«May contain traces of…»
- It is voluntary information. When given, it must not mislead, must not be ambiguous and must be based on data (Regulation (EU) No 1169/2011, Article 36(2)).
- It does not replace avoiding cross-contact. Putting it on every dish «just in case» does not protect the customer and leaves them with no options.
- Use it only when there is a real risk you cannot avoid, and explain to the customer what it is.
«Gluten-free» and «very low gluten»
- «Gluten-free»: only if the food, as sold, contains no more than 20 mg/kg of gluten (Implementing Regulation (EU) No 828/2014, Annex).
- «Very low gluten»: only for foods made from gluten-containing cereals processed to reduce it, with no more than 100 mg/kg.
- Oats: to be called «gluten-free», they must be produced to avoid contamination by wheat, rye or barley and not exceed 20 mg/kg.
- You may add «suitable for people with coeliac disease» or «suitable for people intolerant to gluten» (Article 3(2)).
- It applies to packaged food and to food served unpackaged (AESAN).
- Do not use it for something that never contains gluten, such as a juice: AESAN considers that misleading, because it implies the product is special.
If you write «gluten-free» on the menu, you must be able to guarantee it: gluten-free ingredients, separate preparation and no cross-contact. If you cannot, do not use any gluten statement: the absence of gluten can only be communicated with these statements and on their conditions (Article 3(1)). Give the allergen information and explain the cross-contact risk.
In practiceYour house bread is baked in the same bakery as the wheat bread. Do not call it
«gluten-free»: you cannot guarantee it stays at or under 20 mg/kg.
Source: Regulation (EU) No 1169/2011 on the provision of food information to consumers, Article 36 · Commission Implementing Regulation (EU) No 828/2014 on the absence or reduced presence of gluten, Article 3 and Annex · AESAN: labelling of substances causing allergies and intolerances (in Spanish)