal of listening to those bartenders, there are a few problems with their analysis:

  • Symptoms are not a good indicator of the absence of gluten in a product.
  • Beer is not distilled so the proteins are not removed from the grain ingredients – including malted barley.
  • We do not have verified technology to measure the amount of gluten in beer. That means that a gluten test might give you a number but we have no way to know if that number is correct, or if it might be significantly underestimating the amount of gluten in the beer.
  • As per Health Canada, any product containing barley or malt directly added is not allowed to be called “gluten free”.

Gluten from barley is the hardest type of gluten to detect on a test. In beer, where the barley proteins are broken into pieces, detecting the “bad” part of the proteins is even harder. The conventional tests will give you a number for the amount of gluten in a beer sample, but there is no way to verify that number. Studies that use mass spectroscopy to look at the broken pieces of barley proteins have found gluten in all barley-based beers. This research article gives details if you would like to read more.

Some manufacturers use an enzyme that is supposed to break the gluten sequence in beer into pieces so that it won’t trigger a gluten reaction. This treated beer that is “Crafted to remove gluten” and sold in Canada must carry a statement that indicates that there is no way to accurately measure the amount of gluten in beer. This message has been seen on bottles of Daura Damm in Ontario. It was on the label around the neck of the bottle in very tiny print.

End result, the CCA does NOT consider beer made with gluten as safe for people with celiac disease, treated to remove the gluten or not. Beer is one of those things that does not meet the gluten-free criteria, just like wheat-based bread isn’t safe. There are alternatives that are not really the same (just like with bread). You either get used to them or you stop eating bread. The same rule applies for beer.

Don't listen to bartenders – barley beer isn't safe

by CCA National Office

For many people, bartenders have become experts about gluten in beer. After all, they are educated by brewery representatives who have a job selling beer, not those dietitians and doctors who seem to just make your life miserable and unfulfilling! In the past month I have been told by CCA members and other celiacs that at least 12 different mainstream beers are “OK for people with celiac disease”.

Despite the obvious appeal of listening to those bartenders, there are a few problems with their analysis:

  1. beer-not-gluten-freeSymptoms are not a good indicator of the absence of gluten in a product.
  2. Beer is not distilled so the proteins are not removed from the grain ingredients – including malted barley.
  3. We do not have verified technology to measure the amount of gluten in beer. That means that a gluten test might give you a number but we have no way to know if that number is correct, or if it might be significantly underestimating the amount of gluten in the beer.
  4. As per Health Canada, any product containing barley or malt directly added is not allowed to be called “gluten free”.

Gluten from barley is the hardest type of gluten to detect on a test. In beer, where the barley proteins are broken into pieces, detecting the “bad” part of the proteins is even harder. The conventional tests will give you a number for the amount of gluten in a beer sample, but there is no way to verify that number. Studies that use mass spectroscopy to look at the broken pieces of barley proteins have found gluten in all barley-based beers. This research article gives details if you would like to read more.

Some manufacturers use an enzyme that is supposed to break the gluten sequence in beer into pieces so that it won’t trigger a gluten reaction. This treated beer that is “Crafted to remove gluten” and sold in Canada must carry a statement that indicates that there is no way to accurately measure the amount of gluten in beer. I saw this message on a bottle of Daura Damm at the LCBO store yesterday. It was on the label around the neck of the bottle in very tiny print.

End result, the CCA does NOT consider beer made with gluten as safe for people with celiac disease, treated to remove the gluten or not. Beer is one of those things that does not meet the gluten-free criteria, just like wheat-based bread isn’t safe. There are alternatives that are not really the same (just like with bread). You either get used to them or you stop eating bread. The same rule applies for beer.

Barley-based beer NOT for celiacs

By Mark Johnson, CCA Ottawa Chapter

mark-johnsonWhen people are diagnosed with celiac disease or gluten sensitivity, one of the most frequent concerns is no longer being able to drink beer. Myself, I’m more of a rum and coke kind of guy but I suspect I’m in the minority. The good news is that, with gluten-free being so popular and well known nowadays, there are a number of beers that those with celiac disease can enjoy, ranging from lighter beers to the strong ones that many people swear by.

One of the more frequent objections I’ve heard is that gluten-free beer tastes too different. Particularly for those who like “heartier” beers, some of the gluten-free alternatives are too light-tasting. In exploiting this trend, some companies have been tinkering in the laboratory to develop beers that use barley and hops but are still able to be called gluten free.

You may have seen new varieties at the liquor store. In addition to the classics like La Messagère, New Grist, Bard’s, Glutenberg and Nickel Brook, we’re also seeing some barley-based “gluten-free” beers popping up, such as Omission, Estrella, Brunehaut and Mongozo. While relatively rare here, such beers are more commonly found in Europe.

Let us be clear: the CCA does not recommend that Canadians with celiac disease or gluten intolerance drink any barley-based beers. This is regardless of whatever enzymes might be used to supposedly break down gluten. Yes, the companies may wave tests around showing that samples came up at less than 20 parts per million (ppm) gluten, but what they’re usually less interested in discussing is the scientific accuracy of such tests on a liquid product.

Using currently available testing methods, some beers report a number less than 20 ppm, but there is significant evidence that suggests the tests do not detect all the gluten in the beer. Until we have a test that we are confident is detecting all of the toxic proteins in the beer, we recommend that people with celiac disease not consume it.

In the United States, beers treated to remove barley protein must carry a warning that tells consumers that: (1) the product was made from a grain that contains gluten; (2) there is currently no valid test to verify the gluten content of fermented products; and (3) the finished product may contain gluten. Health Canada has indicated that beer carrying these qualifiers could be sold in Canada, but not with a “gluten-free” claim.

Be aware, and drink responsibly!

Mark Johnson

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Low Gluten Beer

Courtesy National Newsletter

Members have asked a number of questions recently about low gluten beer. A number of vendors offer these beers that are made with malt but are treated to reduce the gluten content using enzymes that break down the barley proteins into small pieces. Various companies claim that their beer tests to less than 20 ppm, less than 10 ppm, and less than 3 ppm gluten. Is it really safe for someone with celiac disease to drink?

The CCA does not have a formal position on these beers, but we do have concerns about the accuracy of the test results. Hordeins, the gluten proteins in barley, are complicated to detect, especially when these proteins are partially hydrolyzed or broken down into pieces as they are in beer.

The most common test for hordeins (the R5 Sandwich ELISA) looks for two specific sites on the protein. When many of the proteins are broken, the test may miss finding the hordein if the protein breaks near the binding site [Note 1]. Some of the fragments of proteins may still cause damage in someone with celiac disease.

Researchers in Australia [Note 2] tested a number of low-gluten beers using a different tool, mass spectrometry, and they found significant amounts of gluten protein and gluten protein fragments in all of the low gluten beers they tested. With a sample size of 60 beers selected from the international market, underestimating the amount of gluten in low-gluten beer is probably a significant issue worldwide.

Good news? The researchers did not find gluten in any of the gluten-free beers made without barley malt. Cheers!

Note 1: For more information about testing for barley, check http://www.glutenfreedietitian.com/newsletter/barley-malt-ingredients-in-labeled-gluten-free-foods/.

Note 2: Colgrave ML, Goswami H, Howitt CA, Tanner GJ. What is in a beer? Proteomic characterization and relative quantification of hordein (gluten) in beer. J Proteome Research. October 2011. The study is available at: http://pubs.acs.org/doi/suppl/10.1021/pr2008434

Food labeling law moves ahead but beer gets an exemption

The proposed allergen labeling law is finally going ahead. Industry now has 18 months to implement new allergen labeling regulations which require food allergen or gluten sources to be written in a uniform way.

The new regulations were set to be announced earlier this month but a last minute attempt by the beer industry for an exemption led to the cancellation of the announcement. Advocates of the new law feared that reopening the discussion for a  beer exemption would set-back the new regulations by a year or more.  Advocacy groups have been asking for the new regulations for a decade.

But it’s not all good news for 1 in 20 who suffer from food allergies.  Beer companies have won their special exemption, at least for now. They successfully argued that it is obvious that beer has gluten in it and too costly to change it’s labels.  Their did not address the argument that other allergens such as sulphites, nuts, and chocolate are increasingly used in their specialty beer products. It also flies in the face of an Angus Reid poll by Anaphylaxis Canada and the Canadian Celiac Association that showed 67 per cent of Canadians wanted the proposed labelling rules to apply to all food and beverage companies.

Wine and spirits are not covered by the exemption.

According to the Globe and Mail, Anaphylaxis Canada and the Canadian Celiac Association were not invited to the government announcement today.

Read the full Health Canada press release below…

Health Minister Leona Aglukkaq

Today, the Honourable Leona Aglukkaq, Minister of Health, and Royal Galipeau, Member of Parliament for Ottawa-Orleans, announced regulations to strengthen Canada’s labelling of food allergens and gluten sources. This means that Canadians with food allergies, sensitivities and celiac disease will soon be able to make more informed choices about the foods they buy. The Ministers also unveiled what the food label will now look like.

“Our Government is committed to protecting children and families from dangerous products, and this is clear from the measures we have taken in our new Consumer Product Safety Act,” said Minister Aglukkaq. “All parents want to have confidence in the food they are serving their families, and these changes to food labels will make it easier for parents of children with food allergies to identify potentially harmful, if not fatal, ingredients in foods.”

It is estimated that approximately five to six per cent of young children and three to four per cent of adults suffer from food allergies. Nearly one per cent of the population is affected by celiac disease, for whom the consumption of foods containing gluten can lead to long term complications.

The new regulations will require additional labelling and strengthen the labelling requirements to require clearer language and the declaration of otherwise “hidden” allergens, gluten sources, and sulphites.

Because of the complexity of the changes and the shelf-life of foods, industry has been given 18 months to implement the new allergen labelling regulations. The coming into force date is set for August 4, 2012.

Health Canada and the CFIA will continue to work with industry members to ensure that there is a smooth labelling implementation period for foods sold in Canada. Health Canada will continue to update Canadians on the progress of this file as the coming into force date approaches.

Please visit Health Canada’s website for details on the final regulatory amendments on labelling regulations for food allergens, gluten sources and added sulphites (http://www.hc-sc.gc.ca/fn-an/label-etiquet/allergen/project_1220_rias_eeir-eng.php).

You can also watch our video on Allergen Labelling (http://www.hc-sc.gc.ca/ahc-asc/media/video/food-aliments-eng.php).

To subscribe to receive email notifications for allergy alerts, visit the Canadian Food Inspection Agency’s recall page (http://www.inspection.gc.ca/english/util/listserv/listsube.shtml)

For more information on food allergies, food intolerances, and celiac disease, please visit:

Health Canada’s Food Allergy and Intolerances Page
www.healthcanada.gc.ca/foodallergies
Health Canada’s Allergen Labelling Page
http://www.hc-sc.gc.ca/fn-an/label-etiquet/allergen/index-eng.php
Health Canada’s Celiac Disease Page
www.healthcanada.gc.ca/celiac
CFIA’s Food Allergens Page
http://www.inspection.gc.ca/english/fssa/labeti/allerg/allerge.shtml