rich emollient used in the management of eczema, psoriasis and other dry skin conditions.


At the recent judging session for FreeFrom Eating out Awards we had a heated discussion about oats and whether they came under the Top 14 allergens banner.

I thought that oats were not in the Top 14 allergens but others disagreed.
It turns out I was wrong. Very wrong.

Oats do not contain gliadin, the protein in gluten containing cereals.  It does contain avenin and can cause problems for some coeliacs.

What is gluten, are oats gluten and what about wheat?

I know that oats don’t contain gluten and many coeliacs can tolerate oats. So why would they be in the Top 14 allergens?

I also know that gluten is not technically an allergen… you can’t be ‘allergic to gluten’ as such but you can have coeliac disease which means you cannot eat any gluten. There is no cure for coeliac disease – the only solution is life long avoidance of all gluten.

Some people are ‘gluten intolerant’ and may have irritable bowel symptoms after eating any foods containing gluten.

I know that gluten covers a range in cereals, including wheat, spelt, rye, barley and kamut. These grains all contain gliadin, the protein in the grain that makes is it such a problem for coeliacs and so amazingly soft, springy and delicious for everyone else who can enjoy bread, cakes and pastry made with gluten containing cereals.

Coeliac UK describe gluten as “A protein that is found in the cereals wheat, barley and rye.” So no mention of oats or kamut there.

Since I have a wheat allergy I know that this is quite a common allergy, yet if you look at the Top 14 allergens that are covered in the Allergen Regulations wheat is not listed but it does come under gluten in the list.

What are the Top 14 allergens?

  1. Cereals containing gluten, namely: wheat (such as spelt and Khorasan wheat), rye, barley, oats
  2. Crustaceans for example prawns, crabs, lobster, crayfish
  3. Eggs
  4. Fish
  5. Peanuts
  6. Soybeans
  7. Milk
  8. Nuts; namely almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia (or Queensland) nuts
  9. Celery (including celeriac)
  10. Mustard
  11. Sesame
  12. Sulphur dioxide/sulphites, where added and at a level above 10mg/kg in the finished product. This can be used as a preservative in dried fruit
  13. Lupin which includes lupin seeds and flour and can be found in types of bread, pastries and pasta
  14. Molluscs like clams, mussels, whelks, oysters, snails and squid

So what on earth is going on?

Thanks to Michelle Berridale-Johnson of the FreeFrom Eating out Awards for trying to explain this to me because I’m baffled.

This is what she very kindly explained to me:

“It is actually very confusing as effectively oats are classed as both gluten containing and gluten free! Below are the relevant paras from the regs and you will see that oats are included in the ‘cereals containing gluten’ – yet oats are also classified as gluten free provided that they have not been on contact with, and therefore contaminated by, gluten from wheat or other sources… The thinking of those who claim them to be gluten free is that they do not contain gliadin, the protein which ‘causes’ coelaic disease, but avenin which is a very similar protein but not actually the same and therefore can be tolerated by many people who would react to gliadin.

Wheat as such is not in the top 14, but it is one of the cereals containing gluten which are!”

Cereals containing gluten

28. The Regulations (Annex II to EU Regulation No. 1169/2011 as amended by Commission Delegated Regulation (EU) No.78/2014) define these as: wheat (such as spelt and Khorasan wheat), rye, barley and oats or their hybridised strains. Spelt and Khorasan are types of wheat, which are not suitable substitutes for people with coeliac disease and/or wheat allergy.

29. Cereals containing gluten will be declared in the ingredients list using the specific name of the cereal, i.e. wheat (such as spelt or Khorasan), rye, barley or oats. Where ‘spelt’, ‘Khorasan’ and ‘Kamut’ have been used; the inclusion of a specific reference to wheat would be required; for example ‘spelt (wheat)’ or ‘Khorasan wheat’ and ‘Kamut (wheat)’.
30. The voluntary inclusion of gluten within the ingredients list following the mandatory declaration of a cereal containing gluten is possible. However, the regulation requires that it is the cereal that should be emphasised, rather than the gluten; for example ‘barley (gluten)’. When using a signpost to allergen information, indicating the presence of cereals containing gluten is also permitted as outlined in the BRC/FDF guidance document.

Thanks again Michelle. This really did help me, sort of.

What it does mean is that Oats should be marked in bold on any packaging and labels for food for retail and food service. I’m not sure the retailers really get this one either as I’m sure oats are not in bold all the time.

Still confused? Me too, and avenin the little oat kernal is confused too.

But I guess it doesn’t really matter as long as people with coeliac disease or a wheat allergy are protected by the new regulations. I think it’s the copy writer in me… I like everything to be just so, correct and accurate and this is just a way of getting gluten and wheat in under one banner because the effect will be the same and kill many birds with one stone. Otherwise it would the Top 15 allergens and contain gluten (for the coeliacs) AND wheat for the (wheat allergics) which is actually a much better number anyway. OR you’d need Allergen Regs and Gluten Free regs for coeliacs.

So after much deliberation I have had to accept defeat on this one. The allergen regs do make sense but technically there are few annoying little discrepancies which make my copy writers eye twitch…

I hope this little blog has helped some of you. It was a good lesson for me.



An allergy and health writer and freelance copywriter, Ruth is passionate about helping those with allergies and food intolerances take control, embrace their condition, and learn to live with and love who they are. It can be very lonely finding you have allergies and discovering what helps you can be a life long journey. What works for one person won't work for another, so after trying nearly every allergy treatment under the sun and finding hours of research necessary to keep abreast of what's going on, Ruth started writing her blog, What Allergy? in April 2009. Ruth has life threatening allergies herself to all nuts, all diary, tomatoes and celery and knows first-hand what it's like to have an anaphylactic attack. Voted in the Top 5 UK allergy blogs by Cision UK in 2011, What Allergy is packed full of interesting articles, hints and tips and product reviews which are a must read for anyone with allergies, food intolerances or sensitivities, asthma and eczema. From subjects such as "What is celery allergy?" to "Surviving a holiday abroad with allergies", it's packed with useful and interesting information. You can register free for a weekly newsletter by visiting her website and also keep in touch by following her on Facebook and Twitter.

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