Confusing May Contain Warnings Explained

By Sue Newell

A large food retailer in Canada adds “May contain wheat” warnings to virtually all of its house brand products.  Snack foods imported from some countries regularly list all 12 priority allergens on their ingredient lists. Products with a gluten-free claim also carry “may contain wheat” warnings (and this is encouraged by Health Canada and the Canadian Food Inspection Agency).  Almost all the ingredient labelling regulations in Canada are set by regulation but precautionary labels remain in the “optional” category.  No wonder people are confused about the words “May contain”.

In the last two years, products have appeared in our stores carrying both a “Gluten-free” claim and a “May contain wheat” warning. According to Health Canada, this labelling rule is acceptable in situations where the product meets the criteria for a gluten-free claim (no gluten ingredients, product made specifically to be gluten-free, and no gluten contamination at levels above 20 ppm) but may have levels of gluten contamination below 20 ppm. The “May contain” warning is provided as a service to people with a true wheat allergy. There are no maximum safe levels for allergy warnings.

So what should someone with celiac disease or non-celiac gluten sensitivity do with these products? Here are our recommendations:

  1. “Gluten-free” claims must be true so they take precedence over any precautionary “May contain wheat” claims. Go ahead and eat the product.
  2. If there is no “gluten-free” claim, but there is a “May contain” warning for any gluten grain, do not eat the product.

The fact that “May contain” labels are voluntary triggers fear for some consumers. Product manufacturers are “responsible for the safety of their products, including addressing potential risks associated with the presence of allergens”.  In other words, if the risk is significant and not controlled, they must inform consumers.

Meeting Health Canada: As the voice for people with CD and GS, CCA representatives recently met with Health Canada in June. CCA is also involved in stakeholder consultations related to prescription drugs, natural health products and new beer standards. We will continue to advocate for ways to make labelling more clear for consumers.

Understanding Gluten Labelling In Canada – Free Webinar May 17th

Gluten-Labelling Webinar

As part of our Celiac Awareness Month activities, the CCA is launching its first of several webinars to support the Canadian celiac community.

Pre-registration is required. The webinar is FREE. 

Contact information is required in order to participate. Space is limited.

DATE: Wednesday, May 17, 2017     TIME:   7 – 8pm OR  9 – 10pm EDT

Title: Is that safe for me? Understanding gluten labelling in Canada 

Presenter: Sue Newell

Here’s what you’ll learn:

1. Understand the requirements for a gluten-free claim in Canada

2. Understand the elements of risk analysis for gluten contamination in food

3. Identify the package elements used to determine the gluten risk for food

4. Understand the core elements of certification

To register: Click or paste on one of the following links:

7 – 8pm EDT –

9 – 10pm EDT –

Domino’s Gluten-Free Pizza Crust in Canada

Courtesy National

domino's pizza logoDomino’s brought their gluten-free pizza crust to Canada this month, but they present customers with this disclaimer when you try to order the pizza:

Domino’s pizza made with a Gluten Free Crust is prepared in a common kitchen with the risk of gluten exposure. Therefore, Domino’s DOES NOT recommend this pizza for customers with celiac disease. Customers with gluten sensitivities should exercise judgment in consuming this pizza.

Right now we don’t know if small amounts of gluten are a problem for people with gluten sensitivity, the CCA does not recommend that anyone with celiac disease or gluten sensitivity consume pizzas from Domino’s.

According to company spokesman Barry Langhodge, the crust is gluten-free but they are NOT selling a gluten-free pizza. The crust is made in a dedicated gluten-free facility. It arrives at the restaurant individually wrapped and ready to cook from scratch, but there are no practices in place to avoid cross-contamination as the toppings are added, the pizza is cooked, and the pizza is boxed up.

The CCA hopes to work with the company to develop policies that will allow them to sell a gluten-free pizza, not just a gluten-free crust.

New labeling law now in effect – what you need to know


CCA LogoNew labelling regulations in Canada come into effect today (August 4, 2012). While manufacturers have had some time to implement the new regulations, some products may not meet all the requirements immediately. While the CONTAINS and MAY CONTAIN statements are helpful in identifying top allergens and gluten, always read the ingredient list.

The new regulations require that the ten priority allergens, gluten sources, and added sulphites of 10 ppm be identified using plain language either in the ingredient list or in a Contains statement that appears immediately after the ingredient list. Manufacturers have a choice about which method they choose to use.

When you check for gluten, you may need to check two places:

  • The INGREDIENT list

Start with the WARNINGS. You are looking for wheat, rye, barley, oats or gluten.

If you see wheat, rye, barley, oats or gluten, in either the CONTAINS or MAY CONTAIN list, the product is NOT OK.

If there is a CONTAINS statement, and it does not include wheat or a gluten grain, the ingredients are acceptable for a gluten-free diet.

If the ingredient list just says oats, assume they are contaminated with gluten, unless they are specifically identified as pure uncontaminated oats or by the source (Cream Hill Estates Oats, Only Oats, etc.).

If there is no CONTAINS statement, check the INGREDIENT list. You are looking for wheat, rye, barley or oats. If you see wheat, rye, barley, or oats, the product is NOT OK. If you do not see any gluten source listed, the ingredients are acceptable for a gluten-free diet.



  • Plain names must be used for all allergens – WHEAT, MILK, EGGS, etc. Allergens cannot be hidden in ingredients like seasoning or natural flavour.
  • If one allergen is listed in a CONTAINS statement, then all the allergens including gluten must be listed.
  • The only warnings that have official meanings are CONTAINS and MAY CONTAIN. All other warnings (“made in a plant that also processes wheat “etc.) can only be understood by contacting the company.
  • Cross-contamination with gluten can occur in a product despite the use of good manufacturing practices and may not be reflected on the ingredient list.

Get a printable PDF version of this document at:

Gluten-Free Labeling Update

Canadian Celiac Association LogoBy the Canadian Celiac Association

At a recent meeting Health Canada has initiated the formation of a Canadian Food Allergy Network. The intent is to promote initiatives to manage food allergy incidents and provide guidance supporting initiatives for the management of food allergies in Canada. Key items on this agenda are the current labelling amendments which would include gluten as a priority allergen, and addressing the issue of Precautionary Labelling that has become over- and misused.

At this first meeting, it was noted that the labelling amendments put forward nearly a year ago, are expected to be revised and finalized by the end of February for final government approval through Canada Gazette Part II. In the end it would mean that all labelling would have t meet these requirements by 2012.

Equally as important to our community, Health Canada did announce that it is now ready to re-visit the regulation governing the ‘gluten-free’ declaration. Key issues here include the matter of pure, uncontaminated oats and the need for (or not) a ‘safe threshold’ of gluten expressed in ‘parts per million’.

The international voluntary standards body ‘Codex’ has finalized revisions to its gluten-free standard with a threshold of 20 ppm, and added another category called ‘reduced gluten’ where foods specially processed to reduce the gluten content to 20 from 100 ppm can be so labelled. Countries are free to choose to adopt and/or adapt this standard at their discretion.

The United States FDA is in the process of finalizing its proposed regulation that was drafted to include a 20 ppm threshold. The final details and threshold limit has not yet been announced.

Proposed New Labelling Requirements

Government of Canada Press Release

OTTAWA – The Honourable Tony Clement, Minister of Health, today announced increased protection for Canadians with food allergies by introducing new labelling requirements for food allergens, gluten sources and added sulphites contained in prepackaged foods. Health Canada also announced the launch of several allergy studies, including a large national study of food allergy prevalence, and two studies on the dietary habits and coping skills of people with celiac disease who are on a gluten-free diet.

The improved regulations would require that manufacturers declare all food allergens, gluten sources and added sulphites on labels of prepackaged foods. The regulations would also detail exactly how these allergens, glutens and sulphites are to be listed on food labels.

The announcement followed a letter writing campaign to Prime Minister Stephen Harper, requesting that these long-delayed regulations be put into law.

To view the complete press release on the Health Canada website:

For more information on the proposed Food Allergen Labelling Regulatory Amendments: