'Free From' claims: Sugar free, Gluten Free. What you should know.

Continuing with a focus on consumer desires to recognise what is in the food they’re eating. Here we have a look at free-from claims.

“Free from” claims are claims such as gluten free, sugar free, preservative free. They address a broad variety of consumer concerns or desires ranging from true medical requirements, to dietary preferences or personal values. These include:

  • Allergens such as gluten and dairy
  • Dietary sensitivities such as, lactose
  • Ingredients associated with healthy lifestyle perceptions (e.g. gluten)
  • Ingredients considered undesirable such as artificial ingredients, food additives or nutrients such as sugar
  • Production practices e.g. avoiding added hormones, pesticides or GMOs

Why make a “free from” claim?

Data from IPSOS Food Chat research showed that preservatives in food and drinks were a high priority for Australian consumers although, had fallen out of the top 10 in the past year. For 23% of consumers’ dietary requirements such as gluten, dairy free were a top purchasing consideration.

The “free from” messages also align with consumers’ desires for more natural foods i.e. foods free from artificial ingredients or those they believe are harmful.

What can I say?

Free from claims, like all claims must comply with the consumer protection regulations and not be deceptive or misleading. In some cases, they must also comply with criteria set out in the Food Standards Code. The Food Standards Code contains conditions for making four “free” claims. These are:

Gluten free

A food claiming gluten free must not contain any detectable gluten; oats or oat products; or cereals containing gluten that have been malted, or products of such cereals.

Lactose free

A food claiming lactose free must have no detectable lactose.

Saturated fat free

A food claiming saturated fat free must contain no detectable saturated or trans fat.

Trans fat free

A food claiming trans fat free must contain no detectable trans fat and also be low in saturated fat that is, have a saturated fat content of no more than 0.75g per 100 mL of liquid food; or 1.5g per 100g of solid food; or 28% of total fat as saturated fat.

What to watch out for

Hormone free

Chicken, beef and pork are not hormone free. No animal meat is hormone free. Chickens, cows and pigs are animals. Animals, like humans, naturally have hormones to regulate the natural processes in their bodies. In most cases the actual message is: No added hormones but even with this you need to make sure you can substantiate it.

Sugar free

The Food Standards Code has requirements for making % sugar free claims. These are that the product meets the requirements for a low in sugar claim. That is, that is has no more than 2.5g of sugars per100 mL for liquid food; or 5g of sugars per 100g for solid food. You may not have added sugar to your product but that doesn’t mean it’s sugar free. Sugar occurs naturally in many foods such as fruit and dairy products. Thinking about claiming no added sugar? The Food Standards Code also contains requirements for foods claiming no added sugar. One of these is that the food contains no added honey, malt or concentrated fruit juice (unless your product is one of a few exempt beverages). This is something I see many companies come unstuck with – just because you didn’t add table sugar doesn’t mean you can say no added sugar.

Gluten free

As mentioned above, the requirements for making a gluten free claim are that there is no detectable gluten. The limit of detection for gluten can be around 2ppm, that is 0.0002g per 100g. To put it in real terms that’s the amount of gluten in roughly 1/16,000ths of a slice of bread. What I’m trying to illustrate here is that the threshold is tiny (like a fly away crumb of bread tiny). My point here; if you’re claiming gluten free, you want to make sure there is no gluten in sight or at very least, that your gluten free products are very strictly quarantined from any gluten containing foods.

The health halo effect

There is no doubt that using free-from claims can create a health halo for products. While this may seem like a great benefit, it also comes with the responsibility to make sure your product is worthy of the halo. In fact, research from Mintel in the UK showed that, if a free from product is shown to be less healthy than a standard product over half of consumers would stop buying it.

There is also an inherent risk with developing products specifically to meet a pseudo health need, you are open to changes in consumer perception (today's gluten is tomorrows lactose) or a shift in media attention on the newest food enemy.

The future of “free from”

Market research is predicting that the “free-from” trend is here to stay. What is up for debate is specifically what consumers will want food to be free from. Some believe gluten free has had its day. While others predict that “free from” is now a mainstream requirement that consumers expect meaning that, companies should look to other attributes to differentiate their products.


My two cents, if the past decade of nutrition has taught us anything it is that, focusing on a single aspect of food, especially the absence of negatives rather than the presence of positives, can lead to confusion and unintended consequences. Surely it’s time that we stopped fearing single ingredients or nutrients and started focusing on whole foods - I promise you the story here is much more compelling.