Gluten labelling continues to cause confusion– especially when it comes to gluten-free products that contain Gluten Free Oats. For food businesses, getting this wrong isn’t just misleading, it can be unsafe and unlawful.
What does the law say?
UK food law requires businesses to clearly declare if a food contains any of the 14 allergens, whether the food is:
- Prepacked
- Prepacked for Direct Sale (PPDS)
- Loose
- Sold online
The legislation defines Oats under Cereals containing gluten
“Cereals containing gluten namely wheat (such as spelt and Khorasan wheat), rye, barley, oats and their hybridised strains and products thereof.” This means oats are legally classed as a cereal containing gluten, even when they are gluten-free.
Gluten intolerance vs cereal allergy
Coeliac disease and gluten intolerance are reactions to gluten, whereas allergies to wheat, barley, rye or oats are reactions to specific cereal proteins.
A gluten-free product (≤20mg/kg gluten) may be safe for someone with coeliac disease, but not safe for someone with an oat allergy if it contains gluten-free oats.
Gluten-free oats must still be clearly highlighted as an allergen.
Labelling matters – everywhere
- Gluten-free oats must be emphasised in ingredient lists
- This applies to prepacked, PPDS, loose foods and online sales
- When selling food online, full ingredient and allergen information must be available before purchase
“Allergen information available on request” is not sufficient online.
Free-from claims carry responsibility
Free-from claims require strict controls and are a guarantee of suitability. If a product contains any of the 14 allergens including gluten free oats, it cannot be labelled free-from the #Top14 allergens.
Where to get guidance
The Food and Drink Federation provides specific information and guidance on free-from and gluten-free claims, which you may find helpful.
The FSA Technical Guidance explains in more detail the labelling requirements: Food allergen labelling and information requirements technical guidance | Food Standards Agency. Please see point 31 for specific guidance on labelling of gluten free oats and point 69 for detail on gluten free labelling. The full guide can be downloaded at the bottom of the page.
For product-specific advice, businesses should speak to their Local Authority Environmental Health team.
Learn more
Watch Food Allergy Aware’s webinar on gluten and allergen labelling:
https://www.youtube.com/watch?v=KRRSJy2UMa4
Clear labelling protects customers, builds trust and keeps businesses compliant – and that’s what free-from should always stand for.
Final thoughts
Clear, accurate allergen labelling is not just about compliance – it’s about trust, safety and inclusion. At the Allergy & Free From Show, we continue to see how empowered consumers are when businesses get this right.
Understanding the following is essential for anyone producing or selling food today.
- Gluten-free does not mean allergen-free
- Oats are still a declarable allergen
- Online information must be complete and transparent
If in doubt – check the guidance, ask your Local Authority, and make allergen safety part of your food culture.
