At its 80th workshop in November 2017, the ALTS dealt with the question of whether there is a misleading trace of milk or wheat with simultaneous labelling as “lactose-free” or “gluten-free”.
“Lactose-free” & “gluten-free”
As a result, the indication “may contain traces of milk” with simultaneous labelling as “lactose-free” is permissible and does not constitute a contradiction. The same applies to the label “May contain traces of wheat” if the product has been labelled “gluten-free”. If the current conditions for the terms “lactose-free” and “gluten-free” are met, there is no misleading evidence for milk or wheat. The indication “gluten-free” is a claim with a legally established limit value of 20 mg/kg according to Regulation (EC) No. 828/2014.
The background for this decision is that the medical terms “gluten intolerance” or “lactose intolerance” and “milk protein allergy” or “wheat allergy” must be objectively distinguished.