BRC GLOBAL STANDARD

FOOD SAFETY ISSUE 8

ADDITIONAL
VOLUNTARY
MODULE 12 AOECS
GLUTEN-FREE
FOODS
2018
BRC GLOBAL STANDARDS
Produced in association with
Association of European
Coeliac Societies
LIABILITY
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The Global Standard for Food Safety: Additional Module 12 AOECS Gluten-free Foods and the terms of the disclaimer set out
above shall be construed in accordance with English law and shall be subject to the non-exclusive jurisdiction of the English Courts.

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© BRC Global Standards and Association of European Coeliac Societies 2018

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*BRC Global Standards is a trading name of BRC Trading Ltd.

B GLUTEN-FREE FOODS
CONTENTS
PART I AUDIT PROTOCOL
INTRODUCTION2
SCOPE2
Exclusions from scope 3

AUDIT PLANNING 3
Preparation by the company 3
Information to be provided to the certification body for audit preparation 3
Audit duration 4

THE ON-SITE AUDIT 4

NON-CONFORMITIES AND CORRECTIVE
ACTION5
Non-conformities5
Procedures for handling non-conformities and corrective action 5
Critical non-conformities 5
Major and minor non-conformities 6

GRADING6
AUDIT REPORTING 6
CERTIFICATION7
ONGOING AUDIT FREQUENCY AND
RECERTIFICATION7
Scheduling re-audit dates 7

PART II REQUIREMENTS
Relationship of the module to the Global Standard for Food Safety 8

12 REQUIREMENTS OF THE AOECS MODULE

FOR GLUTEN-FREE FOODS 9
12.1 Senior management commitment 9
12.2 Management of suppliers of raw materials and packaging 9
12.3 Outsourced production 10
12.4 Specifications 11
12.5 Management of gluten cross-contamination 11
12.6 Management of incidents, product withdrawal and product recall 12
12.7 Labelling 12
12.8 Product inspection and laboratory testing 13

APPENDICES
Appendix 1 List of food products which are not permitted to bear
the Crossed Grain symbol 14
Appendix 2  Glossary 15
Appendix 3  Correct appearance of the Crossed Grain symbol 16
Appendix 4  Example of confirmation of licensed products issued by
a national coeliac society 17

GLUTEN-FREE FOODS 1
PART I
AUDIT PROTOCOL

INTRODUCTION
BRC Global Standards has developed a range of additional modules designed to help remove audit
duplication and reduce costs for sites undertaking BRC Global Standards audits.

This additional module has been developed in association with the Association of European
Coeliac Societies (AOECS) to enable food manufacturers to demonstrate to their customers that
the products supplied have been formulated, processed and prepared to meet the special dietary
needs of people intolerant to gluten, meet legal requirements and are applicable to assurance
schemes managed by AOECS.

This module enables compliance with the AOECS’s Standard for Gluten-free Foods to be assessed
at a BRC Global Standard for Food Safety Issue 8 audit.

Certification to this module in association with the BRC Global Standard for Food Safety Issue 8 will
assist food manufacturers by reducing the need for a separate audit to satisfy the requirements of
the AOECS Standard. The main benefits include:

○○ reducing audit costs and audit time

○○ ensuring proper focus on the safe production of gluten-free foods.

SCOPE
This module is voluntary but is applicable to manufacturers producing gluten-free food products in
accordance with the AOECS Standard for Gluten-Free Foods (available from http://www.aoecs.org).
It applies to foods and drinks for general consumption, as defined below, and to foods and drinks
that have been formulated, processed or prepared to meet the special dietary needs of people
intolerant to gluten.

The Crossed Grain symbol is a registered trademark (at European Union and national level) of the
AOECS itself, and many national coeliac societies who are members of the AOECS. The Crossed
Grain symbol can only be used under licence; therefore, companies wishing to use the symbol
must contact their national society. Where licensed, the symbol may be used on packaging,
promotional materials, websites, signage and corporate literature directly related to the licensed
products. Audit against the AOECS Standard or this module is one of the steps that must be
completed by food manufacturers prior to obtaining a licence to use the Crossed Grain symbol.

The module may be used globally; however, it has been produced with reference to European
legislation and the requirements of the AOECS. The requirements listed in this module are in
addition to any legislation applicable in the country of manufacture and the country of sale.
Sites are expected to meet all the relevant legislative requirements.

2 GLUTEN-FREE FOODS
Products covered by this scope are gluten-free foods and drinks consisting of:

○○ (or made only from) one or more ingredients which do not contain wheat (i.e. all Triticum species,
such as durum wheat, spelt and khorasan wheat, which is also marketed under different trademarks
such as KAMUT), rye, barley, oats1 or their crossbred varieties, and the gluten level does not exceed
20 mg/kg in total, based on the food as sold or distributed to the consumer, and/or
○○ one or more ingredients from wheat (i.e. all Triticum species, such as durum wheat, spelt and
khorasan wheat, which is also marketed under different trademarks such as KAMUT), rye,
barley, oats2 or their crossbred varieties, which have been specially processed to remove gluten,
and the gluten level does not exceed 20 mg/kg in total, based on the food as sold or distributed
to the consumer.

Some products contain very small amounts of gluten in the form of barley malt extract or gluten-free
(Codex) wheat starch. These ingredients are permitted to be used in products bearing the Crossed
Grain symbol provided the final product contains no more than 20 parts per million (ppm) gluten.

Foods which are not permitted to bear the Crossed Grain symbol are listed in Appendix 1.

EXCLUSIONS FROM SCOPE

The module is voluntary; however, for the module to be included within the site’s certification, all
products within the scope of the module shall be included. No exclusions are permitted (in other
words, no gluten-free products manufactured or processed at the site can be excluded).

AUDIT PLANNING
PREPARATION BY THE COMPANY
The certification body shall be notified in advance of the audit of the intention to add the module to
the scope of the audit. This ensures sufficient additional time can be scheduled and that an auditor
with the appropriate qualifications for the additional module is selected.

INFORMATION TO BE PROVIDED TO THE CERTIFICATION BODY FOR

AUDIT PREPARATION
The company shall supply the certification body with any additional background information
requested prior to the audit day to ensure the auditor is fully prepared to audit against the module.
This is likely to include information on the:

○○ products or groups of products within the module’s scope

○○ typical production schedules for gluten-free products.

Audits against this module shall be scheduled for dates/times when gluten-free production
is expected.

In cases where the BRC Global Standrds audit is unannounced and production schedules have
changed, the module can still be audited providing the auditor is able to ‘walk through’ the
production and understand the controls that operate during gluten-free production. In such a case,
the next scheduled audit shall be conducted whilst gluten-free production is taking place.

1 
Oats can be tolerated by most but not all people who are intolerant to gluten. Where used, the oats must themselves contain no more than 20 ppm gluten
and be produced in a safe manner, in accordance with the AOECS Standard. Any product that contains oats must follow guidance for production and
display of the licence number and Crossed Grain symbol in the correct format (see Appendix 3).
2
See previous note.

GLUTEN-FREE FOODS 3
The ‘walk through’ option is not permitted if:

○○ the audit is the first audit against this module or

○○ the previous audit was conducted whilst gluten-free production was not in progress.

In such cases, the AOECS/national coeliac society shall request a standalone audit against the
gluten-free standard (within 3 months of the unannounced audit where there was no gluten-free
production). The auditor shall record whether gluten-free production occurred and was witnessed
during the audit. This information is recorded under ‘Additional modules included’ in section 1 of
the audit report.

AUDIT DURATION
In order for the module to be included within the audit programme, additional time will be needed
for the audit. The amount of additional time will depend upon the number of gluten-free products
and the complexity and size of the production facility, but would typically be 2–4 hours of additional
time. The certification body shall indicate the expected additional time requirements at the time of
planning the audit.

THE ON-SITE AUDIT

Compliance with the requirements of the AOECS Module for Gluten-free Foods shall be assessed
as part of the audit against the requirement of the main Standard and is expected to be integrated
into the audit programme as appropriate.

During the audit, the auditor shall undertake both a traceability audit and a vertical audit specifically
relating to this module (this vertical audit will not include a quantity check (mass balance)). Where the
site uses the Crossed Grain symbol, the auditor will select a product bearing this symbol. Where
the site is not licensed or does not use the symbol, an alternative gluten-free product will be
selected. The traceability test and vertical audit will be completed in accordance with the BRC
Global Standards Guideline on Auditing Techniques. This requirement is in addition to the
traceability and vertical audits completed to meet the requirements of other parts of the BRC Global
Standard or audit protocol.

During the audit, detailed notes shall be made regarding the site’s conformities and non-conformities
against the requirements of the additional module, and these will be used as the basis for an
addendum to the audit report. The auditor shall assess the nature and severity of any non-conformity.

At the closing meeting, the auditor shall present their findings and discuss all non-conformities that
have been identified against the module during the audit. A written summary of the non-conformities
discussed at the closing meeting will be documented by the auditor either at the closing meeting
or within one working day after completion of the audit.

The decision to award certification for the module will be determined independently by the
certification body management, following a technical review of the audit report and the closing of
non-conformities in the appropriate timeframe. The company will be informed of the certification
decision following this review. Additional requirements will be reviewed before awarding or renewing
a licence to use the Crossed Grain symbol. These include evidence of gluten analysis and review
of packaging by the national coeliac society or the AOECS (for more information visit:
http://www.aoecs.org/). Therefore, whilst the decision on certification to this module is completed
by the certification body, decisions relating to the use of the Crossed Grain symbol are completed
separately by the AOECS.

4 GLUTEN-FREE FOODS
NON-CONFORMITIES AND CORRECTIVE ACTION
The level of non-conformity assigned by an auditor against a requirement of a module is an
objective judgement with respect to severity and risk and is based on evidence collected and
observations made during the audit. This is verified by the certification body management.

NON-CONFORMITIES
Non-conformities against requirements of this module shall be graded in the same way as non-
conformities identified against requirements of the main Standard, namely:

○○ Critical Where there is a critical failure to comply with a product safety or legal issue within the
scope of the module.
○○ Major Where there is a substantial failure to meet the requirements of a ‘statement of intent’
or any clause of the module or a situation is identified which would, on the basis of available
objective evidence, raise significant doubt as to the conformity of the product or service to
the module.
○○ Minor Where a clause of the module has not been fully met but, on the basis of objective
evidence, the conformity of the product to the module is not in doubt.

PROCEDURES FOR HANDLING NON-CONFORMITIES AND CORRECTIVE ACTION

Following identification of any non-conformities against the requirements of the module during the
audit, the company must undertake corrective action to remedy the immediate issue (correction).
The process for ‘closing out’ non-conformities depends upon the level of non-conformity and the
number of non-conformities identified.

Critical non-conformities
If a critical non-conformity is identified against a requirement of the module, then the site cannot be
certificated for this module without a further full audit of the module.

Where this occurs at a site that already holds certification for the module, certification of the module
must be immediately withdrawn.

If it is a requirement of customers that they shall be informed when their suppliers have a critical
non-conformity identified or fail to gain certification against a module, the company shall
immediately inform its customers.

Note that a critical non-conformity against a requirement of the module does not necessarily
prevent certification against the main Standard or other modules.

Where certification of the module is withdrawn, the company shall immediately inform the AOECS
or the relevant national coeliac society.

GLUTEN-FREE FOODS 5
Major and minor non-conformities
A module cannot be included on a certificate until major and minor non-conformities have been
demonstrated as having been corrected, either permanently or via a temporary solution that is
acceptable to the certification body.

Close-out of non-conformities can be achieved either by objective evidence being submitted to

the certification body, such as updated procedures, records, photographs or invoices for work
undertaken, or by the certification body undertaking a further on-site visit.

If satisfactory evidence is not provided within the 28-calendar-day period allowed for submission
following the audit, certification for the module will not be granted. The site will then require a
further full audit in order to be considered for certification of the module.

The certification body will review objective evidence of corrective action completed prior to
awarding a certificate.

GRADING
There will be no grading of the AOECS Module for Gluten-free Foods. The module will either be
awarded or not.

Any non-conformities identified when assessing a module shall not be taken into account when
deciding the grade for certification against the Global Standard for Food Safety.

AUDIT REPORTING
Following each audit, a written report shall be prepared in the agreed format for the module and this
will form an addendum to the Global Standard for Food Safety audit report. The addendum report
shall be produced in English or in another language, dependent upon user needs. Where the
report is produced in a language other than English, any applicable audit summary sections shall,
in addition, always be reported in English.

The report addendum covering the requirements for the module shall be prepared and uploaded
onto the BRC Global Standard Directory within 42 calendar days of the completion of the full audit.

The full audit report together with the addendum for the AOECS Module for Gluten-free Foods shall
be uploaded to the BRC Global Standards Directory in a timely manner irrespective of whether a
certificate is issued. The owner of the audit report may allocate access to the audit report with the
addendum to customers or other parties in the Directory.

The audit report and associated documentation, including auditor’s notes, shall be stored safely
and securely for a period of 5 years by the certification body.

6 GLUTEN-FREE FOODS
CERTIFICATION
After a review of the audit report for the module and documentary evidence provided in relation to
the non-conformities identified, a certification decision shall be made by the designated independent
certification manager.

Note that the module is audited as an addendum to the Global Standard for Food Safety. Where
certification to the Global Standard for Food Safety is not achieved, the module cannot be awarded
irrespective of whether the requirements of the module have been met.

ONGOING AUDIT FREQUENCY AND RECERTIFICATION

SCHEDULING RE-AUDIT DATES
If certification to the module is to be maintained, the module shall be included within each
subsequent audit of the Global Standard for Food Safety. The rules for scheduling the next audit
and maintaining certification will follow the audit choice for the Global Standard for Food Safety
(i.e. announced or unannounced).

GLUTEN-FREE FOODS 7
PART II
REQUIREMENTS

RELATIONSHIP OF THE MODULE TO THE GLOBAL STANDARD FOR FOOD SAFETY

Where the company applies for certification to the AOECS Module for Gluten-free Foods, the quality management system clauses
within the Food Standard shall apply to the management of the module. These management clauses include:

3.1 Food safety and quality manual

3.2 Document control

3.3 Record completion and maintenance

3.4 Internal audits

3.5 Supplier approval

3.7 Corrective and preventive actions

3.8 Control of non-conforming product

3.9 Traceability

3.10 Complaint handling

3.11 Management of incidents, product withdrawal and product recall

In addition, where the BRC Global Standard refers to ‘allergens’ without specific reference to gluten or cereals containing gluten, for
the purposes of this module the auditor will specifically audit these requirements with reference to gluten and gluten-containing
cereals. (Where the site also handles other allergens, these will also be audited as required by the Standard.) These clauses include:

2 The food safety plan HACCP – the HACCP plan must specifically consider risk of contamination with
gluten and the controls required to prevent this.

3.5.1.1 Raw material risk assessment – risk assessment must consider the potential for raw materials used
in the manufacture of products suitable for people intolerant to gluten to inadvertently contain,
or be cross-contaminated with gluten.

4.15.1 Storage facilities – raw materials for the manufacture of products for people intolerant to gluten must
be stored segregated from those which contain gluten.

5.3 (including Management of allergens – the site must have systems in place for the management of gluten-containing
clause 5.3.7) materials which minimises the risk of gluten contamination of products that do not deliberately contain
these materials and meet the legal requirements in the country of sale.

Allergen claims – where claims are made regarding the suitability of a product for those who are intolerant
to gluten (e.g. gluten-free), the site shall ensure that the production process is fully validated to meet the
gluten-free claim and the effectiveness of the processes routinely verified.

7.1.4 Training – staff involved in the manufacture of products suitable for people intolerant to gluten shall have
received training on the hazards associated with gluten contamination and the site’s procedures to prevent
this contamination.

8 GLUTEN-FREE FOODS
12 REQUIREMENTS OF THE AOECS MODULE FOR GLUTEN-FREE FOODS
12.1 SENIOR MANAGEMENT COMMITMENT
The site’s senior management shall demonstrate that they are fully committed to the implementation of the requirements
of this module.

CLAUSE REQUIREMENTS

12.1.1 The site shall have genuine, original hard copy or electronic versions of the current AOECS Standard and this
module.
Interpretation The AOECS Standard can be downloaded from www.aoecs.org
BRC Global Standards and modules are available from www.brcparticipate.com or
www.brcbookshop.com.

12.1.2 The company shall share a copy of their latest BRC Global Standards audit report, including this module,
with the designated AOECS contact.
Interpretation The site will need to demonstrate that the most up-to-date copy of their audit report (i.e. their last BRC
Global Standards audit, including the module) has been shared with the AOECS. The most effective way of
achieving this is to use the audit sharing option within the BRC Global Standards Directory. Where the
current audit represents the initial BRC Global Standards audit and/or the first audit to this module, there will
not be a previous audit/module report to share and this will not represent a non-conformity. However, the
expectation is that the reports for the current audit and subsequent audits will be shared in a timely manner.

12.2 MANAGEMENT OF SUPPLIERS OF RAW MATERIALS AND PACKAGING

The company shall have an effective supplier approval and monitoring system to ensure that any potential risks of gluten
contamination are understood and managed.

CLAUSE REQUIREMENTS

12.2.1 The company shall undertake a documented risk assessment of each raw material or group of raw materials
to identify potential risks of contamination with gluten (this risk assessment should be completed as part of
clause 3.5.1.1).
High risk raw materials (i.e. those identified at high risk of gluten contamination) shall either be:
○○ purchased from a certificated supplier (i.e. one that is certificated to the BRC Global Standard for Food
Safety including this module or the AOECS Standard) and who has supplied valid proof of this
certification
○○ supplied with a certificate of analysis that is specific to the consignment
○○ tested for gluten prior to use of the ingredient.
Acceptance of raw materials from low-risk suppliers shall include a supplier questionnaire or certificate of
conformance of the gluten-free status of the specific batch of raw material, or other applicable
documentation.

GLUTEN-FREE FOODS 9
CLAUSE REQUIREMENTS

Interpretation High-risk ingredients are flour, milled ingredients, oats, ingredients processed to remove gluten (including
gluten-free wheat starch and barley malt extract) and ingredients with a high risk of contamination with
gluten.
The minimum requirement for high-risk ingredients is a certificate of analysis showing gluten-free status of
each batch of raw material or a valid proof of certification to the BRC Global Standard for Food Safety
including this module or the AOECS Standard from this supplier. Analysis must be from an accredited
laboratory (or where no such accredited laboratory exists; the laboratory must operate in accordance with
the requirements and principles of ISO/IEC 17025) and use the recommended test method (see guidance
for clause 12.8.1).
Low-risk ingredients are those that are naturally gluten-free and at low risk of contamination with gluten.
Where a supplier questionnaire is used, this should as a minimum include information of any gluten-
containing ingredients used on site, staff training and the procedures to prevent gluten contamination.

12.2.2 Where suppliers of high-risk raw materials are not certificated to the BRC Global Standard for Food Safety
including this module or the AOECS Standard, they shall demonstrably work to the gluten-free production
requirements outlined in these standards.
Interpretation High-risk raw material suppliers must meet the requirements for gluten-free production (for example, those
set out in the BRC Global Standard for Food Safety, including Module 12, or the AOECS Standard). Where
the raw material supplier is not certificated to one of these appropriate standards, the site must establish that
their supplier is working in accordance with the requirements.

12.3 OUTSOURCED PRODUCTION

The company shall ensure that any outsourcing of processing steps and packing does not compromise the safety and legality
of products for persons intolerant to gluten.

CLAUSE REQUIREMENTS

12.3.1 The approval process for outsourced processing or packing shall include a review of procedures to prevent
contamination by materials containing gluten.
The company shall be able to demonstrate that the off-site subcontractor is certificated to either the AOECS
Standard or the BRC Global Standard for Food Safety including Module 12.
Interpretation Subcontractors completing outsourced processing or packing must be certificated to a standard that
specifically considers the gluten status of the products produced, for example the BRC Global Standard for
Food Safety including Module 12 or an audit against the AOECS Standard.

12.4 SPECIFICATIONS
The company shall ensure that raw material specifications for materials used in the production of gluten-free foods are agreed
with the suppliers and that the requirements are understood and complied with.

CLAUSE REQUIREMENTS

12.4.1 Specifications for raw materials used in the production of gluten-free foods shall be in place.
Raw materials used in the production of gluten-free products shall not contain gluten above 20 mg/kg (ppm)
unless derived from a gluten-containing grain (for example, barley malt extract or wheat starch) which may
contain gluten above 20 mg/kg (ppm) providing the final product contains less than this limit.
Interpretation Some raw materials used in the production of gluten-free products that are derived from a gluten-containing
grain (for example, barley malt extract or wheat starch) can contain small amounts of gluten, even above 20
mg/kg (ppm) provided that the final product contains no more than 20 mg/kg (ppm) gluten.

10 GLUTEN-FREE FOODS
12.5 MANAGEMENT OF GLUTEN CROSS-CONTAMINATION
The site shall operate methods of working and process flows that prevent the potential for gluten contamination at all process
steps including sourcing of raw materials, storage, processing and dispatch.

CLAUSE REQUIREMENTS

12.5.1 Raw materials, including processing aids, intermediate/semi-processed products, part-used materials,
finished products and materials pending investigation which are gluten-free or intended to be used in the
manufacture of gluten-free products shall be clearly identified at all stages of the process.

12.5.2 The production of gluten-free foods shall be either physically and/or time segregated.
Where the same production lines and equipment are used to manufacture gluten-free and gluten-
containing products, the following actions shall be performed to avoid gluten contamination:
○○ Cleaning operations that ensure there can be no mixing or cross-contamination.
○○ Appropriate sampling and analysis based on risk assessment.
○○ Evaluation of the need to eliminate the first portion of each production run to ensure the removal of
potential contamination. The volume of product rejected should be based on risk, validated and
recorded.
Interpretation Clause 4.11.3 of the BRC Global Standard states: ‘Where cleaning procedures are part of a defined
prerequisite plan to control the risk of a specific hazard the cleaning and disinfection procedures and
frequency shall be validated and records maintained.’ Therefore, sites producing gluten-free products are
expected to fully validate the cleaning procedures to confirm that the specified cleaning methods,
chemicals and concentrations are capable of consistently achieving the level of performance required.
Records of the validation must be maintained.
Where swabs are used for cleaning verification, their use must be validated to ensure they are used
effectively. Validation tests must be based on the recommended test for gluten, R5 ELISA Mendez method.

12.6 MANAGEMENT OF INCIDENTS, PRODUCT WITHDRAWAL

AND PRODUCT RECALL
The company shall have a plan and system in place to manage incidents effectively and enable the withdrawal and recall of
products should this be required.

CLAUSE REQUIREMENTS

12.6.1 In the event that a gluten-free product contaminated with gluten above the critical limit has been released to
customers, the company shall:
○○ immediately withdraw (and if necessary recall) the affected product
○○ inform the national coeliac society which issued the licence for use of the Crossed Grain symbol.
Interpretation The critical limit for gluten contamination is 20 mg/kg (ppm) for gluten-free products.
The incident management plan must include reference to informing the relevant coeliac society.
Where there is a legislative requirement to notify the relevant national regulatory authority. Then the national
coeliac society should be notified at the same time. Where notification of the regulatory authority is not
required, then the national coeliac society should still be notified within 5 days.

GLUTEN-FREE FOODS 11
12.7 LABELLING
Product labelling shall comply with the appropriate AOECS scheme rules.

CLAUSE REQUIREMENTS

12.7.1 Where products are licensed to be labelled with the Crossed Grain symbol, this shall be displayed in the
correct format and the claim ‘gluten-free’ shall be displayed on the label.
Interpretation Where the Crossed Grain symbol is being used, the registration number shall be clearly displayed with the
symbol.
The relevant coeliac society (i.e. the society which has approved the company’s use of the symbol) will send
the relevant registration number to the company during the product approval process.
The auditor is expected to audit examples of actual packaging to confirm it complies with this requirement
and with the information supplied by the coeliac society. This may be completed as part of the vertical audit
or as a separate activity. (Refer to Appendix 3 for examples of the correct use of the logo and registration
numbers).

12.8 PRODUCT INSPECTION AND LABORATORY TESTING

The company shall undertake or subcontract analyses for gluten.

CLAUSE REQUIREMENTS

12.8.1 There shall be a scheduled programme of gluten testing for licensed, final products bearing the Crossed
Grain symbol.
The frequency of testing shall be based on risk assessment. The minimum requirement for products bearing
the Crossed Grain symbol is an annual test.
The laboratory shall have gained recognised laboratory accreditation or, where no such accreditation is
available, they shall operate in accordance with the requirements and principles of ISO/IEC 17025.
The analytical method shall be an R5 sandwich ELISA (Mendez method), unless testing hydrolysed gluten,
where a modification of the R5 ELISA (competitive ELISA) is required.
Interpretation Whilst the laboratory itself may have accreditation, the actual test methods used must also be accredited.
Where accredited methods are not available, there must be suitable documentary assurances that the
laboratory is working to the requirements and principles of ISO 17025.
The critical limit for gluten contamination is 20 mg/kg (ppm) for gluten-free products.

12 GLUTEN-FREE FOODS
APPENDIX 1
LIST OF FOOD PRODUCTS WHICH
ARE NOT PERMITTED TO BEAR
THE CROSSED GRAIN SYMBOL
UNPROCESSED GRAINS
○○ Rice
○○ Maize

MEAT, FISH AND EGGS

○○ All sorts of fresh or frozen meat, fish and seafood not processed
○○ Tinned or canned fish and seafood with water/vegetable oil and salt, without additives
or other substances
○○ Eggs

MILK AND MILK-DERIVATIVES

○○ Fresh milk, UHT milk, sterilised milk without additives, vitamins or other substances
○○ Infant formula
○○ Yogurt and other fermented dairy products without additives, vitamins or other substances
○○ Fresh milk cream and UHT cream
○○ Cheese3

VEGETABLES AND LEGUMES

○○ All sorts of plain, fresh, frozen, canned or dried vegetables and legumes

NUTS AND SEEDS

○○ All sorts of nuts and seeds, with or without shells, not processed

FRUITS
○○ All sorts of plain, fresh, frozen, canned or dried fruits

DRINKS
○○ Fruit juices
○○ Soft drinks
○○ Mineral waters
○○ Tea, pure coffee
○○ Wine
○○ Distillates for spirits

SWEETS
○○ Honey, sugar
○○ Marmalade and jam
○○ Sweeteners

DRESSINGS AND OTHERS

○○ Butter, bacon fat, lard
○○ Vegetable oil
○○ Vinegar
○○ Spices and aromatic herbs not processed

According to Codex General Standard for Cheese (Codex Stan 283-1978). This means that processed cheese products can be licensed.
3 

GLUTEN-FREE FOODS 13
APPENDIX 2
GLOSSARY
AOECS (Association of
European Coeliac Societies)
AOECS Standard for
Gluten-free Foods
Batch
Codex Standard for Foods
for Special Dietary Use for
Persons Intolerant to Gluten
Crossed Grain symbol
14 GLUTEN-FREE FOODS
Founded in 1988, the Association of European Coeliac Societies (AOECS) is an independent, non-profit
organisation. It is the umbrella organisation of European national coeliac societies with currently
35 enrolled member societies. AOECS represents people who are affected by coeliac disease.
An audit to confirm compliance to the AOECS Standard for Gluten-free Foods is one of the steps
that must be completed before a company may be licensed to use the Crossed Grain symbol on its
products. This module (Voluntary Module 12 of the BRC Global Standard for Food Safety Issue 8)
integrates the requirements of the AOECS Standard into the BRC Global Standard audit. Therefore,
companies that are audited to this module may apply for a licence to use the Crossed Grain symbol
without the need for an additional audit of the AOECS Standard.
A quantity or consignment of goods produced at one time under the same conditions and using
the same raw materials.
The internationally recognised standard for gluten-free foods, adopted in 1981. The standard
forms the basis of legislation covering the use of the term gluten-free. Available at:
http://www.codexalimentarius.org/standards/list-of-standards/.
Gluten-free foods and drinks are those consisting of:
○○ (or made only from) one or more ingredients which do not contain wheat (i.e. all Triticum species,
such as durum wheat, spelt, and khorasan wheat, which is also marketed under different trademarks
such as KAMUT), rye, barley, oats4 or their crossbred varieties, and the gluten level does not
exceed 20 mg/kg in total, based on the food as sold or distributed to the consumer, and/or
○○ one or more ingredients from wheat (i.e. all Triticum species, such as durum wheat, spelt, and
khorasan wheat, which is also marketed under different trademarks such as KAMUT), rye, barley,
oats5 or their crossbred varieties, which have been specially processed to remove gluten, and
the gluten level does not exceed 20 mg/kg in total, based on the food as sold or distributed to
the consumer.
Some products contain very small amounts of gluten in the form of barley malt extract or gluten-free
(Codex) wheat starch. These ingredients are permitted to be used in gluten-free products provided
the final product contains no more than 20ppm gluten.
The Crossed Grain symbol is a registered trademark and protected across the European Union,
Switzerland, Norway, Croatia, Montenegro, Serbia and Bosnia Herzegovina. The symbol can only
be used under licence by companies and organisations on food and drink products that meet the
criteria of the AOECS Standard.
 ELISA Enzyme linked immunosorbent assay. The R5 ELISA Mendez method is the required method of
analysis for gluten in foods.

Gluten For the purpose of this Standard, ‘gluten’ is defined as a protein fraction from wheat, rye, barley, oats
or their crossbred varieties and derivatives thereof, to which some persons are intolerant and that is
insoluble in water and 0.5M sodium chloride (NaCl).

Prolamins Prolamins are defined as the fraction from gluten that can be extracted by 40 70% of ethanol.
The prolamins concerned are:

○○ gliadin (from wheat)

○○ secalin (from rye)
○○ hordein (from barley)
○○ avenin (from oats).

4 
Oats can be tolerated by most but not all people who are intolerant to gluten. Where used, the oats must themselves contain no more than 20 ppm gluten and be produced in a safe manner, in accordance
with the AOECS Standard. Any product that contains oats must follow guidance for production and display of the licence number and Crossed Grain symbol in the correct format (see Appendix 3).
5
See previous note.

GLUTEN-FREE FOODS 15
APPENDIX 3
CORRECT APPEARANCE OF THE
CROSSED GRAIN SYMBOL
The following are examples of Crossed Grain symbol formats used by companies on products licensed to use the Crossed Grain
symbol. Formats depend on the type of licence and whether the product contains oats.

Companies licensed to use the Crossed Grain symbol on their products are provided with a certificate of licensed products by their
national coeliac society, see Appendix 4. This lists licence numbers to be used on certified products.

UK LICENSE GLOBAL LICENSE

Standard Standard plus Global Standard Standard plus European

CUK-M-001 CUK-M-001 CUK-G-001 GB-001-001

CUK-G-001 CUK-G-001

EUROPEAN LICENSE
Standard Oats

GB-001-001 OATS-GB-001-001

16 GLUTEN-FREE FOODS
APPENDIX 4
EXAMPLE OF CONFIRMATION OF
LICENSED PRODUCTS ISSUED BY
A NATIONAL COELIAC SOCIETY
The following is an example of the licence documentation issued by a national coeliac society. This document includes the licence
numbers for each product and therefore provides a reference allowing the auditor to confirm that the products are labelled with the
correct licence number (refer to Appendix 3 and clause 12.7.1).

Certificate of licence
This is to certify that COMPANY NAME has been accepted as a
holder of an annual COELIAC SOCIETY NAME licence to display
the Crossed Grain symbol in Europe under the licence numbers
listed below.

Product name Licence number
Product 1 GB-001-001
Product 2 GB-001-002
Product 3 GB-001-003
Product 4 (containing gluten-free oats) OATS-GB-001-005

The range of gluten-free products listed under the licence must comply with the AOECS Standard for
gluten-free foods.

Date:

Sarah Sleet, Chief Executive.

GLUTEN-FREE FOODS 17
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