From gluten-free labeling updates to new state and federal legislation, there have been several important policy developments in recent months affecting the celiac disease community. This article summarizes the most relevant updates and explains what they mean for access, safety, and daily life for people with celiac disease.
FDA Request For Information:
- The Food and Drug Administration (FDA) issued a Request for Information (RFI) in January 2026 to seek public input on the adverse effects of not having barley, rye and contaminated oats clearly labeled on packaged goods. The SSCD is working on drafting comments that will be shared with membership soon. For more information about the RFI and how to submit your input click here.
Recently Passed / Presented US Legislation and Guidelines:
- Accommodating Celiac Disease in Higher Education: Evidence-Informed National Recommendations (Published January 2026): A multidisciplinary panel of 40 stakeholders was convened by the Celiac Disease Foundation to create expert-based and experience-informed recommendations intended to support institutions as they develop strategies to enhance access to GF food, quality of life, educational supports, and student experience for those living with this chronic autoimmune condition. Read the full publication and recommendations here.
- Illinois Allergen Awareness Training Law (Passed December 2025): The bill requires that food managers in Illinois undergo training that includes gluten-related topics. However, way the Act (Public Act 104-0090) was promoted in the media made it seem like all food service providers in the state will be required to complete gluten-free training, which is not the case. Read an overview of what the bill means here.
- Gluten-Free Labeling Requirement Changes: The U.S. Food and Drug Administration (FDA) included updated guidance on existing gluten-free labeling requirements (June 2025). The updates are about stricter enforcement and guidance on existing rules, not new gluten-free definitions. Key Clarifications & Reinforcements from the 2025 Updates:
- < 20 ppm Rule: The core standard remains: foods must have less than 20 parts per million (ppm) of gluten to be labeled “gluten-free”.
- Ingredient Restrictions: Foods can’t contain wheat, rye, barley, or their crossbreeds, or ingredients from them unless processed to remove gluten.
- Processing Clarification: Ingredients like malt (from barley) can be used if processed to remove gluten, but the final product must still be < 20 ppm.
- Enhanced Oversight: The updated compliance program signals increased FDA attention on how companies ensure compliance, including testing methods and supply chain controls for imported and domestic foods.
- Focus on “May Contain”: Guidance addresses the confusing overlap between “gluten-free” and “may contain” warnings, aiming for clearer communication.
- Department of Defense Peer Reviewed Medical Research Program (PRMRP): The PRMRP supports medical research projects that are relevant to enhancing the health, care, and well-being of military families, and the American public. While celiac disease is a disqualifying condition for military service, its prevalence has increased among service members, veterans, and their family members. Celiac Disease has now been included in the annual report since 2023. The 2025 PRMRP white paper from CDF published in November 2025. Read it here.
Recently Proposed Legislation:
- Massachusetts: Read more about these two bills here.
- CAPE Act (Celiac Awareness and Pediatric Evaluation Act) was introduced into MA Legislature in January 2026. Its goal is to establish a pilot program to evaluate routine screening for celiac disease in children.
- SNACCK Act (Safe Nutrition, Allergen, and Celiac Communication for Kids Act) was introduced into MA Legislature in January 2026. The bill focuses on improving transparency and communication around medically necessary diets in schools to support safe participation in the Universal School Meals Program
- The Medical Nutrition Therapy Act (MNT): This is an act to ensure Medicare and Medicaid cover dietitian visits for celiac disease patients (which currently do not). This was recently introduced in the House (November 2025). It is awaiting review, committee action, and votes in both the House and Senate before potentially being sent to the President.
- The Food Labeling Modernization Act of 2023 : Not new, but important to know about. This bill would update front-of-package food labeling requirements, require updates to the ingredients list on packaged foods, and apply consumer friendly labeling requirements, including the disclosure of gluten-containing grains. It is currently stalled and not expected
Read the bill here.
Global Policy Updates:
- FAO and WHO Labeling Update: Nov 2025Food and Agriculture Organization (FAO) and World Health Organization (WHO) updated their compliance program for food labeling. The expert consultation, held from November 3-7, 2025, provided scientific advice to the Codex Alimentarius Commission and national regulators. Below are the key recommendations and implications:
- Reference Dose (RfD) for Precautionary Labeling: A reference dose of 4 mg of gluten per eating occasion was recommended for assessing the risk of unintended gluten presence. This scientific threshold for regulators is not a safe level for individuals with celiac disease. It is intended to guide the use of “may contain gluten” labels when potential accidental gluten in a serving could exceed 4 mg, thereby reducing unnecessary precautionary labeling if the amount is below this threshold.
- Gluten-Free Standard Unchanged: The global standard for “gluten-free” food remains no more than 20 parts per million (ppm), which is considered protective for those with celiac disease.
- Clarified Labeling: The new guidance aims to prevent the labeling of a product as both “gluten-free” and having a “may contain” warning.
- Harmonization: The 4 mg gluten standard replaces a previous 5 mg total protein reference dose, harmonizing the approach for celiac disease and IgE-mediated wheat allergy.
- Read more about it here.