The FDA’s final rule on gluten-free labeling was published in the Federal Register on August 5, 2013, with a mandatory date for compliance of one year thereafter, or August 5, 2014.  But the FDA makes clear that this is an outside date.  "However, as stated, FDA anticipates that manufacturers are likely to follow the requirements of the final rule as soon as possible."  (emphasis supplied).

Imagine you’re a consumer who suffers from the travails of celiac disease.  Indeed, let’s not imagine one, let’s take a real one, a paralegal in my office who always orders the gluten-free option at our monthly lunches.  Here’s what she says is important about the rule:

As a celiac grocery shopper for the last three years, I was limited to the outside aisles.  But now that food manufacturers are producing more gluten free products, I can once again shop in the once barren inner aisles.  Clear, uniform rules on gluten free labeling are important.  It means less time spent reading labels and less risk of a gluten reaction (usually lasting about 10 days).  I can spend more time with family and friends and don’t have to worry about my reading glasses.

When she talks about "outside aisles", she means the meat, dairy and produce departments.  The inner aisles are prepared and packaged foods.  She’s looking forward to shopping in the inner aisles again like everyone else. 

Here’s the deal:  as the FDA knows, most of the goods that comply with the new rule (i.e., do not have wheat, rye or barley as an ingredient and contain less than 20 parts per million of gluten) are already known to be gluten-free to manufacturers.  But right now, a "gluten-free" label does not need to be one that complies with the rule, yet a consumer like my paralegal has no way of knowing this until next August. 

Why make her wait? 

And wouldn’t a manufacturer get serious bang for the buck by putting out, as soon as it can, a label that says, in essence, "Gluten-Free:  Complies with new FDA Rule"?  

And do it in big type, so she doesn’t need her reading glasses.  To quote a very wise man, "Make It So".