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There has recently been so much controversy and discussion regarding oats and gluten-free labelling. In early 2021, while exhibiting at Naturally Good Expo, I was surprised to see some companies claiming that their oat products were ‘Gluten-Free’.  In Australia and New Zealand, the current Food Standards Code states that all oat products must declare gluten allergen.

So let’s talk about this and break down the science and Australian & NZ gluten-free food labelling laws (Oats & Gluten-Free Labelling).⠀

What is gluten and how is it tested?

Gluten is the name given to the protein in wheat, rye, barley and oats that affects people with coeliac disease. Gluten is declared as a food allergen.

Gluten represents the following proteins:

  • Gliadin in Wheat
  • Hordein in Barley
  • Secalin in Rye
  • Avenin in Oats

Food analytical laboratories can currently test for gluten by assessing the gliadin, hordein, and secalin content but not avenin. So when the Gluten-Free analytical test report returns as ‘Not Detected’, it refers to them being free of contamination from wheat, barley and rye (and their hybrids).⠀⠀⠀⠀⠀⠀

Currently in Australia, the food laboratories that test for gluten can measure levels of gluten to a low 3mg/kg (3ppm), which is then reported as ‘Not Detected’. This tight restriction is in contrast to USA, UK and EU regulations that have a much wider testing limit of less than 20mg/kg (20 ppm) to make a gluten-free claim.


Gluten-free claims around the world

Imported Gluten-Free Products

Any gluten-free products imported into Australia or New Zealand from the USA, EU or UK, must undergo testing to prove that they comply with the FSANZ level of ‘Not Detected” otherwise they are not a legal product in Australia and could cause harm to coeliacs and gluten-sensitive consumers. My recommendation is to used an Australian or New Zealand NATA accredited food analytical laboratory as many overseas labs cannot test to the strict FSANZ Not Detected levels.

Tastebuddies Statement of Ingredients VS Summary Statement

Back to Oats…

Tastebuddies Statement of Ingredients VS Summary Statement

However, even with this analytical testing completed for oat products and a report of ‘not detected’, FSANZ Food Standards Code states we are not permitted to make a Gluten-Free claim on any food or drink labels for any product that contains oats as an ingredient.⠀⠀⠀⠀⠀⠀⠀⠀⠀
Oats can NEVER be labelled Gluten-Free in Australia & New Zealand.


Why is this?

The reason for this is documented on Coeliac Australia’s website and what many people don’t realise is that 1 in 5 people with coeliac disease react to the oat protein, avenin, and have similar symptoms to the other 3 gluten proteins mentioned above which are detrimental to their health and wellbeing.⠀


My advice

From all of the above technical information, the labelling advice is:

  • Be careful not to make Gluten-Free claims for Oat products
  • Be mindful that “pure, uncontaminated oats” must never be declared as Gluten-Free and
  • Oats must be BOLDED in the ingredient list and declared in the allergen summary statement as Gluten.


Source: glnc.org.au; coeliac.org.au⠀


If you need help with understanding the food laws, get in touch with me here.


Check out also our previous PEAL blog posts.



This is general information rather than regulatory advice. We, therefore, recommend you seek further advice that takes into account your particular ingredients, products, processing, packaging and other circumstances before making commercial decisions for your business.

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