Anyone who is an avid reader of food labels knows how difficult it can be to decipher the ingredients of packaged foods. For someone on the SCDiet, finding products without sugar, wheat, rice, corn, soy, or any other starch can be nearly impossible. Even if these “illegal” ingredients are not listed on the label, there is still a chance they could be lurking in packaged foods. Here’s the lowdown on food labeling laws:

The FDA regulates the labeling of food produced in the United States (foods imported from other countries abide by the labeling laws of their origin, which may be different from the U.S. regulations). According to the FDA, all ingredients must be listed in order of predominance (the ingredient that weighs the most is listed first, then down the line). Ingredients that comprise less than 2% of the product must be listed, but can be listed in any order. Some ingredients can be omitted from labels, and here’s where things get sticky. The FDA also allows for spices and flavorings to be listed collectively, e.g. “natural flavors,” “spices,” rather than individually. The FDA also exempts “incidental additives that are present in a food at insignificant levels and do not have any technical or functional effect in that food.” This includes byproducts of the manufacturing process as well as substances that are sub-ingredients of another ingredient. It also excludes substances added during processing that are “present in the finished food at insignificant levels and do not have any technical or functional effect in that food.” What makes an additive “incidental” or “at insignificant levels” is not well defined except for a few ingredients such as sulfites (which are considered incidental if the amount is less than 10 parts per million). It also seems unclear to me how (or how well) labeling laws are enforced.

So, if I am interpreting correctly, there are a few ways that unwanted ingredients can find their way into your foods:

  • If they are given a different name (e.g. dextrose instead of sugar)
  • If they are considered a flavoring, in which case they can be listed simply as “flavoring,” “spices,” etc.
  • If they are a sub-ingredient of another ingredient (for example, an added vitamin could have a byproduct used as a stabilizer or binding agent which is undeclared).
  • If it is used as part of the manufacturing process (e.g. the chemicals used on manufacturing equipment can leave trace amounts of residue on foods)

Now, if your diet restricts items that are among the 8 most common allergens (milk, eggs, fish, crustacean shellfish, peanuts, tree nuts, wheat, and soy), you are in luck. According to the Food Allergen Labeling and Consumer Protection Act, ingredients that are major allergens must be declared, even in small amounts. They also must be listed by their common name so that consumers can easily identify them. Companies are not, however, required to warn consumers if any accidental cross-contamination is possible due to allergens being processed in their facility (though many do), so if you have severe allergies, look for labels that specifically state that it was produced in a facility free of the foods you must avoid.

So where does this leave us? Still wading through the ingredients on our food labels, I’m afraid. Especially for those who are avoiding foods that are not considered major allergens (like sugar, rice, and corn), there are no guarantees that your packaged food is completely free of “illegals.” Some people categorically outlaw things (e.g. all canned vegetables) due to concerns that there are hidden additives in them. Others are more willing to trust certain foods. My personal view is that each person needs to weigh the severity of their intolerance against the necessity of the product to determine whether it is worth the risk. I make most of my food from scratch so that I can control the ingredients. Occasionally I try packaged products that I trust. If I have a concern, I contact the company to ask them to verify that it does not contain any of the foods I need to avoid. If I try it and am able to tolerate it, I add it to my repertoire.

So there you have it—food labeling regulations in a nutshell. Lately I’ve been learning about all of the different food additives out there – xanthan gum, dextrose, guar gum etc. Does anyone have any weird food additives they’d like to get to the bottom of? Leave them in the comments section and I’ll try my best to get some background on them!

For more reading:

Food allergen law

Food allergen labeling

Exemptions in the code of federal regulations

An easy to understand article on kosher foods found within packaged goods

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