public-service · gluten-free food labeling rule
What "Gluten-Free" Legally Means on a US Food Label
The FDA's gluten-free label rule sets a numeric threshold, not a zero-gluten promise, effective October 13, 2020.
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Updated: Sources: 2

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What matters now
- "Gluten-free" is a legal threshold, not a claim of zero gluten.
- The threshold is below 20 parts per million (ppm) of gluten, equal to below 20 mg per kg of food.
- This numeric standard comes from a specific FDA regulation, 21 CFR 101.91.
- The current rule, as amended for fermented and hydrolyzed foods, took effect October 13, 2020.
Under the FDA’s governing regulation, a food labeled “gluten-free” in the United States does not have to contain zero gluten. It has to meet a specific numeric limit: “[a]ny unavoidable presence of gluten in the food bearing the claim in its labeling is below 20 ppm gluten (i.e., below 20 mg gluten per kg of food)” (21 CFR 101.91). The current version of this rule has been in effect since October 13, 2020 (Federal Register, 2020-17088).
This original record-reading guide is a general reading aid, not cited evidence. It does not depict a source record; the article text and source links provide the facts.
Key points
- “Gluten-free” is a legal threshold, not a claim of zero gluten.
- The threshold is set at below 20 parts per million (ppm) of gluten, equivalent to below 20 mg of gluten per kg of food.
- This numeric standard comes from a specific FDA regulation, 21 CFR 101.91.
- The current rule, as amended for fermented and hydrolyzed foods, took effect October 13, 2020.
Numeric gluten limit
The word “gluten-free” on a US food label is a regulated term with a defined meaning, not a plain-English guarantee that no gluten is present. The FDA’s regulation states that for a food to bear the “gluten-free” claim, “[a]ny unavoidable presence of gluten in the food bearing the claim in its labeling is below 20 ppm gluten (i.e., below 20 mg gluten per kg of food)” (21 CFR 101.91). In other words, the regulation permits some unavoidable trace gluten, as long as it stays under that 20 ppm ceiling.
When this rule took effect
The current version of the gluten-free labeling rule — the one that also addresses fermented or hydrolyzed foods — has an “[e]ffective date: This rule is effective October 13, 2020” (Federal Register, 2020-17088). Any food labeled “gluten-free” under this framework is being labeled against that same 20 ppm threshold.
What this article does not answer
This article explains only what the regulation itself requires for the words “gluten-free” to legally appear on a label, and when that current rule took effect. It does not address whether any specific labeled product is safe for a person with celiac disease or gluten sensitivity, how any manufacturer tests its products for compliance with the 20 ppm threshold, or what other, unregulated phrases such as “no gluten ingredients” mean — those are separate questions the governing text quoted above does not settle. This article also does not offer any judgment about whether a person should eat a particular product; that decision depends on individual health circumstances outside the scope of a labeling regulation.
Source links
https://www.ecfr.gov/current/title-21/section-101.91 https://www.federalregister.gov/documents/2020/08/13/2020-17088/food-labeling-gluten-free-labeling-of-fermented-or-hydrolyzed-foods