"May contain traces of gluten": what to do with that statement?

It is the line that makes you hesitate in the aisle: “may contain traces of gluten”, “made in a facility that handles wheat”, “may contain cereals containing gluten”. It is everywhere, it does not mean the same thing depending on the product carrying it, and the most confusing part is that it has no legal definition.

Two statements with different status

Two things the label puts side by side need separating.

Allergen declaration is compulsory and precise: if wheat is an ingredient, it must be written, emphasised, in the list. A manufacturer who omits it is breaking the law.

Precautionary allergen labelling, “may contain”, “traces”, “facility that handles”, is voluntary. No European regulation requires writing it, none defines from what level of risk it applies, none sets a threshold. It rests on the manufacturer’s responsibility and caution, and on its legal advice. Our guide to reading gluten-free labels mentions it in a line; this article dwells on it.

Consequence: two products identical in real risk may one carry the statement and the other not. And two products carrying the same statement may range from “our analyses never found anything, but the plant is mixed” to “we never tested”.

The case that seems absurd, and is not

A product may bear both “gluten-free” and “may contain traces of gluten”. That is not a contradiction.

The “gluten-free” claim is regulated: it commits the manufacturer to a content below 20 mg/kg in the finished product, as sold, so traces included. Implementing Regulation 828/2014 does not care where the gluten comes from, ingredient or contamination: it looks only at the result. A “gluten-free” product with a traces statement is therefore compliant, and under 20 ppm; the traces statement simply signals that manufacturing is not in a dedicated environment, and that the manufacturer prefers to say so.

Conversely, a product with no statement at all is not safer. It is not committed to any threshold. The paradox is real: the product that “admits” traces and commits to 20 ppm is often more reliable than the one that says nothing.

How to decide

A simple grid, from safest to least safe:

1. “Gluten-free” + Crossed Grain: regulatory commitment plus an external audit by a patient association. The most solid level, and here is why.
2. “Gluten-free” alone, with or without a traces statement: regulatory commitment under 20 ppm, on the manufacturer’s responsibility. Safe for the vast majority of people with celiac disease.
3. No statement, naturally gluten-free ingredients (rice, vegetables, cheese, raw meat…): generally safe, but nothing is guaranteed for processed products made in a mixed plant; that is the supply-chain logic we detail for quinoa, rice and corn.
4. “May contain traces” without a “gluten-free” claim, on a processed product: the risk is not quantified. Not necessarily dangerous; unknown. Caution means preferring a product from category 1 or 2 when one exists.

The factor that weighs most, and that the label does not say: frequency. An unknown trace in a product eaten once a month does not carry the same weight as in the morning bread. The 20 ppm threshold was calibrated for daily consumption; it copes badly with stacking “unknown” products at every meal.

What the Nutrixe scanner does

The scanner follows the grid above. A product bearing an official “gluten-free” label gets the green verdict, even with a traces statement: the threshold applies to the finished product. A product without a label but with a “may contain” statement gets a separate amber verdict, “possible traces”, distinct from the red “contains gluten”, and the app recommends avoiding it if you have celiac disease. It does not turn “may contain” into “contains”, but it does not erase it either: it is a third state, and it is the right one.

In short