Why the barley-based label requirement limits consumer understanding
It's one of the first things we hear about Kukko when we are trying to tell the brand story, "if it's not labelled Gluten Free, it's not safe for me."
This is one of the more frustrating hurdles when attempting to introduce a barley-based product to gluten free consumers. The market has been trained by painful personal experience that barley-based gluten reduced beers are not really safe for celiacs and the government offers no other means of classifying a product like Kukko - which has been safely consumed by celiacs in Finland for over a decade.
A brief history...
Around 2012, a few brewers with good intentions discover that clarifying enzymes commonly used in breweries for removing chill haze also return a <20 part per million result on the R5 Competitive ELISA test for gluten. Having no reason to distrust the test results, they petitioned The Alcohol and Tobacco Tax and Trade Bureau (TTB) for the right to call their product gluten free. The TTB, realizing they don't have their hands around this issue, essentially punts to the FDA for clarification and, in the interim, allows beers made with these enzymes to label themselves as Crafted to Remove or Reduce Gluten. In fact, Oregon's Omission brand of beers (one of the first of these types of beers made) actually wins the argument at the state level and labels itself fully "Gluten Free."
As gluten experts and celiac disease specialist have told us, these enzymes go beyond simple fermentation to further hydrolyze the gluten protein (essentially making it smaller), but they do not actually remove the offensive protein. Said another way, the enzymes fool the traditional gluten test and offer a false sense of security to the gluten free...A fact that many celiacs (including the author of this blog post) found out the hard way.
The challenge for Kukko is that while it is brewed with barley, locally sourced Finnish barley to be exact, it DOES NOT and HAS NEVER used these enzymes as part of the gluten removal process. The gluten found in the malted barley is removed through a proprietary and wholly natural process that was discovered by the brewer in 2001 - long before these enzyme short-cuts were ever imagined. There are no weird additives or unproven processing aids. Everything involved in this proprietary process is approved by the Beer Institute and the ingredients are simply barley, water, hops and yeast. To put it plainly, it is uniquely a great beer that is surprisingly low in gluten, with a significant track record of safe consumption.
Now the European standards are not recognized by the TTB or FDA and maybe they should not be. This is an entirely different country with its own culture, laws and consumer expectations. However, what is the value of more than 15 years of market data? Doesn't the FDA typically require rigorous market testing of many substances before they rule them as safe for sale to U.S. consumers? If celiacs in Finland have a track record of safe consumption, regardless of unique laws and cultural differences, shouldn't that account for something? Maybe, but right now it's just not that simple.
Barring a scientifically definitive test that can absolutely isolate what we understand to be more than 500 types of gluten that can be offensive, the answer to the question of the utility of a safety track record is probably a personal one.
Today, there simply is no easy way to explain the alternative that Kukko offers to the enzyme beers. Taste proves the point versus the sorghum, millet and rice brewers, but there is no test that is currently sufficient to prove the ppm point to the FDA/TTB. Until there is, consumers like this writer will have to rely on personal judgement. To that point, what gives me the confidence to bring this product to market in the U.S. is the fact that is made in an utterly different way, has a 15 year safety record with real Celiacs and every beer that will be sold in the U.S. will have passed five batch tests resulting in a less than 20 ppm of gluten result before it ever reaches our shores. I've even had it tested here at an independent lab and had the same <20 ppm results.
More importantly to me personally, I have been drinking Kukko for 10 years with zero negative outcomes and my doctor continues to tell me my test results are good. What do you think? Is 15 years of market data worth a try? We hope you think so and that you realize the same great taste and asymptomatic outcomes that we do. Then, we have to believe that the Kukko difference will spread by word of mouth, because lumping Kukko in with the enzyme beers that are Crafted To Remove Gluten is simply not that helpful to gluten free consumers or to innovative brands like Kukko.