Gluten Free, Gluten Friendly, GFO or Wheat Free – Are We Creating More Confusion?

Written by Caroline Benjamin MIH of Food Allergy Aware, following her session on the Feed Your Business Stage at Glee Birmingham 2026, Food Safety & Allergen Awareness: Protecting People and Reputation.

Following my presentation at Glee Birmingham on 8 September 2026, one topic prompted some particularly interesting conversations: the terminology businesses use when communicating gluten-free food.

Gluten Free. Gluten Friendly. GFO. GFA. NGCI. Wheat Free. Coeliac Compliant.

We are seeing more and more terms appearing on menus, labels and websites – but what does the customer actually think they mean?

This was one of the key challenges I raised during my Glee presentation, Food Safety & Allergen Awareness: Protecting People and Reputation.

Are we making things more complicated?

One of my slides deliberately put several commonly used terms alongside each other: Gluten Free, Gluten Friendly, GFO, GFA, NGCI and Wheat Free. They may make sense internally to the business, but will the customer interpret them in the same way?

Different terminology can mean different things, and importantly, “wheat free” is not the same as “gluten free”. Uncertainty can also have another unintended consequence: businesses become so concerned about making a claim that they remove choices altogether rather than putting appropriate controls in place to manage the risk.

Clear and consistent language supports a safer conversation. “Coeliac compliant” isn't the legal term, gluten free is. At Glee I shared an example of a menu using the wording “coeliac compliant” alongside a gluten-free menu. My message was simple:

“Coeliac compliant” is not the legal term. Gluten free is.

Creating alternative terminology does not necessarily make a business safer and can leave customers trying to work out what the terminology actually means. For gluten-free claims, there is a defined threshold: gluten free means no more than 20mg/kg (20 parts per million) of gluten in the final food. That leads to one of the biggest areas of confusion I have encountered when speaking to hospitality businesses.

Do caterers have to test every gluten-free dish?

No.

This was an important clarification I received directly from the Food Standards Agency and included in my Glee presentation.

Testing is not mandatory. Testing can be a beneficial verification check, but the critical requirement is having strict controls in place to limit unintended gluten presence.

The FSA examples highlighted in my presentation included segregation, preparation controls, utensils, cleaning and hygiene. If the risk of cross-contact cannot be sufficiently mitigated, then the business should not make the gluten-free claim.

There is also no requirement for accreditation simply to make a gluten-free claim. The Food Business Operator (FBO) needs to decide what controls, monitoring and verification are necessary to support the claim. For hospitality businesses, this distinction is extremely important. Having gluten somewhere in your kitchen does not automatically answer the question. What matters is whether you can adequately manage the risk for the particular food you are describing as gluten free.

Claim = responsibility

One of my key messages at Glee was:

The claim is not the problem – an unsupported claim is the risk.

If an FBO uses the term “gluten free”, it must be satisfied that the food meets the threshold of no more than 20ppm, your documented controls should support that decision. Where cross-contact cannot be sufficiently mitigated, the FSA advised that a gluten-free claim could be misleading and potentially breach food law.

So rather than asking:

“Are we allowed to say gluten free?”

I would encourage businesses to ask:

“What evidence do we have to support saying gluten free?”

That is a much more useful question.

What should an FBO have in place?

For loose food, routinely laboratory testing every meal is not mandatory. However, this does not mean that an FBO can simply make the claim without evidence behind it. This is where your Food Safety Management System, Allergen Policy and Standard Operating Procedures (SOPs) become so important.

Depending on the operation, controls may need to address purchasing and approved suppliers, product specifications, deliveries, storage and segregation, recipes, allergen matrices, preparation, equipment and utensils, cleaning, cooking, service and customer communication, and they need to be documented.

Earlier in my Glee presentation I described this as moving:

FSMS → Allergen Policy → SOPs → Training → Implementation → Monitoring → Verification.

The policy cannot just sit in a folder. There needs to be evidence that the controls are understood and actually happen in practice. Gluten free is different from other “free-from” claims.

There is another important distinction that can easily get lost, not all “free-from” claims work in the same way.

As highlighted in my presentation, gluten free has a defined threshold of no more than 20ppm in the final food. An allergen free-from claim, such as “nut free”, is different. Currently there isn't an equivalent 20ppm threshold for other allergens; such a claim is treated as a guarantee that the food does not contain that allergen. 

This is why businesses need to know the claim they are making rather than treating “free from” as one universal definition.

I also covered “very low gluten” at Glee. This means less than 100ppm, but it is not a general hospitality option. It relates to specified gluten-containing cereal ingredients that have been specially processed to reduce their gluten content. Communication is just as important as the wording. Good procedures are essential, but they are only half of the customer journey.

Communication is key. A food business should not make an absolute promise that there can never be accidental cross-contact. Instead, staff need to be confident enough to explain the procedures that are actually in place.

For example:

“We use gluten-free ingredients for this dish and have procedures in place to minimise cross-contact, including separate preparation controls, clean utensils and equipment. We do also handle gluten-containing foods within the kitchen., please speak to a member of the team if you have any queries”

That gives the food hypersensitive customer useful information. They can ask further questions about the processes and make an informed decision about whether they are comfortable eating the food. That is far more valuable than simply saying:

“We can't guarantee anything.” What does that actually tell the customer?

Equally, phrases such as “it should be okay” or “it's gluten friendly” can create uncertainty rather than confidence. Staff should know what the controls are, what they can confidently communicate and when they need to stop and ask someone else.

This links directly to another point from my presentation: training does not automatically equal competency. Staff need to be able to apply their training during a busy service, know where the current allergen information is and know when to escalate a question rather than guess.

A real example from Glee

Interestingly, the subject came to life again after my presentation.I spoke with a cake exhibitor using the term “gluten friendly”. During our conversation, I was told that the product was actually tested for gluten. It immediately raised the question: If you have the controls and evidence to substantiate a gluten-free claim, why use terminology that is less clear to the customer?

What does “gluten friendly” mean? Is it gluten free? Is it low gluten? Is it made without gluten-containing ingredients? Or is it simply a warning that cross-contact may occur?

If the business and customer interpret the phrase differently, we have created another communication risk.

The takeaway from Glee: clarity, controls and confidence

My conclusion from my experiences is that we need to stop making allergen communication unnecessarily complicated. Gluten free is the legally defined term.

For FBOs selling loose food, testing is not mandatory, although it may form part of verification. What is essential is that the business has appropriate controls to support the claim and can demonstrate how it is managing the risk of cross-contact.

If you cannot sufficiently mitigate the risk, don't make the gluten-free claim. If you can, document what you do, train your team, monitor whether the controls are being followed and verify that they work.

Then communicate confidently with the customer. Don't promise something you cannot substantiate. Instead, explain your processes, answer their questions and give them the information they need to decide whether they are comfortable eating with you. That is what builds confidence.

Don't just say it or do it → document it → verify it.

Protect the customer → protect your staff → protect your reputation.

Need help reviewing your allergen procedures?

Food Allergy Aware works with hospitality and foodservice businesses to review Food Safety Management Systems, Allergen Policies, SOPs, training, allergen communication and gluten-free procedures.

Our Food Allergy Aware Certification can also provide independent verification of your approach, including documentation, training, communication, suppliers and service, with policy review, audit and mystery dining incorporated into the process.

If my Glee presentation raised questions about your own procedures or the claims you are making on menus and labels, get in touch and let's have a conversation

Caroline Benjamin |  consultancy@fatc.co.uk | 07732637292