Beyond the Big Nine: The Push for Comprehensive Gluten Labeling in U.S. Food Policy

On July 31, 2026, a significant legislative shift aimed at protecting millions of Americans with celiac disease and gluten sensitivity began to take shape. Congresswoman Anna Paulina Luna (R-FL) introduced the Food Allergy Safety, Treatment, Education, and Research (FASTER) Act of 2026, a bipartisan effort designed to overhaul how the U.S. Food and Drug Administration (FDA) mandates the disclosure of gluten-containing grains on packaged food labels.

The proposed legislation seeks to amend the Federal Food, Drug, and Cosmetic Act (FD&C Act) by fundamentally redefining what constitutes a “major food allergen.” By replacing the narrow focus on "wheat" with the broader category of "gluten-containing grain," the bill would require manufacturers to explicitly list barley, rye, oats, and crossbred hybrids—such as triticale—alongside wheat. This move aims to eliminate the "hidden" gluten sources that currently evade clear labeling, creating a safer landscape for the estimated 25.7 million Americans living with gluten-related health conditions.

A Chronology of U.S. Allergen Regulation

To understand the gravity of the 2026 FASTER Act, one must examine the evolution of federal allergen mandates. Since the passage of the Food Allergen Labeling and Consumer Protection Act (FALCPA) in 2004, which took effect in 2006, the U.S. has mandated the labeling of the "Big Eight" allergens. However, for two decades, this framework has remained stagnant regarding the inclusion of non-wheat gluten grains.

The 2019 FASTER Act Precedent

The legislative momentum for the 2026 bill draws heavily from the FASTER Act of 2019. That landmark legislation was a watershed moment for food safety, as it officially recognized sesame as the ninth major food allergen. The 2019 Act not only mandated the clear disclosure of sesame in ingredient and "contains" statements but also established a formal research agenda focused on the immunology and clinical management of food allergies. The success of this act in protecting a vulnerable population has served as a primary blueprint for advocates pushing to expand gluten-related protections.

The 2025 USDA-FSIS Directive

While the FDA handles general packaged food, the U.S. Department of Agriculture’s Food Safety and Inspection Service (USDA-FSIS) has also been tightening its oversight. In September 2025, the agency issued a revised directive titled, "Ongoing Verification of Product Formulation and Labeling Targeting the Nine Most Common (‘Big 9’) Food Allergens." Notably, this directive went beyond the statutory "Big 9" by instructing inspectors to verify that establishments producing meat, poultry, and egg products were also managing and labeling for gluten. This regulatory overlap highlighted a growing disconnect between federal agencies and the lack of a unified, comprehensive mandate for gluten labeling.

Supporting Data: The Case for Transparency

The urgency behind the 2026 FASTER Act is rooted in a massive public health crisis. Approximately 25.7 million Americans grapple with celiac disease, non-celiac gluten sensitivity, or IgE-mediated wheat allergies. For these individuals, accidental ingestion of gluten is not merely an inconvenience; it is a clinical hazard that can trigger systemic inflammation, intestinal damage, and severe allergic reactions.

Global Standards vs. U.S. Policy

The United States is currently trailing behind international best practices. According to global food safety data, 87 countries—including Canada, the United Kingdom, and many nations within the European Union—already mandate the labeling of barley, rye, and oats. In these jurisdictions, consumers have the benefit of transparent, consistent, and clear disclosures that allow them to navigate grocery aisles with confidence. By failing to adopt similar standards, the U.S. has left its citizens to navigate a marketplace where ingredients like "natural flavors" or "barley malt extract" can mask the presence of hazardous grains.

Official Responses and Political Momentum

Congresswoman Luna, who has publicly shared her own struggles with gluten intolerance, framed the bill as a matter of consumer dignity and public safety. "This is a real and serious issue," Luna stated upon the bill’s introduction. "It is time the food industry respected that. We need transparent labeling so Americans can make informed decisions and safeguard their health."

The 2026 FASTER Act is not operating in a vacuum. It is part of a broader legislative trend focused on food transparency. Other notable bills currently moving through the halls of Congress include:

• H.R. 9048, the Celiac Safety Act of 2026: This bill mirrors the language of the FASTER Act, specifically targeting the amendment of the FD&C Act to include gluten-containing grains within the definition of a "major food allergen."
• H.R. 8385, the Food Labeling Modernization Act of 2026: This broader bill, currently referred to the House Energy and Commerce Committee, focuses on the "front-of-package" labeling experience, suggesting a shift toward making nutritional and allergen information more visible to the average shopper.

Implications for the Food Industry

If the 2026 FASTER Act is signed into law, the impact on the American food supply chain will be profound. The shift from a voluntary "gluten-free" labeling framework to a mandatory allergen disclosure system would force a paradigm shift in how food companies approach product development.

From Labels to Documentation

Industry experts, including attorneys Claudia Lewis and Richard Starr, have argued in Food Safety Magazine that the industry must prepare for a transition from "label-driven" compliance to "documentation-driven" compliance. Currently, many companies rely on simple label templates. However, under the proposed requirements, compliance will necessitate a rigorous overhaul of:

1. Supplier Approval: Manufacturers will need to audit their supply chains to ensure that incoming raw ingredients are not contaminated with barley, rye, or oats.
2. Manufacturing and Sanitation: Facilities will need to adopt more stringent cleaning protocols to prevent cross-contact, which is currently a major blind spot for oats—a grain that is frequently cross-contaminated in the field.
3. Quality Assurance (QA): QA departments will be required to maintain extensive, traceable records that prove an allergen-control program is in place, specifically addressing the "hidden" gluten grains.

The FDA’s Expanding Agenda

The FDA is already laying the groundwork for this transition. In 2026, the agency issued a Request for Information (RFI) regarding gluten cross-contact and labeling. This RFI serves as a clear signal that the agency is moving toward formal rulemaking. As the FDA continues to develop its "Allergen Agenda," food manufacturers should expect increased scrutiny regarding how they manage gluten in their plants. The days of treating gluten-sensitive consumers as a niche market are ending; the future of the industry will be defined by comprehensive, transparent, and rigorous allergen management.

Conclusion: A New Standard for Public Health

The introduction of the FASTER Act of 2026 represents a critical step toward aligning U.S. policy with global standards. By acknowledging the health risks associated with barley, rye, and oats, lawmakers are acknowledging the reality of a modern health crisis. For the millions of Americans navigating the daily risks of gluten exposure, this bill offers more than just a label—it offers the promise of safety, the power of information, and the recognition of a widespread, often overlooked, medical necessity. As the bill moves through the legislative process, the food industry must prepare for a new era of transparency where consumer safety is the ultimate metric of success.