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The Lowdown on Gluten-Free Wine Labeling

The FDA has not yet issued a final rule on the use of the term “gluten-free” on food labels, but the TTB is issuing an interim policy on gluten content statements in the labeling and advertising of wines, distilled spirits, and malt beverages.

The TTB has received requests from various alcohol beverage industry members who wish to use gluten-free statements on their labels and in advertisements. Pending the issuance of a final rule by FDA, TTB is providing interim guidance on the use of the term “gluten-free” on alcohol beverage labels and in advertisements subject to TTB’s authority under the FAA Act. In the absence of a regulatory definition of the term “gluten-free,” TTB believes that the term will be interpreted by consumers of alcohol beverages to mean that the product contains no gluten.

Sound familiar?  Think about sulfite-free labeling. Many drinkers interpret sulfite-free wines to mean no sulfites. But that isn’t the case.  By definition, the term ‘gluten-free’ implies no gluten, but in practice a zero level does not exist.

This is where it get a little tricky. Wine is made from grapes, not grains, so it is naturally gluten-free.  But according to the TTB, there are a few things to take into consideration with the final bottled product.  For example,

A wine fermented from grapes, or a vodka distilled from potatoes, may be labeled “gluten-free” only if the producer used good manufacturing practices, took adequate precautions to prevent cross-contamination, and did not use additives, yeast, or storage materials that contained gluten.

Under TTBs interim policy, they will allow the use of a “gluten-free” claim in the labeling and advertising as long as the bottler of the product ensures that the claim is truthful and accurate. Although some industry members claim that their products have been processed to remove gluten, such claims cannot be properly verified without a scientifically valid method to measure the gluten content of the products.  TTB will not approve labels containing the above claims unless the label application contains a detailed description of the method used to remove gluten from the product, which should be less than 20 ppm (parts per million).

I assume the reason why a winery would want to promote gluten-free on the label is to follow the gluten-free food trend. From a marketing perspective, this could open up a whole new market, and hey, if it creates new wine drinkers, its all good.  But on the flip side,would this cause more consumer confusion? Would it lead to believing all wines contain gluten [above the 20 ppm threshold] unless the bottle has a gluten-free stamp?  We don’t want drinkers saying,  “I can’t drink wine because I am allergic to gluten.”

I also wonder if gluten-free labels would drive consumers away. Plenty of drinkers pass on wines stamped with “sulfite-free” or “organic” labeling.  Its not to say these wines are better or worse, its simply how the drinker perceives its quality or message in the bottle.  And if most allergic to gluten don’t have problems drinking wine, then I guess it comes down to what’s the point of labeling it as such? Hopefully, the marketers will keep the promotional strategies real. We don’t want to spend the next decade educating consumers on misleading gluten-free advertising.

What do you think? Would you buy a wine with a gluten-free label?  And is it good or bad for the wine business?

Photo credit: http://celiacsinthehouse.com/

This post was written by:

- who has written 284 posts on Enobytes Wine Online.

Editor and co-founder of Enobytes.com, Pamela is a former restaurant manager, wine buyer, and sommelier with WSET, CMS & Center for Wine Origins certification. She has contributed to or been quoted by various publications, including the Los Angeles Times, Sommelier Journal, Vegetarian Times, VIV Magazine, UC-Berkeley Astrobiology News, The Washington Post, the Associated Press, and USA Today. True to her roots, she seeks varietal and appellation integrity and is always passionate about finding the next great bottle of wine.

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61 Responses to “The Lowdown on Gluten-Free Wine Labeling”

  1. George Reichert says:

    You bring good questions to the table and I’m on the fence with this one. On the consumer side, it is good to enclose as much information about the product. But imagine a label with “gluten-free”, “sufite-free”, “organically made”, “made with organic grapes”, “certified biodynamic”, “grown with “biodynamic grapes”. Where does it end?? It causes confusion unless the consumer knows exactly what each definition means. From a marketing perspective, I think they should think carefully about the message they want to convey and stick with it. I don’t think I would purchase a bottle of wine with some sort of gluten-free identifier but I’m assuming someone would make a buying decision based on that information.

    • Hey George, you forgot to list “salmon-safe”! ;) Maybe the discussion turns to disclosing a list of ingredients on the back label. I know that Randall Grahm lead the way on this topic a while back.

      • More to the point is no iodine containing ingredients (eisenglas) to prevent people with (shellfish) allergies going into anaphylactic shock.

        What we really need is consumers not to disdain an ingredients list (sorry about the double negative).

        It should not be a winemaking sin to use a pure culture of naturally occurring yeast to prevent spoilage organism growth and emphasize the fruit’s inherent characters…but it is.

        • Regarding iodine, could the same case be made for casein or albumen fining agents. It probably doesn’t carry the same weight or severity someone would experience if they were allergic to shellfish, but it still poses risk to those with milk and egg white allergies.

      • Devona says:

        As someone who has recently been diagnosed with Celiac, triggering from CORN and gluten, this is a rising health issue to be taken seriously — think debilitating digestive disorders that handicap people. I am extremely frustrated by our labeling requirements and desperately want to see all ingredients listed, not things that people have to try to interpret, or have no interpretations, e.g.: “flavoring”. Attempting to avoid corn and wheat is about impossible in anything processed; which I eat none of, except red wine! I love red wine and thought it was safe. I would prefer wines aged w/o the use of flour, gluten, corn products — so I guess the option is stainless steel. And, I would like to be an informed consumer and see this info somewhere on the label!

  2. As winemaker/ winery owner with Celiacs disease this isn’t a merely a marketing concern. While Gluten Free (GF) may seem like a fad it is a serious health issue for over 5% of the population.

    So yes, I’d be in favor of labeling “No Gluten Containing Ingredients”. We work very hard to make sure nothing used in our winemaking contains gluten (for obvious reasons). Maybe if these labels start appearing gluten will be eliminated from the supply chain and no one will need to worry about labeling.

    As an industry we may have an issue with claiming “Gluten Free” wines if barrels are used. Barrel heads are still often sealed with wheat paste and the barrel sales personnel are not aware of the potential problem. We clean our barrels with a high pressure water jets even before their first use to reduce the chances of contamination. Although I have yet to detect any gluten in our wines, but that doesn’t mean they’re totally gluten free either. So I’m not sure any winery could claim “Gluten Free” if barrels are used.

    The distinction between “Gluten Free” and “No Gluten Ingredients” is important. Flour is often used in processing (to prevent items sticking to the machinery) food stuffs but is not listed and does not disqualify the manufacturer from using “No Gluten Ingredients Used”.

    • Hi Steve, thanks for bring up the use of wine barrels and flour. I was talking with another winemaker and he agreed these were legitimate concerns but also stated most of the commercial wines on the shelves are way below the 20 ppm threshold—which is why I’m questioning the need for gluten free labels. If the TTB makes the determination that gluten-free means below 20 ppm, and 99% of the commercial product sold is already below this threshold (but is it?) then why are we drawing attention to it? I think your “Gluten Free” and “No Gluten Ingredients” will be an important key in the TTBs final decision. Appreciate you chiming in here.

      • I need to preface this with I’m not in-favor of mandatory labeling. NGI/GF will become mandatory for foods this fall. Having it on alcoholic beverages is probably a good idea. Unlike many label/tags this one has very tangible immediate health impact in addition to the longer term issues (low-salt, fat-free…. etc). It also affects a much larger population than sulfites, shellfish, or Phenylalanine.

        I’ve learned the hard way that gluten has crept into almost every manufactured food product; Many that would be though of as naturally gluten free (certain brands of string cheese are among my latest “discoveries” – probably flour used in the processing equipment). Gluten is contaminate in many food components – I was given an expensive Italian liquor and was stunned when I had an issue with it (severe leg cramps within an hour of one shot). On closer inspection the liquor was slightly sweet and looking at the ingredients list it contained dextrose as sweetener… undoubtedly wheat derived since corn dextrose has gotten expensive.

        While 99% of wines are probably safe and I routinely “risk” a glass of wine, I’d rather know it’s ok than worry about a week of pain and misery.

        I am very leery of supporting mandatory notices of any substance. Sulfites being a prime example of how things have gone very wrong.

    • Steve, on a side note, have you come across wines that cause problems for you? I have a few friends that are gluten sensitive and don’t have problems drinking wine, but I am sure there are others that have had reactions.

      • I have not been able to definitively say gluten in wine has been a problem. Usually I have wine with food and the food is far more likely to have a cross contamination issue (unless it’s at home).

        To be honest I’m more likely to have issues with Biogenic Amines than gluten in wine, which is why I believe in some sulfite in wine.

    • The responses have caused me to go do the homework on barrels and I don’t think they’re much of an issue:
      - A barrel holds 225L or ~225,000 G of wine. (59Gal or 472 lb)
      - High Gluten flour is 14% gluten by weight
      - cup of flour weighs in at 125G
      - to reach 20PPM would require at least 4.5g or 1/4 cup of flour.

      Even for a new barrel (one that has been rinsed out thoroughly) that’s a lot of flour.

      Elizabeth, I’m not sure why you’d fine a wine with flour and haven’t seen any reference to it as a fining agent.

      http://www.traditionaloven.com/conversions_of_measures/flour_volume_weight.html
      http://www.pizzatoday.com/Buckets/TomLehmann/gluten-is-important-to-dough

  3. Elizabeth says:

    Great post and great points. I think you have a particularly good point about gluten-free labeling potentially causing consumers to wonder if wine is not generally a gluten-free product. As Steve pointed out, the wheat paste used in the barrels may cause problems for some people, and I think some winemakers use wheat products as fining agents, so there are potential problems there, but without testing the parts per million it’s hard to say for sure. It’ll be interesting to see where this goes.

    • It would be interesting to see the percentage of winemakers using wheat products as fining agents…and based on Steve’s comment, I wonder if barrel makers would alter the way they seal barrel heads if this issue was brought to light. Agreed, it will be interesting to see where this goes…!

  4. Jo Diaz says:

    Would love it. I’m living in a gluten free world, as much as possible… along with organic. Talk about being finicky, I know…

  5. Catie says:

    It just so happens gluten was a big topic at dinner I hosted last night. My sister is a pastry chef and their catering company has an area where only gluten-free products are prepared (no cross-contamination of wheat flour). Overall their kitchen prepares food for over 400 college students. They prepare gluten-free products for a minimum of about a half-dozen gluten intolerant staff/students, yet the catering staff sees it overall as a trend based on their findings and the daily food they prepare. More students than usual will start out the year fussing they are gluten intolerant, but as the year progresses they tend to be less interested in the gluten free products, change their minds about their gluten allergies and grab more of those tasty pastries, cookies and pasta made with traditional wheat flour.

    I wish there was a font that could show me rolling my eyes, but here we go again. Sulfites, anyone? To me it reeks nothing but the same sulfite hysteria we faced a few years ago. Everyone was “allergic to sulfites,” denying red wine, claiming it bothered their stomachs (allergy to sulfites is typically breathing/asthma related) while stuffing frozen fries and other processed foods down their gullets. They were claiming they could only drink white wine, because of all of the sulfites in red wine (ummm … white wine has more sulfites than red wine)

    I have specific food allergies and I feel it is my responsibility to acknowledge them, get educated about them and not expect the government to do it for me.

    • I totally agree with you on the sulfite hysteria!

    • Catie,
      I completely agree with you about educating oneself about managing a chronic health issue, however education doesn’t help if you can’t identify foods that contain gluten.
      As background because of the special nature of alcohol and our American society all claims made on a wine label require TTB authorization. The TTB is responding to an industry request to be able to add gluten free labeling. The FDA is also regulating based on pressure from consumer advocacy groups (not on whim) and is actually doing a very good job of defining under what circumstances a manufacturer can advertize a feature of their product and insuring consistent marking of that feature.
      There are a huge number of hidden sources of gluten in the ingredients and many more cases of gluten contamination in processing (that are not labeled).
      The TTB has pointed out to the wine industry that there may be hidden sources of gluten in our basic ingredients (yeast, enzymes, etc). These components are not labeled as to their gluten status.

  6. It is an indication that there might even be a controversy about “gluten-free” labeling on wine labels that our culture is in its final decadent death-throes. There’s no gluten in wine, at least there should not be, and presumably most people understand this. (Coopers may use a small amount of wheat flour in helping seal joints in wood tanks or barrels, but these potential levels of gluten are truly at the almost theoretical, sub-homeopathic level.) Advertising that wine contains no gluten is as commendable as suggesting that no dwarves were harmed in the production process. (That would be a reasonable assumption, and can be presumed, no?) Should any foodstuff, potential comestible (water, soft drink, etc.) that contains no gluten whatsoever carry a gluten-free label? I don’t think so, but maybe that’s just a question of personal aesthetics. Conversely, should every product that contains gluten be compelled to carry a gluten warning? Likewise, I don’t think so. (And this is from someone who does his best to try to avoid gluten wherever it lurks.) The labeling law currently provides for the inclusion of any truthful statement. It is truthful that wine does not contain gluten, but to state so on the label is just a waste of space, a connerie, in my humble opinion.

    • As a winemaker who is always breaking new ground and setting precedent in the wine industry, I appreciate your candid response Randall. In the past, you have embraced full disclosure of ingredients and production techniques, so its enlightening to see where you sit on the fence on this issue. Thanks for stopping by.

  7. David Rossi says:

    The whole GF thing is still up in the air. What made 20ppm the number? Is this too high, too low? What is the real number of Celiacs disease sufferers? Estimates range from 1-10%. What is gluten intolerance- A simple rumbly in your tumbly, or anaphylactic shock? How many people are dying every year from this?

    Clearly this is a serious issue for some and not to be taken lightly, but as a public policy issue we know almost nothing.

    It just shows you how reactive we are as a culture that the topic of Gluten Free in(of all products) wine makes our collective radar.

    I know of Certified Gluten Free products(GF certified-below 20ppm tested) are made in large bakeries that use wheat in other products in the same plant in the same room. This is acheived through following standard sanitation protocols. To get above 20ppm gluten in a winery? Impossible.

    • Great questions – I have no idea where the 20 ppm number came from. Someone pulled a number out of a hat for all I know.

      I was talking to another winemaker which basically agreed it was impossible for a winery to get above (or near) 20ppm.

  8. NoGlutenEver says:

    The sulfite info was helpful.   My spouse has problems with many GF foods at the 20 ppm level, but other foods, certified by the CSA at 5 ppm suit him just fine.    I have been trying to dtermine why he does fine with white wines but not red.  He does fine with Hard ciders which say they have sulfites.   So, i suppose sulfites are not the problem.

    What is it about red wine?  Does it have too much gluten for him or is there some other variable we are overlooking.   He does not believe in homeopathy, I can assure you.  He does react react  and swiftly to casein. 

    There are some studies that show that many celiacs do not heal up even on a strict GF diet.  http://www.celiac.nih.gov/TissueDamage.aspx
    I think this may mean that the 20 ppm limit is too high for some celiacs.  The FDA compiled a risk assessment report:
    http://www.fda.gov/downloads/Food/ScienceResearch/ResearchAreas/RiskAssessmentSafetyAssessment/UCM264152.pdf

    the big problem with the research thst shows that most celiacs can handle 20 ppm is that the research participants are most likely to be the healthiest celicas out there.

    At the end of the day, i suspect that you can put a GF label on wine and it will only tell me that my husband can try it, but it may not work for him. His friends and relatives will buy it for him and he may or may not get sick drinking it. Knowing there was no flour on the barrel or even in the winery would be a more interesting variable.

    So if you know if any stainless steel barrelled, non casein fined wines that are actually drinkable, we are open to suggestions.

  9. NoGlutenEver says:

    I forgot to address tannins. He does fine with smoked meats and very dark chocolate (casein free) even in large quantities. He can eat a pound of pulled pork in a sitting.

    He doesnt have a problem with vanilla or tea. Those are the main sources of tannins in his diet that I am aware of.

    • Hi NoGlutenEver, thanks for chiming in. You pose many great questions, of which I have very few answers but of course, I have an opinion on the subject having done my share of research. But please consult a doctor for advice!! I’m not a doctor nor do I play one on the Internet!

      Wine has many amino-based compounds including Tyramines and Histamines, which can trigger a wide range of symptoms from nausea, headaches and hot flashes to respiratory disorders and high-blood pressure for many wine drinkers.

      Subsequently, there are impurities called “Cogeners”, which are organic molecules that develop during the fermentation process. Wines with higher concentrations of Cogeners are more prone to cause illness and an interesting fact is that lower quality wines will typically have higher levels of Cogeners (hint, hint: drink high-quality wines and see if the reactions differ)

      One piece of discovery which I find interesting because it ties into your question about your husband having problems with red wines (and not so much with whites) is regarding amino-based compounds—they naturally turn up during malolactic fermentation (ML), which is a secondary fermentation process red wines go through. Not all whites go through ML – this is a decision made by the winemaker, which gives them a buttery flavor. The malolactic fermentation process kindles tyramines and histamines, which can cause adverse reactions for many wine drinkers. It might be interesting to try a high-quality red wine that was fermented/ cellared in stainless steel. I have a query out to find some examples, so stay tuned…

      I might also recommend reading a second article which talks about a study done in ’08: http://enobytes.com/2008/03/31/mars-device-to-ease-adverse-wine-effects/ but as far as I know, there are no conclusive studies that link biogenic amines with red wine intolerance. Also read the comments on this post carefully as they provide some good information. This has probably raised more questions than answers, but I hope I pointed you to some good educational information.

  10. Quinton says:

    Great post and inspirational for many of my friends that can’t drink wine for various reasons. I’ll pass the information along.

  11. Leo says:

    This is an interesting topic as I always attributed wine as a gluten-free product. I’m curious to know which direction the industry will go on labeling. I don’t think it would be advantageous to call out something that is obvious.

  12. Dorian says:

    You made a few fine points here which are relevant. I’m not sure where the industry will land on gluten-free labeling but I’m thrilled you bringing this discussion to the forefront. It’s better to deal with it ahead of the curve rather than dealing with the repercussions.

    • Ahead of the curve is definitely where we want to be. I think it is great to give everyone a forum to voice their opinions and to hash out issues that are relevant and fitting while shaping and influencing those that are the ultimate decision makers. Cheers!

  13. Jesse Owens says:

    I do not even know how I ended up here, but I thought this post was great. I loved the interaction between comments. Cheers!

  14. Sara Dewit says:

    Very nice post. I have a friend that has problems with Gluten. I’m not sure if he has problems with wine but I plan on sending this article along.

  15. Renato Carin says:

    I’m still learning from you, as I’m making my way to the top as well. I absolutely enjoy reading everything that is written on your blog. Keep the tips coming. I enjoyed it!

  16. Loreen Mccullock says:

    Thank you for the auspicious writeup. By the way, how can we communicate?

    • enobytes says:

      Hi Loreen, the best way to communicate is to add a comment to the blog! I’d be happy to follow up via email if you prefer a direct response regarding personal inquiries.

  17. Kallie Frost says:

    I really found some interesting debate in this article. I am leaning towards no labeling unless someone can point out a good reason to add it!

  18. Nate Wall says:

    With all the talk about avoiding potential for gluten in red wines due to barrel aging (although keep in mind that several whites are more often than not fermented and/or aged in oak barrels as well – Chardonnay being a prime example), looking for stainless steel reds is not the only answer. Many winemakers are re-discovering the use of concrete tanks for fermentation and aging. Tanks can now be poured with porosities which supposedly come close to mimicking that of oak barrels – so you can get some of the benefits of oak aging without the oak (or possibly gluten).

    Just another thing to be looking for.

  19. NoGlutenEver says:

    Thank you so much for a very helpful comment! We don’t have a lot of experience with whites, because he prefers reds, but he has on occasion tried an “unoaked chard.”

    Hope to try the Torbreck Cuvee Juveniles sson; he’s clearing his schedule a bit.

  20. NoGlutenEver says:

    Torbreck Cuvee Juveniles – this one worked and he liked it.
    He’s also tried the Big House cab and the Pinot = those seem fine and are offered as a house wine at a restaurant he likes and that can handle no gluten, no dairy.

    Black Box did not work.
    Franzia worked fine, but he didn’t like it.

    He can drink wines and ciders with sulfites.

    He used to like things like Barbera and Malbec.

    • enobytes says:

      I am thrilled the Torbreck Cuvee Juveniles worked out for him…if I come across other suggestions I’ll let you know.

  21. NoGlutenEver says:

    http://www.glutenfreedietitian.com/newsletter/2012/10/10/gluten-content-of-wine-aged-in-oak-barrels-sealed-with-wheat-paste/

    Latest info on wheat sealed barrels and testing for gluten.

    I know he likes Merlots, perhaps he can try them again with more confidence.

    • enobytes says:

      This is great information, thanks NoGluten! I hope the Merlot works…Keep us posted! By the time were done, we’ll be able to write our own scientific report :)

  22. Hannah says:

    Hello All!
    The consensus among the medical community is that Celiacs should not exceed .02ppm of gluten a day. (As a point of reference, one bread crumb contains between 34-50ppm of gluten). Could this be on the low end, perhaps, but since the alternative is autoimmune disorders, fatal cancers, neurological complications, etc., it seems best to error on the side of caution. This is one reason why gluten free labeling can be so dangerous for celiacs, as legally, producers are able to grossly exceed this amount. If there is any question that something was produced with a gluten containing agent, avoid it! Even if you are not physically reacting, inflammation is still occur and your body is still destroying its intestinal walls.

  23. NoGlutenEver says:

    Living Without December/January 2013 issue
    Wine. Vino. Vin. A toast to safer sipping
    p. 26

    This was a great writeup of all the possible issues in wines. Sulfites, tannins, histamines, fining agents were all discussed. Pesticides, yeast and intolerance of alcohol itself were also mentioned.

    I found the pesticide part to be really interesting because wheat is an allowable inert ingredient. http://www.epa.gov/opprd001/inerts/section25b_inerts.pdf

    The article says that grapes are not washed before pulping, so insecticide residue is a possibility. What do you think? Are grapes not washed?

    Then barrel practices were discussed. Here’s some interesting info from that section – A wheat based paste is used to lubricate the barrel head seal. Paste is applied to the top and bottom of the barrel and then the barrel is washed in warm water for 30 minutes. . The barrels are shipped to the winemakers where they are washed again because the barrels must stay swollen to stay tight.

    A “neutral” barrel has been used at least 3 times. Rhone varietals often use neutral barrels. So these may also be promising to try.

    • enobytes says:

      Thanks for the additional info NoGlutenEver. I would assume that washing grapes is not the norm (may cause diluting) but maybe a winemaker can chime in.

      • Grapes are not washed, doing so would probably not be that effective given that most wine grapes produce tight clusters and there would be difficulty removing anything except for small amount of exposed surface. The most common late season “pesticides” (usually fungicides) are naturally occurring bacteria which would be grown in wheat free media.

  24. There are finally a few studies emerging that measure the gluten contained in wine samples.
    https://www.glutenfreewatchdog.org/blog.php?id=8

  25. There seem to be two issues here concerning gluten:
    Firstly, the possible sources of gluten in wine. We at Festival Wines are not aware of any of our wines being fined with anything containing gluten. Most of our producers use bentonite (a form of clay) and so are suitable for vegans in that they avoid the usual gelatin, isinglass, egg whites or dairy. It seems the main source of gluten may be barrels and the sealants used in/ on them. It would seem that this would be a negligible amount, but perhaps enough for some to react. On this basis the safest bet would be to look at how wines are stored: to minimise risk the use of stainless steel has to be better than barrels.
    Secondly, the labelling: currently the only additive that is required to be mentioned on the label is sulphites and even then the amounts involved do not need to be stated. There are several hundred additives allowed, where do we stop? Many producers do not state that their wines are organic or suitable for vegans or whatever because either it is of little interest for them or they see it as a negative marketing issue – they are often solely interested in producing the best possible wine.

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