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Frequently Asked Questions

General Information

Who is the Allergen Control Group Inc. (ACG)?

The Allergen Control Group Inc. is a Canadian corporation assigned by the CCA to exclusively manage the GFCP brand and to administer and deliver the program.

What is the Gluten-Free Certification Program (GFCP)?

The Gluten-Free Certification Program (GFCP) is a voluntary program designed for manufacturers and distributors of gluten-free foods, drugs and other consumer goods wishing to differentiate their products from the increasing clutter of gluten-free claims.

What is Gluten?

“gluten” means any gluten protein from the grain of any of the following cereals or from the grain of a hybridized strain that is created from at least one of the following cereals:

  1. barley
  2. rye
  3. triticale
  4. wheat
  5. oats except gluten-free oats (Canada only) or
  6. any modified gluten protein, including any gluten protein fraction, that is derived from the grain of any of the cereals referred to in sections (a) to (e) or from the grain of a hybridized strain referred to in those sections.

Are there regulations that apply to products carrying a gluten-free claim?

Yes. The USFDA and Health Canada have designed specific regulations to govern the use of the term gluten-free. Gluten-free is treated as a voluntary claim and enforcement is lumped under misbranding. Intentional addition of gluten ingredients into gluten-free products (note: contamination is not an ingredient) is disallowed. Gluten ingredients include any gluten protein OR any modified gluten protein (or protein fraction) from the grain of any of the following cereals (or hybridized strain of at least one of the following) is not allowed: Barley, Rye, Triticale, Wheat and Oats (Canada only- gluten-free oats allowed). Canada has only one regulatory enforcement body. Health Canada, whereas the USA has three autonomous bodies (USFDA, USDA and Alcohol and Tobacco Trade and Tax Bureau (TTB) which have slightly different rules and enforcement strategies.

Is there an accepted gluten threshold associated with making a gluten-free claim?

In the USA and Canada, products displaying a gluten-free claim may contain levels of gluten not exceeding 20ppm due to cross-contamination. If there is intentional addition of gluten in the product formulation a gluten-free claim cannot be made.Companies that have a policy to manufacture gluten-free products to a specific threshold of less than 20ppm (i.e. 10ppm or 5ppm) will be expected to meet this threshold and audited to against their internal policy requirement.

What is a Gluten-Free Management System?

A gluten-free management system is the part of a facility’s food safety management system which incorporates and controls the management of gluten sources at all stages of the production cycle. This includes identifying gluten as a chemical hazard throughout a facilities good manufacturing practices (GMPs) and Hazard Analysis Critical Control Point (HACCP) plan(s).

Who Should Participate in the GFCP

Who can participate in the GFCP?

Any commercial manufacturer or distributor of gluten-free products including food, drugs and other consumer goods can participate in the program. The GFCP does not apply to the restaurant, food services or hospitality sector at this time.Private label brand owners wishing to use the GFCP mark will be required to enter into a license agreement with the Allergen Control Group Inc. Facilities manufacturing products for private labels need to meet the requirements of the GFCP and hold valid Certificate of Recognition (COR).

Can gluten-free products imported into Canada be certified under the GFCP?

Yes, providing the manufacturing facilities producing the gluten-free products to be imported meet the requirements of the program.

I manufacture gluten-free products in my home. Can my products become certified in the GFCP?

Currently the GFCP is limited to commercial manufacturers who can meet the rigorous food safety requirements of the program.

Can product(s) already certified and labelled as gluten-free by another certification organization also carry the GFCP mark?

Yes, providing the facility producing products under the program meet the GFCP requirements.

Does my facility need to be HACCP certified or certified in one of the GFSI benchmarked standards to gain recognition in the GFCP?

No, however facilities that are certified in these programs may benefit by already having many of the GFCP requirements implemented resulting in reduced GFCP certification costs.

Do my suppliers also need to be certified under the GFCP?

No, however receiving GFCP certified raw materials reduces your risk of potential gluten contamination and may also reduce the potential analytical testing costs for incoming products.

About the Program

What does the GFCP mark mean?

As the most trusted Canadian resource for consumers seeking gluten-free products, the Canadian Celiac Association’s vision for the GFCP mark is that it will provide consumers with safe, trusted and easily identifiable gluten-free products at point of purchase.The GFCP mark on product packaging provides consumers with an added level of assurance that those products are manufactured in a facility which successfully passes routine third-party audits to verify that their gluten-free management system consistently meets the requirements of the Gluten-Free Certification Program.

Can I use the GFCP mark in other countries?

Yes, providing that the facility producing products under the program meets the GFCP requirements.

What are the costs associated with the GFCP?

A breakdown of costs can be found here.

What are the requirements of the GFCP?

All requirements of the GFCP are detailed in the “GFCP Standards and Policies” document. A copy of all GFCP Technical Documents, including the GFCP Standards and Policies, are included with your facility application.

Is analytical product testing required as part of the GFCP?

Yes, however the GFCP does not prescribe analytical testing policies and procedures. Routine testing protocols should be developed and conducted by the facility based on the risk of gluten contamination, and integrated from the receiving of raw materials to end product.

Does my facility need to be dedicated gluten-free to be recognized under the GFCP?

No. However, in non-dedicated facilities, gluten contamination must be controlled or eliminated by standard operating procedures detailing cleaning and testing protocols to verify that the facility can be safely used to produce gluten-free products.

What is a recognized facility under GFCP?

A “recognized facility” is a manufacturing facility producing gluten-free products that has been audited by an approved third-party auditor and has met all of the requirements of the Gluten-Free Certification Program.

What is the Certificate of Recognition (COR)?

When a facility passes its third-party GFCP audit it will be issued a Certificate of Recognition (COR), which is mandatory for use of the GFCP mark. A COR is valid for a period of one year from date of issue.

What is the Program License Agreement (PLA)?

The Program License Agreement (PLA) is the official agreement between a company (brand owner) and the Allergen Control Group Inc. identifying the scope of products manufactured in the recognized facility and grants permission for the company to display the GFCP mark on product packaging and in marketing/advertising materials.

Do I need to use the GFCP mark on my products in the program?

Yes, it is a mandatory requirement of the program to use the GFCP mark. In special cases, where sufficient space is not available on the product packaging, specific pre-determined wording will be required.

How is certification applied to products?

The Gluten-Free Certification Program recognizes individual facilities once they have successfully completed a third-party audit to verify they are consistently able to manage a gluten-free environment. Gluten-free products manufactured in a recognized facility are then eligible to carry the Gluten-Free Certification Program mark. Products carrying the mark are certified as being manufactured in a GFCP recognized facility.

Does product packaging displaying the GFCP mark need to be pre-approved?

Yes, It is a mandatory requirement to use one of the GFCP trademarks on packaging of all gluten-free products certified in the program. See the Trademark Usage Guide for all rules and regulations.

The Audit Process

If products are already certified gluten-free by another organization will this be deemed equivalent to gain certification by the GFCP?

No, each certification organization certifying gluten-free products operates based on a different set of standards and requirements which are not considered equivalent to those of the GFCP.

Who performs the on-site audit?

GFCP audits must be conducted by GFCP trained and approved auditors who are employed by a third-party auditing company that has a current working agreement with the Allergen Control Group Inc.

Can a GFCP audit be combined with my current third-party food safety audit?

Yes, the GFCP audit can be combined with most food safety audits. This may include GMPs, HACCP, any of the GFSI benchmarked or ISO standards.

How long will the GFCP audit take?

A stand-alone GFCP audit is estimated to be 1½ days in duration. A combined GFCP audit is estimated to add approximately ½ day to any existing third-party facility audit.All audit durations may vary based upon size and complexity of the facility.

How much does an audit cost?

Audit costs vary and are quoted by the individual approved auditing companies.

How long do I have to close out non-conformances from my GFCP audit?

All non-conformances must be closed out with evidence provided to the auditor within 28 days following the audit.

How often do I need to be audited?

To maintain your facility “Certificate of Recognition” in good standing, each facility must be audited a minimum of once per year.