Oats in Gluten-Free Diets: An Examination of the Codex Standard and Country-Specific Differences in Gluten-Free-Food Labeling Regulations, for Oats and Oats Declared as Ingredients in Gluten-Free Products

Abstract Globally, there are differences in the way oats are regulated—particularly regarding the food labeling when oats are called gluten-free, with the potential to impact people who have celiac disease or related conditions. The potential cross-contact of oats with wheat, rye, and barley during processing is a concern for people with gluten-related disorders. This study examined selected international regulations governing gluten-free foods, the regulatory treatment of oats, and the requirements for declaring oats as an ingredient on gluten-free food labels. A comparative review of key regulatory frameworks was undertaken, including the World Health Organization and Food and Agriculture Organization—Codex Alimentarius Standard, and regulations from the United Kingdom (UK), the European Union (EU), the United States, Canada, and Australia and New Zealand (ANZ). All of the listed jurisdictions, with the exception of ANZ, define gluten-free foods as foods containing less than 20 mg gluten/kg food (20 ppm) (in the United States), or less than or equal to 20 ppm. In ANZ, a gluten-free food must not contain detectable gluten or oats, which prohibits oats from being labeled as gluten-free. The United States alone classifies oats as not containing gluten. The regulations of many countries are based on the premise that oats processed with minimizing of gluten cross-contact are safe for most individuals with celiac disease, but stipulate that oats are only permitted to be labeled gluten-free if they contain <20 ppm (in the United States) or ≤20 ppm gluten (in the remaining listed jurisdictions with the exception of ANZ). The current ANZ labeling regulations are not aligned with other international regulations, and emerging clinical evidence suggests it may be timely and impactful to re-evaluate the regulatory definitions of oats, such that individuals can safely identify products suitable for their medical requirements.