Are Natural Flavors Gluten-Free?

When you see the term “natural flavors” on a food label, it can be both reassuring and perplexing. It sounds like something that might be wholesome and unprocessed, yet it’s also vague. For those with celiac disease, food allergies, or gluten sensitivity, this ambiguity can lead to an important question: Are natural flavors gluten-free?

So, let’s talk about it – not just as a technical breakdown, but from the heart – from one label-reader to another.

What is Gluten, and Why Does It Matter?

Gluten is a protein naturally found in certain grains, including wheat, barley, and rye. It provides elasticity and structure to foods, helping bread and baked goods rise and maintain their shape. However, for those of us who need to avoid it, gluten can be harmful, causing a range of symptoms and health complications.

For me and millions of others living with conditions such as celiac disease, gluten sensitivity, or an allergy to a gluten containing grain, staying gluten-free is non-negotiable. It’s not a trend; it’s a matter of health.

That’s why understanding food labels is so critical — especially when terms like “natural flavors” can be so frustratingly unclear.

For consumers like us, understanding food labeling – particularly terms like “natural flavors,” and navigating regulatory loopholes created by the Food Allergen Labeling and Consumer Protection Act (FALCPA) and the GRAS (Generally Recognized As Safe) guidelines – are crucial to safely avoiding gluten in our diets.

Understanding the Food Allergen Labeling and Consumer Protection Act (FALCPA)

The Food Allergen Labeling and Consumer Protection Act (FALCPA) is a U.S. law passed in 2004, effective since January 1, 2006, designed to make it easier for consumers, especially those with food allergies, to identify potential allergens clearly on food labels. This act requires food manufacturers to explicitly state the presence of nine major food allergens:

• Eggs
• Fish
• Milk
• Peanuts
• Sesame
• Shellfish (crustaceans)
• Soy (soybeans)
• Tree nuts
• Wheat

Does FALCPA Cover Gluten?

FALCPA directly addresses wheat labeling, which is beneficial for individuals avoiding gluten. However, it doesn’t specifically cover barley and rye—both of which contain gluten. Therefore, the presence of gluten from barley or rye could potentially remain undisclosed under general “natural flavors.”

What are Natural Flavors?

According to the U.S. Food and Drug Administration (FDA), natural flavors are substances derived from plant or animal sources. These can include fruits, vegetables, herbs, spices, or even meat, seafood, and dairy. The purpose of natural flavors is to enhance or impart flavor without being the primary nutritional component of the food.

Natural flavors are found in a wide range of products, from beverages to baked goods, snacks, and even supplements. Their exact composition isn’t typically disclosed on labels, which can make things tricky for those with dietary restrictions.

“The term natural flavor or natural flavoring means the essential oil, oleoresin, essence or extractive, protein hydrolysate, distillate, or any product of roasting, heating or enzymolysis, which contains the flavoring constituents derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, seafood, poultry, eggs, dairy products, or fermentation products thereof, whose significant function in food is flavoring rather than nutritional. Natural flavors include the natural essence or extractives obtained from plants listed in §§ 182.10, 182.20, 182.40, and 182.50 and part 184 of this chapter, and the substances listed in § 172.510 of this chapter.”

—FDA Labeling Requirement for Natural Flavors

Gluten, a protein found in wheat, barley, rye, and their derivatives, can trigger severe reactions in people with celiac disease, gluten-related allergies, and those with non-celiac gluten sensitivity. While natural flavors may seem benign, the possibility that they could contain gluten is a valid concern.

Gluten-Containing Ingredients Hidden in “Natural Flavors”

Critically, within FDA regulations, specifically Part 184 (GRAS substances), certain gluten-containing ingredients may appear as part of “natural flavors” without clear identification. Key examples include:

You see the problem, right? These ingredients can all hide in that one innocent-sounding phrase: “natural flavors.”

Understanding the Loopholes in Food Labeling Laws

Even more concerning is how the system works behind the scenes.

Current FDA labeling regulations allow gluten-containing ingredients to be legally hidden under the ambiguous term “natural flavors,” creating significant risks for consumers who must strictly avoid gluten. This occurs primarily due to certain loopholes within federal food labeling laws.

Understanding the Loopholes in FALCPA

Although the Food Allergen Labeling and Consumer Protection Act (FALCPA) requires manufacturers to identify any of the  top 9 allergens, including wheat, on the food label of a product, it doesn’t require all sources of gluten, namely barley and rye, to be identified.

Further, federal law permits manufacturers to submit exemption petitions and notifications to the FDA for ingredients they claim should be exceptions to the allergen labeling requirements mandated by the Food Allergen Labeling and Consumer Protection Act (FALCPA). This effectively creates a regulatory loophole, allowing certain allergens to potentially escape transparent labeling, relying heavily on the manufacturer’s own testing and assertions of safety.

A striking example of such circumvention provided by the FDA involves enzyme preparations derived from wheat flour. If such an enzyme is used in products that typically would not contain wheat protein, manufacturers may successfully petition to exempt this wheat-based ingredient from allergen labeling requirements.

“If an enzyme preparation contains proteins derived from a major food allergen and is used in foods that normally do not contain this allergen, such an enzyme preparation may fall under the provisions of FALCPA unless it is granted an exemption from allergen labeling as a result of a petition or a notification. For example, such a situation may occur if an enzyme preparation has been formulated with wheat flour and is intended for use in foods that normally do not contain wheat protein.”

—FDA Guidance on Enzyme Preparations

In other words, the FDA permits scenarios in which wheat—a major gluten-containing allergen—could be deliberately included yet remain undisclosed on product labels. Such exemptions not only undermine the very intention of FALCPA but also place vulnerable consumers at genuine risk, highlighting a clear contradiction between the law’s intended purpose and its regulatory execution (FDA Guidance on Enzyme Preparations).

The FDA explicitly states that petitions submitted for exemption must include scientific evidence demonstrating that the ingredient in question does not provoke an allergic response or adverse reaction in sensitive individuals (FDA Guidance for Industry). Yet, the responsibility and burden of proof rest primarily on manufacturers—raising concerns about potential conflicts of interest or insufficient oversight by regulators.

FDA’s Refusal to Set Allergen Thresholds Exacerbates Risk

Compounding these labeling shortcomings and despite its mandate to protect public health, the FDA refuses to establish a standardized thresholds for allergens in foods within the U.S. (FDA Food Allergies) even though international scientific consensus and action by global authorities.

For instance, the Food and Agriculture Organization (FAO) of the United Nations and the World Health Organization (WHO) have set a specific threshold for wheat allergens at 5 mg per serving, an amount notably higher than what the FDA itself acknowledges as the threshold below which gluten exposure does not cause morphological or clinical adverse effects in people with celiac disease (FAO/WHO Risk Assessment, FDA Health Hazard Assessment).

The FDA’s reluctance to adopt clear and consistent allergen thresholds arguably leaves consumers at risk, depending instead on vague regulatory language and case-by-case evaluations. Such an approach contributes to uncertainty and may lead to inconsistencies in allergen labeling practices, potentially jeopardizing consumer safety, especially for vulnerable groups such as individuals with celiac disease or severe food allergies.

The GRAS Loophole and Manufacturer Self-Regulation

Adding another layer of risk, ingredients listed in FDA’s Part 184 are designated as “Generally Recognized As Safe (GRAS).” Yet, despite the reassuring nature implied by “GRAS,” the actual determination of safety is left largely to manufacturers themselves. According to FDA guidelines, manufacturers – not regulators – have primary responsibility for determining the safety of GRAS ingredients. FDA notification is voluntary, and the agency does not mandate independent oversight or formal approval (FDA GRAS Guidance).

Thus, manufacturers self-determine ingredient safety, a practice criticized by many food-safety experts as an inherent conflict of interest. This self-regulation creates significant concerns around transparency and potential risks to consumers, particularly those with food sensitivities or allergies, such as gluten intolerance or celiac disease.

Here are the Key Points to Consider about Natural Flavors:

1. Source Ingredients: Natural flavors can be derived from grains, including wheat, barley, or rye. For example, barley malt or wheat starch could potentially be part of a natural flavor blend.
2. Labeling Regulations: In the U.S., the FDA requires manufacturers to disclose wheat as an allergen on food labels. This means if natural flavors contain wheat, it should be listed in the allergen statement. However, the other sources of gluten (namely barley and rye) are not covered by this rule, which leaves room for uncertainty.
3. Loopholes in FALCPA: Wheat is the only source of gluten that is covered by FALCPA. Barley and Rye are excluded as that they are not one of the top 9 allergens. Additionally, manufacturers can petition for an exemption from labeling requirements to disclose allergens due to loopholes in the law. Further, the lack of a legal allergen threshold creates a concerning health risk. Gluten-containing ingredients can easily bypass allergen regulations and be hidden under the ambiguous description of “natural flavors”.
4. Loopholes in GRAS: The FDA’s GRAS guidelines allow manufacturers to determine for themselves whether an ingredient qualifies as GRAS without mandatory FDA oversight or approval.

How to Determine if Natural Flavors are Gluten-Free

Navigating food labels can be frustrating, but there are ways to determine whether natural flavors are safe for a gluten-free diet:

1. Look for a Gluten-Free label and/or Certification: Products labeled gluten-free or certified gluten-free have been verified to contain less than 20 ppm (parts per million) of gluten, which complies with U.S. food labeling laws for foods bearing a gluten-free claim. Choosing products that have a gluten-free claim is the safest choice that can be made.
2. Contact the Manufacturer: When in doubt, reach out to the company directly. Many manufacturers have customer service teams that can provide detailed information about their natural flavors and whether they contain gluten.
3. Check Allergen Statements: If the product contains wheat, it should be disclosed under the allergen section of the label. This doesn’t account for barley or rye or any cross-contamination that may have occurred during harvesting, transportation, storage, and manufacturing. So, it’s best to err on the side of caution and avoid the product if the manufacturer does not clarify with a gluten-free statement.

Bottom Line

Unless an item is specifically marked “gluten-free,” you cannot count on it being safe to consume.

The self-policed GRAS loophole combined with the FDA’s refusal to set clear allergen thresholds, while allowing exemptions from the already limited scope of FALCPA creates uncertainty, complicating gluten-free compliance and potentially risking consumer safety.

By looking for gluten-free labels, including those that are certified gluten-free, you can enjoy a wide range of foods with more confidence that you’re likely avoiding inadvertent gluten exposure. When it comes to managing celiac disease, food allergies, or gluten sensitivity, knowing your country’s food labeling laws and exercising due diligence goes a long way toward maintaining your health and peace of mind.

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