Guide · Allergens
Cereals containing gluten — and which cereals are gluten-free
Gluten sits at the very top of the allergen list — as number 1 of the 14 allergens. Two things get confused here: which cereals are affected, and when a product may be called “gluten-free”. Both are settled below, with the exact thresholds.
What are cereals containing gluten?
Gluten is the protein that makes dough elastic and bakeable. For people with coeliac disease or a wheat allergy it is a problem. That is why “cereals containing gluten” is number 1 in Annex II of the FIC Regulation (Regulation (EU) No 1169/2011).
The cereals concerned
Annex II no. 1 names them: “Cereals containing gluten, namely: wheat (such as spelt and khorasan wheat), rye, barley, oats or their hybridised strains, and products thereof”.
| Cereal | Note |
|---|---|
| Wheat | including spelt and khorasan wheat (kamut) |
| Rye | — |
| Barley | also relevant in malt and beer |
| Oats | a special case — see below |
| Hybridised strains | crosses of the species named (triticale, for instance) |
Worth stressing: spelt and khorasan wheat are kinds of wheat — so they contain gluten. “Ancient grain” or “spelt” is no indication of being gluten-free.
The four exceptions in Annex II no. 1
The entry carries four exceptions that are easy to overlook. They matter in practice, because these ingredients are everywhere:
- “wheat based glucose syrups including dextrose”
- “wheat based maltodextrins”
- “glucose syrups based on barley”
- “cereals used for making alcoholic distillates including ethyl alcohol of agricultural origin”
These do not have to be declared as the gluten allergen. Everything else made from the cereals above does.
Which cereals are naturally gluten-free?
The other side is just as important. These cereals and pseudocereals contain no gluten by nature and are suitable for a gluten-free diet in coeliac disease.
| Type | Naturally gluten-free |
|---|---|
| Cereals | Rice, maize, millet |
| Pseudocereals | Buckwheat, quinoa, amaranth |
Flours made from them (rice, maize or buckwheat flour) are gluten-free as well. Oats are the well-known special case — low in the relevant proteins by nature, but usually contaminated with gluten-containing cereals in practice.
The special case of oats
Oats contain very little of the protein that is critical in coeliac disease. They are listed all the same, because in farming practice they are almost always contaminated with wheat, rye or barley — shared fields, mills and transport.
Regulation (EU) No 828/2014 deals with this expressly: oats in a food presented as gluten-free or very low gluten “must have been specially produced, prepared and/or processed in a way to avoid contamination by wheat, rye, barley, or their crossbred varieties and the gluten content of such oats cannot exceed 20 mg/kg”.
“Gluten-free” vs “very low gluten” — the thresholds
Both statements are legally defined and tied to fixed limits by Regulation (EU) No 828/2014, which has applied since 20 July 2016:
| Statement | Maximum gluten content |
|---|---|
| “Gluten-free” | “no more than 20 mg/kg of gluten” |
| “Very low gluten” | “no more than 100 mg/kg of gluten” |
What counts is the content “in the food as sold to the final consumer”. “Very low gluten” additionally requires that the wheat, rye, barley or oat ingredients “have been specially processed to reduce the gluten content”. Other wordings — “low in gluten”, or private logos with no basis — are not regulated and can mislead.
How to label cereals containing gluten
In the list of ingredients on prepacked food, the particular cereal has to be named (“wheat flour”, “barley malt”) and emphasised under Article 21(1)(b) — usually in bold. That is mandatory and applies to every product with gluten-containing ingredients.
The claim “gluten-free” is a separate matter: it is voluntary, and only permitted within the thresholds above. For food sold without prepackaging, Article 44(1)(a) makes the allergen particulars mandatory; Article 44(2) leaves the means to the Member States, which in Germany is § 4 LMIDV. See allergen labelling in restaurants.
This article is general information and does not replace legal advice. What counts is the wording of the regulation as it applies at the time (Annex II no. 1 of Regulation (EU) No 1169/2011 and Regulation (EU) No 828/2014). The English text of the Regulation is quoted from the consolidated version of 1 January 2018 on EUR-Lex.