FDA Labeling Law Post 1: "Verbiage"

I get a lot of questions regarding the FDA labeling law and how it should be interpreted. Most of these answers can be found on the FDA website's Q&A page, but I thought I would cover some of them a little more in depth.

Today, I will be talking about "verbiage" because it is one I misunderstood until recently. This is the question and answer on the FDA website:

(Full text of this below if you'd like to copy and paste)

 Previously, my understanding was that any form of stating gluten free such as "naturally free of gluten" meant the same exact thing as "gluten free" meant. While researching the topic, I discovered I was wrong. I definitely want to look further into this. They state the statement needs to be "truthful and not misleading," but what does that ultimately mean? If it's made without gluten-containing ingredients, are they are allowed to say that with zero regard to manufacturing practices? Could it potentially have a large amount of cross contamination from another product made on the same lines?

On a sidenote, this is such a misunderstood topic that I read an argument regarding the use of a dash in stating gluten free and how it determined whether or not they needed to follow the labeling laws (as in with it or without it didn't need to: "gluten free" vs "gluten-free"--I can't remember which way they argued was correct).  Please correct me if I'm wrong, but I've never read anything in the FDA guidelines pertaining to the use of dash when stating a product is gluten free.

As promised, here is the text of the verbiage above if you'd like to copy and paste the info:
Are statements like “made with no gluten-containing ingredients” or similarly “not made with gluten-containing ingredients” permitted on labels of foods bearing a gluten-free claim?
Yes. Neither the final rule nor FDA’s general food labeling regulations prohibit the use of a statement like “made with no gluten-containing ingredients” or “not made with gluten-containing ingredients” on any food products, provided that the statement is truthful and not misleading. However, unless the label of the food including such a statement also bears a gluten-free claim, consumers should not assume that the food meets all FDA requirements for the use of the “gluten-free” claim.

I was never thoroughly impressed with the labeling law, but it was definitely a huge step forward. It was something that was needed to avoid companies labeling anything as gluten free (even if it was a "regular" product--if you want to read a story of this happening, click here). My worry is what happens when companies start working around the rules so that they don't have to comply AND they're not breaking the law. It would be great if we could come together as a united gluten free community to encourage companies to make things as safe as possible while being as straightforward as possible.

I highly recommend using cautious when purchasing an item that does not specifically state gluten-free. Research the product just as you would any product that did not bear any type of gluten claim by checking with the manufacturer and confirming their manufacturing practices and labeling policies. It is definitely always better to be safe than sick!