The FDA has formally opened the door to revising how gluten is labeled on food products — and the celiac community has a rare opportunity to shape what comes next. The agency’s Request for Information (RFI), reported by Nutritional Outlook, asks manufacturers, researchers, and the public what the agency needs to know before potentially updating its gluten labeling requirements.
What’s Happening
A Request for Information is a formal data-gathering step that typically precedes new or updated rulemaking. The FDA uses it to hear from industry, science, and the public before deciding whether and how to act.
The current gluten-free labeling rule has been in place since 2013. It requires any food labeled “gluten-free” to contain fewer than 20 parts per million (ppm) of gluten. That threshold was based on the best available science at the time — and it has not changed in over a decade. But the science has advanced considerably, and gaps in the rules have become harder to ignore:
- Precautionary labeling — phrases like “may contain wheat” or “processed in a facility with wheat” are voluntary and unregulated, leaving families to guess what they actually mean
- Cross-contact risk disclosure — manufacturers have no obligation to tell consumers when a product may have come into contact with gluten during production
- Oats — the rule’s treatment of oats remains a persistent source of confusion, since oats are inherently gluten-free but frequently contaminated during processing
- Ingredient transparency — wheat-derived additives like malt flavoring and certain modified starches are not always clearly flagged on labels
An RFI is not a proposed rule. It is the FDA saying: Tell us what you know before we decide what to do. That makes this early in the process — but it’s precisely the moment when public input carries the most weight.
This RFI builds on a pattern of recent activity. We covered the FDA’s earlier moves in FDA Takes Steps to Improve Gluten Ingredient Disclosure in Foods, and the broader push by advocates has been years in the making, as we detailed in Advocating for Clearer Labeling of Gluten in the U.S. The RFI signals that the agency is finally formalizing its inquiry.
What It Means for Celiac Families
For the roughly 3 million Americans with celiac disease — and the caregivers who shop, cook, and advocate for them — gluten labeling is not a regulatory abstraction. It is a daily safety system.
My son has celiac disease. Every label I read is a risk calculation. The words “gluten-free” carry real weight at our kitchen table, but the current rules leave genuine gaps. A product can carry a “gluten-free” claim and still display an advisory elsewhere on the package about wheat in the same facility. There is no requirement to disclose cross-contact risk at all. Families fill that void by developing their own rules of thumb — a patchwork approach that no one should have to rely on.
Closing these gaps would have concrete effects:
A lower ppm threshold would mean that products labeled gluten-free contain even less gluten. While 20 ppm is considered safe for most celiac patients, research suggests a subset of patients react at lower levels. A stricter limit provides a wider safety margin for the most sensitive.
Regulated advisory labeling would give families consistent, meaningful information about cross-contact risk rather than legally cautious boilerplate that provides no real guidance.
Clearer ingredient sourcing would remove the guesswork from ingredients derived from gluten-containing grains that are easy to overlook on a crowded label.
These are not niche concerns. They are the daily friction points that make managing celiac disease harder than it needs to be.
What You Can Do
RFIs include a public comment period. When the FDA publishes the formal notice in the Federal Register, anyone — patients, caregivers, clinicians, researchers — can submit comments directly.
To make a comment count:
- Be specific. Personal experience with labeling failures is relevant, but pair it with a clear statement of what rule change would have prevented the problem.
- Focus on the gaps. The most useful comments identify what the current rules do not cover — precautionary labeling, oats, cross-contact disclosure — and explain the real-world harm those omissions cause.
- Connect with advocacy organizations. Groups like Beyond Celiac and the Celiac Disease Foundation submit formal consolidated comments and track rulemaking closely. Coordinating with them amplifies individual voices.
- Monitor the docket. Search regulations.gov for the FDA’s gluten labeling RFI docket number once it is formally published. That is where comments go on the record.
If the comment process feels overwhelming, start by reaching out to your gastroenterologist or a celiac-specialist registered dietitian. Many clinicians are already engaged in advocacy efforts and can point you toward coordinated comment campaigns.
Regulatory change moves slowly. But agencies do respond to organized, specific input from the communities their rules affect. This is a formal invitation to put the celiac community’s experience on the record — and that does not happen often.
Related Coverage
- FDA moves toward tougher gluten labeling rules
- FDA Takes Steps to Improve Gluten Ingredient Disclosure in Foods
- Advocating for Clearer Labeling of Gluten in the U.S.