Allergen-Free, Gluten-Free and Precautionary Statements
Fortification of Gluten-Free Foods

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Section D.03.003 of the FDR allows the fortification of gluten-free foods that:

  • are foods for special dietary use – meaning foods that have been specially processed or formulated to meet the requirements of B.24.018 of the FDR;
  • do not have a standard prescribed in the Regulations, and
  • are not advertised to the general public

The intent of this regulation is to allow flour replacements such as soy flour to be fortified. Foods that are inherently "gluten-free" may not be fortified under this provision, even if they are unstandardized.

Examples:

  • It is acceptable to fortify gluten-free crackers to replace the nutrients that would have been in enriched wheat flour, when wheat ingredients are replaced with a gluten-free substitute. Crackers are not standardized foods.
  • Although it is possible to label a salad dressing product as a "gluten-free" food when it processed and formulated to replace any gluten ingredients and components provided for in the standard (FDR B.07.042), salad dressing may not be fortified since it is a standardized food.

Health Canada does not specify fortification levels, nor specific nutrients that may be added to gluten-free foods that may be fortified. However, as a general rule, fortification of gluten-free foods should be done to achieve levels of enrichment equivalent to those required in flour, and corresponding to the amount of flour replaced. Companies that are considering fortification beyond the nutrients and amounts permitted for flour should contact Health Canada for advice. Over-fortification that poses a health risk may be subject to enforcement action by the CFIA.

A product is considered to be a food for special dietary use with respect to the absence of gluten when it is a type of food that could otherwise contain gluten, due to product formulation or cross-contamination, but for which the manufacturing process or formulation has been modified to remove the gluten. Foods that are inherently gluten-free are not considered foods for special dietary use for this purpose.

Advertising of Gluten-Free Foods to the General Public

Gluten-free foods fortified according to the provisions of section D.03.003 of the FDR may not be advertised to the general public. These fortified foods may be sold at retail but may not be advertised by the store or the manufacturer to the general public. They may be advertised in magazines, newsletters and other materials targeted to individuals with celiac disease and/or to those who are on gluten-restricted diets.

Note: Other foods labelled as gluten-free (those that are not fortified or those fortified in accordance with FDR D.03.002) may be advertised to the general public.

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