1/ @CeliacBeast recently reached out about an enzyme supplement that included a Contains wheat statement on the label (see photo). I contacted the company. Their reply: Wheat is used in the fermentation media of the enzymes...

2/ and according to Food Allergen Labeling and Consumer Protection Act of 2004(FALCPA), wheat must be declared as an allergen. However the wheat has been processed to remove the gluten allergen protein." The manufacturer is correct about FALCPA, BUT this product is misbranded...

3/ under both the 2013 and 2020 gluten-free labeling rules. The FDA did NOT exempt enzymes from the rule on gluten-free labeling of fermented and hydrolyzed foods and ingredients...

4/ Paraphrasing from FDA: If wheat, barley, or rye is used as a food source for a microbe, consumers are justified in their concerns that gluten could be present in the microbe ingredient due to the lingering presence of growth media...

5/ If bacteria grown on media that contain wheat, barley, or rye is used to produce enzymes, gluten may be present in an enzyme ingredient due to the lingering presence of growth media. If gluten is present in the growth media it may have been broken down into protein fragments.

6/ FDA does not know at this time if gluten fragments produced during fermentation of growth media are capable of causing an immune response in people with celiac disease...

7/ FDA also does not know if it is possible to accurately test for the presence of any residual gluten in bacteria, yeast, or enzymes produced on growth media containing a gluten source. Manufacturers should use microbial starting materials that are gluten-free...

This is confusing information. Please let me know if there are any questions and I will do my best to explain.