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Guide

How to label gluten-free PPDS products

A gluten-free claim does not replace the ingredients list. List every ingredient, emphasise any of the 14 that are present (egg, milk, soya, nuts…), and only claim gluten-free when the product meets the claim rules.

Reviewed against official guidance.SourcesNot legal advice.

The short answer

A gluten-free claim does not replace the ingredients list. List every ingredient, emphasise any of the 14 that are present (egg, milk, soya, nuts…), and only claim gluten-free when the product meets the claim rules.

Emphasise Annex II allergens inside the ingredients list — bold, capitals, colour or underline — as set out in FSA allergen labelling guidance.

How to apply it

A gluten-free claim does not replace the ingredients list. List every ingredient, emphasise any of the 14 that are present (egg, milk, soya, nuts…), and only claim gluten-free when the product meets the claim rules. Emphasise Annex II allergens inside the ingredients list — bold, capitals, colour or underline — as set out in FSA allergen labelling guidance. Walk the product in front of you against the checklist below before you print. The mistake to refuse is: Symbols and claims are not a PPDS ingredients list.

  • Write the full ingredients list first
  • Emphasise remaining Annex II allergens
  • Only add a gluten-free claim when justified
  • Watch oats and “gluten-free wheat starch” carefully

Worked example

Worked example for “How to label gluten-free PPDS products”: take one real SKU you sell this week. Apply the first check — write the full ingredients list first. Then contrast it with emphasise remaining Annex II allergens. Write the name of the food and the full ingredients list from today’s recipe and supplier specs, emphasise every Annex II allergen each time it appears, and only then print. If the pack in your hand does not match that list, it is not ready for sale. (A gluten-free claim does not replace the ingredients list.)

Checklist before you print

CheckWhy it matters
Write the full ingredients list firstFor “How to label gluten-free PPDS products”, “Write the full ingredients list first” is the check that stops the pack drifting from what you actually sell.
Emphasise remaining Annex II allergensFor “How to label gluten-free PPDS products”, “Emphasise remaining Annex II allergens” is the check that stops the pack drifting from what you actually sell.
Only add a gluten-free claim when justifiedFor “How to label gluten-free PPDS products”, “Only add a gluten-free claim when justified” is the check that stops the pack drifting from what you actually sell.
Watch oats and “gluten-free wheat starch” carefullyFor “How to label gluten-free PPDS products”, “Watch oats and “gluten-free wheat starch” carefully” is the check that stops the pack drifting from what you actually sell.

Printing “GF” instead of ingredients

Symbols and claims are not a PPDS ingredients list.

Go deeper

Next: Cereals containing gluten. Wheat, rye, barley and oats naming. Then paste your ingredients into the free generator and confirm allergens before you print.

Questions

Can oats appear in a gluten-free product?
Only when the claim rules and specs allow. Oats are still an allergen to declare when used.
Do I emphasise wheat if it is absent?
No. Emphasise allergens that are ingredients.

Official sources

Everything on this page traces back to these. Where they and we disagree, they are right — tell us and we'll fix it.