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Gluten Free Chia Charge and Flapjacks -There is no wheat added to our ace Chia Charge flapjacks, and oats don't contain gluten so what is the problem?

March 18, 2015

I get asked this a lot, and have been meaning to put this information out for a while, (this has been written in March 2015).

There is no wheat added to our ace Chia Charge flapjacks, and oats don't contain gluten so what is the problem? -  they can't be called gluten free (GF) because of legislative definitions on the subject.


Not everyone has the same sensitivity to gluten or wheat that the legislation prescribes, to be legally GFThis is a response that I emailed to a customer who asked today about GF flapjacks.

Hi Nikki

The quick answer is that I can't make a GF declaration because of legislation, I can only call the chia seeds gluten free currently, I have pasted below the longer answer that I hope helps you make your own decision, have a great day and thanks for emailing me.

Only the chia seeds can be described as gluten free, the problem is the testing and manufacturing regimes required, plus the need for using gluten freeoats in the flapjacks.


There is no gluten or wheat added to any of my products, but because of the onerous testing required to be able to label things GF I just don't bother declaring it (gluten free).

I've pasted below, what is in effect my position on Gluten, which I recently wrote for my Polish distributor.

It is not a quick answer, so apologies for the length of this note.

GF is not a straightforward subject, especially in the UK where legislation creeps into everything and often at the expense of common sense. Although I have to agree the line needs to be drawn somewhere and then we just have to obey the law.

Oats and Flapjacks
Gluten does not occur in oats (the cereal used in flapjacks) however it does contain 2 other proteins avenalin and avenin, and it is well known that fields of oats are often contaminated with wheat growing wild. Thus gluten free oats are those that have been sorted and processed differently to normal oats and have a consequential much higher price, I could use these oats in the CC flapjacks, however the flapjacks are made in a bakery that also makes wheat containing biscuits, so although they would never put wheat I the flapjacks, there will inevitably be flour floating around in the atmosphere containing gluten, so it cannot be avoided currently.

Gluten Free Standards in the UK
In order to declare something that is manufactured GF it is necessary to be able to prove you have tested the ingredients for contamination, each time you make the product, unless your suppliers have guaranteed their GF status. The costs to do the tests would be around £150/ ingredient thus for the Protein Bars (although the factory does not use any wheat at all) it would cost £1000/ production run. This is why some companies set up their own GF factories as it is a cheaper way through if you have the volume to justify the investment..

So here is the list of DF and GF products (although in the UK they cannot be labelled GF due to the level  of proof required).

Dairy Free
Protein Bars
Trail mix
Honey Trail mix
Chia seeds
Coconut and Cashew Nut Butter
Chiaocalate Nut Butter

Gluten Free - we can't declare GF on products because as a small business we can't afford to GF test every ingredient, which is the required legal standard.

The following are wheat and GF (it is only the oats in the flapjacks and the fact they are made in a biscuit bakery that means I wouldn't call them GF).

Protein Bars
Trail mix
Honey Trail mix
Chia seeds
Chia Charge Raspberry drinks
Coconut and Cashew Nut Butter
Chiaocalate Nut Butter

The relevant EU regs state - The European Commission, using recent internationally recognised scientific evidence, has introduced compositional and labelling standards (Commission Regulation (EC) No. 41/2009) that set levels of gluten for foods claiming to be either 'gluten-free' or 'very low gluten', which came into force in January 2012. These levels are:
'gluten-free': at 20 parts per million of gluten or less
'very low gluten': at 100 parts per million of gluten or less - however, only foods with cereal ingredients that have been specially processed to remove the gluten may make a 'very low gluten' claim

Hope that helps......

best wishes
Tim

PS email me with any other questions or suggestions and probably corrections - timtaylor@chiacharge.co.uk