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Original article 1187 Consumption of gluten-free products: should the threshold value for trace amounts of gluten be at 20, 100 or 200 p.p.m.? Anna Giberta, Montserrat Espadalera, Miguel Angel Canelab, Anna Sáncheza, Cristina Vaquéa and Magda Rafecasc Objective The threshold of gluten contamination in gluten-free products of both dietary and normal consumption is under debate. The objective of this study was to gather information on consumption of gluten-free products intended for dietary use of people under a gluten-free diet. This information is essential to ascertain the exposure of coeliac patients to gluten through their diet and deduce the maximum gluten content that these products should contain to guarantee a safe diet. Methods A diet diary of consumption of gluten-free products intended for dietary use was distributed to the coeliac societies of two typical Mediterranean countries (Italy and Spain) and two Northern countries (Norway and Germany). The diet diary included a self-weigh table of the selected food items and a 10-day consumption table. Results were reported in percentiles as distributions were clearly right skewed. Results The respondents included in the study accounted for 1359 in Italy, 273 in Spain, 226 in Norway and 56 in Germany. Gluten-free products intended for dietary use contributed significantly to the diet of coeliac patients in Italy, Germany and Norway and to a lesser degree in Spain. The most consumed gluten-free product in all countries was bread, and it was double consumed in the Northern countries (P < 0.001). Mediterranean countries showed consumption of a wider variety of gluten-free foods and pasta was eaten to a large degree in Italy. gluten-free products but in the type of products consumed. The observed daily consumption of gluten-free products results in the exposure to rather large amounts of gluten, thus the limit of 200 p.p.m. should be revised. A limit of 20 p.p.m. for products naturally gluten-free and of 100 p.p.m. for products rendered gluten-free is proposed to guarantee a safe diet and to enable coeliac patients to make an informed choice. These limits should be revised as new data become available. Eur J Gastroenterol Hepatol c 2006 Lippincott Williams & Wilkins. 18:1187–1195 European Journal of Gastroenterology & Hepatology 2006, 18:1187–1195 Keywords: Codex Alimentarius, coeliac disease, consumption of gluten-free products, gluten exposure, gluten threshold, gluten-free diet, gluten-free labelling, gluten-free standard a SMAP Celı́acs de Catalunya, Coeliac Society, Departments of bApplied Mathematics and Analysis and cNutrition and Food Science-CeRTA, University of Barcelona, Barcelona, Spain Correspondence and requests for reprints to Anna Gibert, C/Balmes 109, Pral 2a 08008 Barcelona, Spain Tel: + 34 93 412 17 89; e-mail: [email protected] Sponsorship: This study was supported by SMAP Celı́acs de Catalunya, the Coeliac Society of Catalonia and by Agència Catalana de Seguretat Alimentària, the Food Safety Agency of Catalonia. Note: Preliminary data corresponding to 500 coeliac patients from Italy were presented at the Association of European Coeliac Societies meeting in Edinburgh, September 2005 and at the meeting of the Working Group on Prolamin Analysis and Toxicity in Maikammer, September 2005. Received 27 March 2006 Accepted 19 July 2006 Conclusions The differences between Northern and Mediterranean countries were not in the total amount of Introduction Coeliac disease is a chronic food hypersensitivity caused by ingestion of gluten in genetically predisposed individuals. It is a complex multifactorial disorder developed as a result of both genetic and environmental factors. The description and characterization of the pathogenesis of the disease has recently made significant progress [1–3]. T-cell response is triggered by gluten peptides with the action of tissue transglutaminase [4]. Those peptides can bind to human leukocyte antigen (HLA)-DQ2/DQ8 with high affinity. The autoimmune response leads to villous atrophy in the small bowel and subsequent nutrient malabsorption. The consequences of untreated patients are defined as very serious [5–7]. The classic clinical manifestations of the disease, that is, vomiting, diarrhoea, abdominal distension and failure to thrive, are no longer described as the only ones. Nowadays, coeliac disease has been related to extraintestinal evidences such as dermatitis herpetiformis, osteoporosis, anaemia, vitamin B12 deficiency, hepatitis, stomatitis and dental defects, infertility, depression, neurological diseases and cerebellar ataxia [8–11]. The oligosymptomatic and asymptomatic forms are being recognized as very common presentations of the disease, although highly under diagnosed [12]. The prevalence of the disease in the Western world is very high, accounting to 1 : 100 [11,13]. It is reported as c 2006 Lippincott Williams & Wilkins 0954-691X Copyright © Lippincott Williams & Wilkins. Unauthorized reproduction of this article is prohibited. 1188 European Journal of Gastroenterology & Hepatology 2006, Vol 18 No 11 even higher in certain Western European countries [14] and in at-risk group populations [13] such as those with Down syndrome [15], diabetes [16] and relatives [13,16]. Coeliac disease is a common medical condition and as such an effort is being made to identify the undiagnosed population, defined as the iceberg theory [8,17–19], as at present diagnosed people may be 10 times lower [9]. Although alternative therapies are being researched [20], the only treatment available nowadays for those suffering from coeliac disease is to adhere to a strict gluten-free diet for life. This includes a combination of consumption of naturally gluten-free foods, such as meat, fish, fruit, vegetables, legumes, eggs and dairy products with glutenfree substitutes of bread, cookies, pasta and other cerealbased foods. Gluten-free products intended for dietary use have two main roles. On the one hand, they are essential for achieving a balanced diet and on the other, they minimize the differences with the diet of noncoeliac patients. These two roles should not be underestimated, the former should provide the appropriate energy and nutrients required for a healthy diet and the latter improves socialization of coeliac patients, preventing them from looking different, from feeling deprivation and consequently from committing transgression. This is particularly important for the newly diagnosed as they are often undernourished, especially in cases in which a late diagnosis has occurred. This is also crucial during adolescence, widely documented as the most difficult stage to manage a strict gluten-free diet. Considering the important role of gluten-free products in the diet of coeliac patients, the quality of these products should be carefully assessed and reviewed. Gluten-free products are industrially manufactured using gluten-free cereals, mainly rice and corn. These cereals, however, may be cross-contaminated by gluten cereals during harvest, handling of grain cereals, transport and milling practices. Current European legislation does not specify the threshold for gluten contamination in glutenfree products and in addition starches that have been rendered gluten-free by extraction may also be used to produce gluten-free products. The inclusion of these starches into the gluten-free diet is controversial [21–27] as the residue of gluten may be higher than the contamination that occurs in naturally gluten-free products. The current Codex Alimentarius standard for gluten-free products [28] has been under revision since 1998. In the draft revised standard [29], a limit of 20 p.p.m. is defined for products consisting of or made only from naturally gluten-free ingredients, while a limit of 200 p.p.m. is proposed only for foodstuffs or ingredients that have been rendered gluten-free and for foods containing a mixture of the two ingredients. The European Food Safety Authority (EFSA) [30], the Food and Drug Administration, Center for Food Safety and Applied Nutrition (FDA/ CFSAN) [31] and the Working Group on Prolamin Analysis and Toxicity [32,33], however, have questioned the scientific sound of these limits. A limit of 100 p.p.m. has recently been proposed by Collin et al. [27] and this is supported by the Association of European Coeliac Societies. The definition of the term gluten-free needs clarification from the regulatory authorities in the very near future. Three main issues are required to establish the safe residue limit of gluten in gluten-free products: to have a fully validated method of analysis to detect and quantify low levels of gluten, to establish the threshold of toxicological concern of gluten for coeliac patients, and to find out the levels of exposure of coeliac patients to gluten through the diet. The development of a reliable and accurate method of analysis of gluten has been one of the main objectives of the Working Group on Prolamin Analysis and Toxicity. One of its members, Dr Méndez from the National Center of Biotechnology (Madrid, Spain), has developed a sandwich enzyme-linked immunosorbent assay (ELISA) method, based on the monoclonal antibody R5, able to recognize the potential coeliac-toxic epitope QQPFP [34,35]. The method has a detection limit of 3.2 p.p.m. of gluten, thus allowing for the determination of low levels of gluten content. The Working Group on Prolamin Analysis and Toxicity presented the method to the Codex Alimentarius, after performing a ring test and the Committee decided to endorse the R5-ELISA sandwich as the standard method for the analysis of gluten residues in food [36]. As for the threshold of toxicological concern, the EFSA [30] and the FDA/CFSAN [31] reviewed available clinical data. Although more studies are needed, currently published data can be used to draw a conclusion to temporarily establish a threshold for gluten. Nonetheless, reported data on the consumption of gluten-free products are scarce [27,37,38]. It is not scientifically established to what extent coeliac patients substitute bread, pasta, cookies, and other cereal-based foods with the corresponding gluten-free products and consequently the exposure to gluten traces cannot be deduced. This study was designed to collect consumption data of gluten-free products intended for dietary use on the basis of the responses to a 10-day diet diary of such products, in order to ascertain the potential gluten exposure of coeliac patients through their diet. Foods for normal consumption were not included. This information is essential to Copyright © Lippincott Williams & Wilkins. Unauthorized reproduction of this article is prohibited. Consumption of gluten-free products Gibert et al. 1189 define the threshold value for gluten contamination in gluten-free products. Another aim of the study was to gather consumption patterns of coeliac patients and to compare the consumption patterns of gluten-free products between two typical Mediterranean countries (Italy and Spain) and two Northern countries (Norway and Germany). No studies of this kind have been performed before in Europe. Methods Diet diary A diet diary of gluten-free products intended for dietary use for people on a gluten-free diet was designed by health professionals (three pharmacists and one dietician) of SMAP Celı́acs de Catalunya, one expert on Nutrition and Food Science and one statistician from the University of Barcelona. Owing to the diversity of the food products depending on the country and also because coeliac food is known to be different in size and format to the corresponding glutencontaining product, it was considered very important to include in the questionnaire the weight of the rations or products consumed. According to this, the first part of the questionnaire was to self-weigh the selected gluten-free products and to record them in a table. This was requested just once at the beginning. In the second part of the questionnaire, consumption of the selected gluten-free products day by day, over a period of 10 days, was asked to be recorded in another table. The days did not need to be consecutive. Very detailed instructions and examples on how to record the weight of the rations and how to fill the daily consumption table were given to the respondents. The questionnaires were tested with a group of 10 study participants from SMAP Celı́acs de Catalunya, in the presence of the health professionals, to check that instructions were clearly understood. Before proceeding with the mailing, the questionnaires were distributed to the coeliac associations of four countries: Italy (AIC Associazione Italiana Celiachia), Spain (SMAP Celı́acs de Catalunya, ASOCEPA Canary Islands), Norway (NCF Norsk Cøliakiforenings) and Germany (DZG Deutsche Zöliakie Gesellschaft e.V.). Each country participating in the study had the questionnaire translated to its own language and the selected food items revised to adapt them to the food habits of each country. The Spanish questionnaire contained 23 items, the Italian 22, the Norwegian 18 and the German 23. Room to add other items not detailed in the list was also included as ‘others’. Questionnaires were mailed to 36 000 members in Italy, 5000 to two regions of Spain (Canary Islands and Catalonia) and to 7500 in Norway. A self-addressed stamped envelope was included so that all answers were to be returned to SMAP Celı́acs de Catalunya. In Germany, the questionnaire was announced on the Society web site and returned by e-mail to SMAP Celı́acs de Catalunya. The questionnaire included a sentence to protect respondents’ privacy: ‘I hereby give my consent that my personal data are used for activities related to scientific research or similar activities that would improve the quality of life of coeliacs’, or similar statements. Questionnaires were sent between May and June 2005 and received between June and October 2005. Data collection and calculations Each questionnaire was carefully reviewed for its validity before being included in the study. Respondents filling the consumption table but not recording the weight of some rations were excluded from the sample, probably producing a downward bias, as this typically occurred with individuals with a wide range of consumption. Respondents with great deviations that could be attributed to misprints or confusing the weight of the ration by the total weight ingest for any of the items, were also excluded. For lasagne, only the contribution of the sheets and the flour of the béchamel sauce was considered. For each 100 g of lasagne, 16 g of contribution of gluten-free product was included. For each piece of crumbed meat or fish, the weight of one heaped tablespoon of bread crumbs (20 g) was considered. These figures were determined experimentally, as for the rest of the food items. Data were processed by means of a self-designed database. To simplify the presentation of the results, the food items listed in the questionnaire were grouped into the following food groups: bread, pasta, pastry, biscuits, pizza, breakfast cereals and bread-crumb-coated foods. Statistics As the distribution of intake for the various food groups considered in this study was positively skewed, the results reported in this study are percentiles, in order to avoid the strong influence of the right tail of the distribution on means and standard deviations [39]. Five percentiles (10, 30, 50, 70 and 90th) are reported for each of the seven food groups and for the total daily intake. The 50th percentile (the median) is reported as the Copyright © Lippincott Williams & Wilkins. Unauthorized reproduction of this article is prohibited. 1190 European Journal of Gastroenterology & Hepatology 2006, Vol 18 No 11 Table 1 Summary of the population under study Italy (n = 1359) Men Women Age (years) r2 3–10 11–30 31–50 > 50 Spain (n = 273) Norway (n = 226) Germany (n = 56) n Percentage n Percentage n Percentage n Percentage 328 970 29 71 102 171 37 63 64 156 29 71 13 23 36 64 12 259 439 477 173 9 19 32 35 13 11 96 58 74 34 4 35 21 27 12 0 13 26 60 125 0 6 12 27 55 2 10 14 21 7 4 18 25 37 12 Consumption data (in percentiles) of gluten-free products of the countries studied central measure and the extreme percentiles as a measure of the spread. Table 2 Differences between countries, sexes and age groups have been tested using the nonparametric Kruskal–Wallis test. All the calculations have been performed with R, the public domain implementation of the S statistical language. Daily intake (g) Percentile Results Population under study The respondents included in the study accounted for 1359 in Italy, 273 in Spain, 226 in Norway and 56 in Germany. These data represent 3.8% of the members of the coeliac society in Italy, 5.0% in the two regions of Spain (Catalonia and Canary Islands), 3.0% in Norway and 0.3% in Germany. In all the countries studied, the respondents were mainly female. According to age, in Italy and Germany very similar populations entered the study with the majority of the respondents between 11 and 50 years old. In contrast, in Spain the major group of respondents was that aged 3–10 years and in Norway more than half of the respondents were over 50 years. See Table 1 for a summary of the population studied. Consumption of gluten-free products by food groups In Italy, Germany and Norway, gluten-free products intended for dietary use contributed significantly to the diet of coeliac patients. A lower consumption was detected in Spain as compared with the other countries. In percentages, half of the population in Italy and Germany ate at least 16% more than in Norway and 35% more than in Spain. Table 2 is a summary, based on percentiles, of the daily intake (grams per day). The differences between the extreme percentiles and the median (P90th – P50th and P50th – P10th) clearly show that all distributions were right skewed, thus providing an argument against the use of means and standard deviations [39]. The differences P90th – P10th indicate that daily consumption of gluten-free products in Italy was more spread around the median than in the other countries. See Fig. 1 for a graphical representation of the distribution as adapted from Costanza et al. [39]. Italy (n = 1359) Bread Pasta Pastry Biscuits Pizza Breakfast cereals Bread-crumb-coated foods Total daily intake Spain (n = 273) Bread Pasta Pastry Biscuits Pizza Breakfast cereals Bread-crumb-coated foods Total daily intake Norway (n = 226) Bread Pasta Pastry Biscuits Pizza Breakfast cereals Bread-crumb-coated foods Total daily intake Germany (n = 56) Bread Pasta Pastry Biscuits Pizza Breakfast cereals Bread-crumb-coated foods Total daily intake 10th 30th 50th 70th 90th 18.0 24.0 0.0 0.0 0.0 0.0 0.0 43.8 48.0 15.0 11.1 10.0 0.0 0.0 68.5 64.7 30.0 23.6 18.0 0.0 0.0 101.3 89.0 49.6 40.0 30.0 6.0 3.6 200.0 138.4 84.0 85.6 56.0 30.0 8.0 151.5 209.8 265.1 343.0 531.2 16.0 0.0 0.0 0.0 0.0 0.0 0.0 37.8 10.0 6.0 6.7 0.0 0.0 2.4 54.3 20.0 18.0 14.7 0.0 0.0 7.2 90.6 30.0 36.0 28.6 10.0 13.1 14.3 167.3 58.0 71.8 61.5 25.0 40.0 31.8 91.0 131.3 173.1 226.5 404.0 48.0 0.0 0.0 0.0 0.0 0.0 0.0 90.0 0.0 3.2 0.0 0.0 0.0 0.0 126.8 0.0 15.0 3.0 0.0 0.0 0.0 173.4 10.5 34.0 8.0 15.0 9.0 0.0 263.9 30.0 73.5 21.0 40.4 30.0 8.0 108.1 179.9 225.7 281.0 411.6 48.0 8.0 0.0 0.0 0.0 0.0 0.0 99.5 15.0 6.0 5.6 0.0 7.0 0.0 128.7 22.4 17.5 11.0 10.0 16.0 0.0 171.3 39.2 44.5 17.6 20.0 36.0 0.2 232.0 52.5 66.7 38.4 30.0 69.5 0.7 129.3 213.4 268.1 326.5 400.1 By food groups and based on the medians, the most consumed gluten-free product in all countries was bread. In all countries studied bread was chosen every day. In Italy there was also a daily choice of pasta, and in Spain of biscuits. In Spain and Germany, pasta was consumed between two and three times every 10 days. The median daily contribution in percentages of the different groups of gluten-free products was as follows: in Copyright © Lippincott Williams & Wilkins. Unauthorized reproduction of this article is prohibited. Consumption of gluten-free products Gibert et al. 1191 Owing to the size of the Italian sample, all comparisons across countries were highly significant (P < 0.001). Even excluding Italy, all comparisons were highly significant (P < 0.058), except for pizza. Fig. 1 10th percentile 50th percentile 90th percentile 600 Total intake (g/day) 500 531 404 400 300 200 265 226 152 100 0 412 173 91 Italy Spain 108 Norway 400 268 129 Germany Total gluten-free products consumption in percentiles by country (grams per day). Italy, 27% of the daily intake of gluten-free products was bread, closely followed by pasta (24%), then pastry (11%), biscuits (9%) and pizza (7%). In Spain, 35% of the daily intake of gluten-free products was bread, followed by pasta (11%), then pastry (10%), biscuits (9%) and bread-crumb-coated foods (4%). In Norway, bread was 61% of the daily intake of gluten-free products, followed by a low contribution of pastry (7%) and biscuits (1%). In Germany, 49% of the daily intake of gluten-free products was bread, followed by pastry (10%), pasta (9%), breakfast cereals (6%), biscuits (5%) and pizza (3%). The contribution of the group ‘others’ was not significant. The Northern countries (Germany and Norway) showed the highest intake of bread, with medians of 128.7 and 126.8 g/day, respectively. As for the Mediterranean countries, in Italy the median consumed was nearly half of this (68.5 g/day) and in Spain slightly lower (54.3 g/day). Italy was the country with the highest pasta intake, followed by Germany and Spain with similar figures. In Norway, pasta was scarcely consumed. The medians of pizza consumption accounted for 18.0 g/day in Italy and 10.0 g/day in Germany, while in Spain and Norway this product was barely consumed. Pastry and biscuits contributed substantially to the Mediterranean countries’ daily intake, particularly in Italy, but also in Spain. These products were also consumed in Germany, but were of less importance in Norway. Breakfast cereals only contributed to some extent to the diet of coeliac patients in Germany. For the other countries, consumption of breakfast cereals was not significant. Similarly, bread-crumb-coated foods only contributed to the diet of coeliac patients in Spain. Consumption of gluten-free products by age The highest intake of gluten-free products occurred in the age group between 11 and 30 years and the lowest in the group aged below 2 years. This responds to the difference in energy requirements and dietary habits existing between these age groups. In percentages of the medians, in Italy, Spain and Norway, the group aged 11–30 years consumed 17–22% more than the group aged 2–10 years. As compared with the group aged r 2 years, this figure was variable depending on the country. In Italy, the group aged 11–30 years consumed 23% more than the group r 2 years, but in Spain this group ate 62% more than the group r 2 years. This shows that a very low consumption of gluten-free products in children below 2 years occurred in Spain. In Italy and Spain, consumption of bread increased with age (P < 0.001). In Norway no difference of bread consumption occurred with age and in Germany consumption of bread was also quite homogeneous across the different age groups, except for children r 2 years. On the contrary, biscuits were mainly eaten by children in all countries studied. Consumption of gluten-free products by sex In all countries, males ate more than females (13–28%). The sex effect was significant in Italy for biscuits (P < 0.001), pastry (P < 0.001), pasta (P < 0.001) and pizza (P = 0.014). In Spain it was significant for biscuits (P = 0.043) and pasta (P = 0.003), and in Norway it was only significant for bread (P < 0.001). As for their consumption patterns, however, males and females of the same country tended to consume the same types of foods, except that in Norway the median of pasta consumption was null for males and in Germany pizza was exclusively eaten by males. Discussion Studies on the diet followed by coeliac patients have been focused on topics such as the inclusion of wheat starch [27,40] or oats [40–42] in the gluten-free diet, in the adequacy of nutrients intake [43–45], in the level of dietary compliance [46–51] or in the impact on the quality of life [52]. Only three studies containing data on the quantity and/or type of gluten-free products eaten by coeliac patients have been identified in the literature [27,37,38]. One study [53] contained data on the amount of gluten consumed by first-degree relatives of coeliac patients in the Netherlands. Copyright © Lippincott Williams & Wilkins. Unauthorized reproduction of this article is prohibited. 1192 European Journal of Gastroenterology & Hepatology 2006, Vol 18 No 11 In the framework of such studies, the 10-day recording period of this survey, chosen to minimize day-to-day variations, and the complete list of gluten-free products intended for dietary use to facilitate the record of each food item, provided an adequate tool to assess consumption patterns of such products. The number of respondents made this survey representative of the coeliac population of Italy, Norway and the two regions of Spain, although it may be only informative for Germany owing to the smaller size of the population studied. The survey was only limited by a slight downward bias caused by the incomplete questionnaires that could not be included. follow-up to achieve a nutritionally adequate diet, as has been strongly recommended [45,58,59]. The age of the respondents was indicative of the situation of the water line of the coeliac iceberg in each of the countries studied. In Italy, Norway and Germany, the diagnosis and awareness of the disease has made significant progress in the recent decades [54]. The high participation of adults in those countries reflects on the one hand the paediatric population diagnosed some years ago and on the other, the progress of adult detection of the disease. On the contrary, in Spain, the disease has recently shown a high incidence owing to awareness of paediatricians [55,56], but diagnosis in adults is only incipient. This may explain the high number of respondents below 10 years of age and the low number of adults. It is also worth mentioning that the higher number of female respondents in all countries reflects the higher incidence of coeliac disease in the female sex. Greco et al. [37] studied the consumption of Italian adolescents in a gluten-free diet and found an average of about 11.32 kg/month (377.3 g/day) of gluten-free products. This figure was similar to the mean found in our study for the group aged between 11 and 30 years in Italy (345.0 g/day). Contribution of gluten-free products in coeliac patients’ diet Despite the different kind of recommended daily intakes, cereals provide the greatest amount of calories per person in all European countries [57] and are described as the main source of carbohydrates and also provide protein and vitamins. According to FAO food balance sheets of 2002, per capita supply of cereals in Europe (15 countries) was mainly due to gluten cereals (wheat, barley, rye, oats), accounting for 90% of the total. Only 10% of the per capita supply was due to rice, maize, millet or sorghum. To follow such consumption pattern, coeliac patients must substitute their gluten cereals intake with the corresponding amount of gluten-free cereals. The coeliac population included in this study showed an important contribution to the diet of gluten-free products, thus implying that coeliac patients base their diet not only on naturally gluten-free products but also on important amounts of gluten-free bread, pasta, pastry, biscuits or pizza. As it has been reported that coeliac patients’ diets are often unbalanced [38,43,45] and have higher percentage of calories from fat and proteins and less from carbohydrates [43,45], however, the reported intake of these products could even be higher in the following years if coeliac patients get dietary advice and Thompson et al. [38], in a study of gluten-free diets of American coeliac patients, found a mean daily intake of grain food servings of 4.6 for women and 6.6 for men, which is lower than the recommended [60]. The authors also reported that coeliac patients’ diets have so far been focused on the allowed/not allowed food rather than on ensuring a nutritionally adequate diet, and recommended a daily intake of 6–11 servings of glutenfree products. Collin et al. [27] reported that the median daily use of flours by coeliac patients in Finland was 80 g (range 10–300 g) for adults and 60 g (range 20–140 g) for children. In this study, results of daily intake were calculated on the finished product and not on the amount of flour consumed. Differences between Northern and Mediterranean consumption patterns This survey showed that the difference between Northern (Germany and Norway) and Mediterranean (Italy and Spain) countries’ coeliac patients’ diet was not in the total amount of gluten-free products consumed. Italy, Germany and Norway showed similar medians, although in Italy some individuals ate very high amounts as shown by the high value of the 90th percentile. On the contrary, in Spain a lower consumption of gluten-free products as compared with the other countries was detected. This may be related to the fact that gluten-free products are not funded in Spain. It is reasonable that coeliac patients may deliberately divert their diet to consumption of nondietary naturally gluten-free products that are less expensive and more accessible, although this would most likely lead to nutritional deficiencies. The differences between Northern and Mediterranean countries were in the contribution of the different types of gluten-free products in the diet. The most significant difference was the consumption of bread (P < 0.001). The Northern countries consume double the amount of bread than the Mediterranean. Consumption of bread (in grams per person per day) by the general population has been reported [61] to be 158 in Italy, 141 in Spain and 197 in Norway, thus confirming the tendency of Northern countries to a higher consumption. Copyright © Lippincott Williams & Wilkins. Unauthorized reproduction of this article is prohibited. Consumption of gluten-free products Gibert et al. 1193 reported that maximum gluten intake should lie between 10 and 100 mg/day. The other main difference between Northern and Mediterranean countries was in pasta consumption, traditionally part of the Mediterranean diet. The survey showed that this product was highly consumed in Italy, and was also greatly consumed by coeliac patients of Spain and Germany. In contrast, in Norway consumption of pasta was nearly null. Clinical data are nonconclusive, but meanwhile the FDA/ CFSAN [31] has stated that the safety assessment-based approach is a viable approach to establish a threshold for gluten using currently available ‘no observed adverse effect level’ (NOAEL) or ‘lowest observed adverse effect level’ (LOAEL) data for coeliac disease. The threshold for gluten contamination in gluten-free products following the safety assessment-based approach can be deduced from the tolerable daily intake (TDI = NOAEL/uncertainty factor), which must then be compared with the level of intake in the upper part of the distribution [65]. In conclusion, coeliac patients of the Mediterranean countries but also of Germany ate the same types of food: bread, pasta, biscuits, pastries and pizza to some extent, so that a wide variety of products contribute to their diet. On the contrary, in Norway, the intake of cereals by the coeliac population was made almost exclusively by means of high amounts of bread. In this study, the level of intake of gluten-free products intended for dietary use has been assessed. Table 3 shows a summary of the exposure to gluten calculated from the different percentiles used by regulatory agencies [65] (90th percentile in United States, 95th percentile in the European Union, 97.5th in the United Kingdom) and the different thresholds of gluten contamination under debate (20, 100 and 200 p.p.m.). It can be observed that with the limit of 20 p.p.m. and in the different percentiles, values of gluten daily exposure due to consumption of gluten-free products range from 8.0 to 20.1 mg. For the limit of 200 p.p.m., the values range from 80.0 to 201.0 mg/day. At midway, with the limit of 100 p.p.m., the values range from 40.0 to 100.4 mg/day. One should bear in mind that these levels of gluten exposure do not take into account other sources of gluten in the diet of coeliac patients such as those carried by consumption of normal processed food, for which manufacturers often use the 200 p.p.m. limit as the reference for labelling it as gluten-free, regardless of the vegetal (wheat/nonwheat) origin of their ingredients. Gluten exposure assessment The threshold for gluten that triggers an adverse reaction has not yet been ascertained. The studies to establish this threshold are difficult and expensive, because in the absence of animal models, the studies need to be performed in humans and assessed by means of biopsy. Available clinical data have been reviewed by Collin et al. [27], by the EFSA [30] and also by FDA/CFSAN [31]. Invivo challenge studies have covered different exposures to gliadin (from 1.2 mg to 1 g/day) or gluten (from 100 to 500 mg/kg/day), for different lengths of time (from hours, days, months or years) and by means of different methodologies. A recent case study has shown that the ingestion of 1 mg of gluten per day over a period of 2 years prevented histological recovery [62]. Collin et al. [27] reported that according to histology changes, a daily intake of 30 mg of gluten was safe. The most recent challenge study has been performed by Catassi et al. [63]. The study has promising and reliable results as it is a prospective, multicentre, placebo-controlled, double-blind, randomized gluten challenge trial performed on 36 coeliac patients exposed to gluten for 3 months. Preliminary results of this study showed that 10 mg/day were well tolerated but there was a trend to histological changes when patients were challenged with 50 mg. Hischenhuber et al. [64], in a review article, have recently Gluten-free standard As mentioned before, the draft revised standard for gluten-free products is under discussion. It seems that there is a general agreement on the fact that the limit of 20 p.p.m. is protective enough for coeliac patients. The limit of 200 p.p.m. for products rendered gluten-free, however, is not accepted in the same way. Table 3 Daily gluten exposure deduced from the different percentiles of consumption of gluten-free products and the different thresholds of gluten contamination Italy (n = 1359) Spain (n = 273) Norway (n = 226) Germany (n = 56) Percentiles of daily intake (g) 90th 531.2 95th 639.4 97.5th 1003.7 90th 404.0 10.6 53.1 106.2 13.9 69.6 139.3 20.1 100.4 201.0 8.1 40.4 80.8 Gluten threshold (p.p.m.) 20 100 200 95th 97.5th 90th 95th 512.2 717.2 411.6 512.1 Daily amount of gluten exposure (mg) 97.5th 638.3 90th 400.1 95th 467.3 97.5th 505.7 10.2 51.2 102.4 12.8 63.8 127.7 8.0 40.0 80.0 9.3 46.7 93.5 10.1 50.6 101.1 14.3 71.7 143.4 8.2 41.2 82.3 10.0 50.2 100.4 Copyright © Lippincott Williams & Wilkins. Unauthorized reproduction of this article is prohibited. 1194 European Journal of Gastroenterology & Hepatology 2006, Vol 18 No 11 It is well known that Northern countries are less concerned about the 200 p.p.m. limit, while the Mediterranean countries prefer the 20 p.p.m. limit. In Italy, there is a National Regulation [66] that does not allow the use of wheat starch in the manufacture of gluten-free products and consequently establishes a unique limit of 20 p.p.m. These differences might be related to consumption patterns, as on the one hand, cereals highly contribute to the Mediterranean diet and consequently the exposure to gluten traces may be higher. On the other, the existence of a 200 p.p.m. limit allows using wheat starch to produce bread of good quality and texture and makes it highly appreciated in the Northern countries in which bread seems to be the main glutenfree product of the coeliac diet. It should be mentioned that because of the evolving food technology of recent years, bread of great characteristics can also be produced using no wheat-based ingredients. With the data collected in this study, consumption of gluten-free products in both Northern and Mediterranean countries results in the exposure to rather large amounts of gluten. Until the tolerable daily intake for gluten and subsequent risk assessment to establish the safe threshold of gluten for coeliac patients are completed and following the precautionary principle of European food law, it is suggested to define as glutenfree any product with a content of less than 20 p.p.m. This standard is achievable for naturally gluten-free products and gluten can be detected and quantified with available analytical methods. This limit of 20 p.p.m. should also be the upper limit for labelling foods for normal consumption according to the recent European Union Directive on Allergen Declaration [67]. This would allow coeliac patients to follow a strict glutenfree diet exclusively based on naturally gluten-free products coming from both gluten-free products intended for dietary use and processed foods for normal consumption. teeing a safe diet for coeliac patients. These limits, however, should be revised as new data become available. Acknowledgements Coeliac societies from Italy, Norway, Canary Islands and Germany have been of great help with translations and promoting participation. Special mention should be given to the Italian Society for its high contribution to the study. We also thank the Youth and volunteers of SMAP Celı́acs de Catalunya for their contribution to data collection. References 1 2 3 4 5 6 7 8 9 10 11 12 13 14 As in some European countries, however, wheat starchbased products are highly appreciated and widely consumed, especially in countries in which there is a high consumption of bread, a limit of 100 p.p.m. for products rendered gluten-free could be agreed temporarily, assuming that the total intake of gluten-free products does not all come from wheat-based products, and that most wheat-based flours contain less than this [27]. 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