Gluten labelling laws by country (and what they mean for you)

If you are newly diagnosed with celiac disease, food labels can feel like a trap. The hard part is that the rules are not identical worldwide. A label that looks safe in one country can require extra checking in another. This guide compares the key gluten-related labelling rules in the United States, Canada, Australia, New Zealand, and Europe, including what "gluten-free" means (in ppm) and which grains must be declared.

1. The big picture: what "ppm" means

"ppm" means parts per million. For gluten, it is a way to express tiny amounts: 20 ppm means 20 milligrams of gluten per kilogram of food. Many countries set 20 ppm as the maximum allowed for a "gluten-free" claim. Australia and New Zealand are stricter: "gluten-free" means no detectable gluten using available test methods.

2. Quick comparison table

3. United States (FDA)

In the US, "gluten-free" is a regulated claim for most packaged foods. The FDA standard is less than 20 ppm gluten. If a product uses a gluten-free claim, it also cannot contain gluten-containing grains (wheat, barley, rye, triticale) unless they are processed to remove gluten and the final food still meets the standard.

The biggest practical issue for new celiacs is allergen labelling: wheat must be declared as a major allergen, but barley and rye do not. That means a product can have no wheat allergen statement and still contain barley malt, malt extract, or rye. You must read the ingredient list.

• FDA gluten-free rule (20 ppm): FDA: Gluten and Food Labeling
• US major allergens (wheat included): FDA: Food Allergies

4. Canada (Health Canada and CFIA)

Canada broadly aligns with the 20 ppm gluten-free threshold used internationally. Canadian allergen and gluten source disclosure is generally more celiac-friendly than the US because gluten sources are expected to be declared clearly in plain language.

Oats are the big difference. Canada allows specially produced, uncontaminated oats in gluten-free foods (if the overall food meets the gluten-free standard). So you may see oats in gluten-free products in Canada, and that can still be legitimate.

• Health Canada: gluten-free and oats position: Health Canada: Gluten-free diet guidance (includes oats)
• CFIA: food allergens and gluten sources labelling: CFIA: Allergen labelling

5. Australia (FSANZ)

Australia uses a stricter definition than North America and Europe. Under the Australia New Zealand Food Standards Code, a food labelled "gluten-free" must have no detectable gluten. Practically, that means if gluten is detected in testing, it cannot be labelled gluten-free.

Australia also does not allow oats in foods making a gluten-free claim. So if you are used to seeing "gluten-free oats" elsewhere, this is where the rule changes.

Allergen labelling in Australia is also quite clear: cereals containing gluten must be declared, and the modern "plain English" allergen labelling updates push clearer, more consistent naming and presentation.

• FSANZ: Gluten-free definition and conditions: FSANZ: Gluten claims (Australia and New Zealand)
• FSANZ: allergen labelling changes (plain English): FSANZ: Food allergens and labelling

6. New Zealand (FSANZ)

New Zealand follows the same Food Standards Code as Australia. So the key points are identical: "gluten-free" means no detectable gluten, and foods using a gluten-free claim cannot include oats.

Like Australia, New Zealand requires clear allergen declarations for cereals containing gluten. If you are travelling or importing products, treat NZ gluten-free claims as stricter than a 20 ppm system.

• FSANZ: Gluten claims (applies to NZ too): FSANZ: Gluten claims

7. Europe (EU)

In the European Union, "gluten-free" is defined as 20 ppm or less. EU labelling law also requires a set list of allergens to be highlighted in the ingredients list, including cereals containing gluten (wheat, rye, barley, oats, spelt, kamut, and hybrids). That makes label scanning faster because gluten grains are typically emphasized in the ingredients.

You may also see "very low gluten" in some contexts, but as a celiac, the practical approach is to stick to products clearly labelled gluten-free and always read any precautionary "may contain" statements.

• EU gluten-free standard (20 ppm) summary (UK FSA page referencing EU rules): UK Food Standards Agency: Gluten-free and allergen labelling
• EU allergen list and highlighting requirements: European Commission: Food allergies and intolerances

8. What to do with this as a new celiac

The practical takeaway is simple: learn your country’s "gluten-free" threshold, then learn what the allergen statement does and does not protect you from. In the US, the allergen box mainly protects you from wheat, not barley or rye. In Canada and Europe, gluten cereals are more consistently declared. In Australia and New Zealand, a gluten-free claim is stricter and excludes oats.