For Amber Waves of Grain: U.S. Farmers Will Not Be Impacted by FDA Rulemaking Requiring the Labeling of Gluten

Jax Bari

"Today, American farmers feed the world, American companies lead the world, and American energy powers the world. This economic growth has been a force for technology, health and agriculture innovations that have increased U.S. life expectancy by more than 30 years compared to 1900. But the same forces of modernization and industrialization have also introduced threats to our health and revealed growing inefficiencies in our ability to respond to them." -- The MAHA Report

We are pro farm and pro farmer. We want farmers to keep growing, and keep feeding the words. We also want 729,000 American kids with Celiac Disease to grow up safely. To Make America Healthy Again, we have petitioned the FDA to require the labeling of Gluten on all food products in the United States, just like Gluten must be declared as a Major Food Allergen on all packaged foods in 87 other countries.

To those who may worry that Celiac Journey's requested rulemaking to require the labeling of Barley, Rye and Oats could potentially hurt farmers, we have not seen any evidence to suggest that being pro-labeling of Gluten and pro-farming are at odds with one another. To the contrary, we believe that any concern that farm income could be hurt by requiring the labeling Gluten is a red herring. Celiacs need to avoid all Gluten containing grains, but Celiacs consume other Celiac safe crops such as corn and rice.

Wheat is Even More Central to Modern Civilization than Oil

In evaluating the public health importance of the requested action in Celiac Journey's Citizen Petition to require the labeling of Barley, Rye and Oats as Major Food Allergens, it is also instructive to read what the Washington Post reported on May 6, 2022 about Wheat,

"Wheat is a valuable global commodity, both symbol and sustenance. In 2009, after a spike in prices, a [U.S.] Senate subcommittee proclaimed wheat 'even more central to modern civilization than oil.' Bread is a measure of stability ­or instability. And that's what makes it such a powerful propaganda tool. 'Wheat,' as one agriculture economist [Bob Utterback] wrote during the panic of 2010, 'is all about fear.' The real danger is not a global wheat shortage; it's a fear-driven panic that pushes up prices and cuts off the truly hungry."

Wheat is very important to the U.S. and global economies, and Wheat has been required to be labeled in in the U.S. since the Food Allergen Labeling and Consumer Protection Act became effective on January 1, 2006. The 1999 Codex Criteria strongly recommended that Gluten containing grains (Wheat, Barley, Rye and Oats) should be required to be labeled on all packaged foods, and today Gluten Containing Grains (including Wheat, Barley, Rye and Oats) are required to be declared on all food product sold in 87 other countries.

Statistics on Wheat

As of March 2025, the USDA found, "Wheat ranks third (behind corn and soybeans) among U.S. field crops in planted acreage, production, and gross farm receipts." In 2022, Wheat generated $13.46 Billion in farm income. According to the USDA, "the general downward trend in wheat plantings over the last two decades is attributable to lower relative returns for wheat, changes in Government programs that give farmers more planting flexibility, and increased competition in global wheat markets." Since 2000, nearly 90 percent of world wheat exports were accounted for by the United States, the European Union, Canada, Australia, Argentina, and the former Soviet Union. The USDA does not appear to have found any data showing or even suggesting that there has been any impact on planted acreage, production, and gross farm receipts from the production of Wheat because Wheat is a Major Food Allergen. The bottom line is that Wheat market in the United States has consistently remained very strong over time, including after Wheat was required to be labeled as a Major Food Allergen.

Statistics on Barley, Rye & Oats

According to data from the Agricultural Marketing Resource Center, around 75.0% of the Barley grown in the U.S. is used for malt production, with the remaining amount allocated to livestock feed or human food. The share used for human food is relatively small, accounting for about 4.0%. In 2022, Barley generated almost $919 Million in U.S. farm income.

According to data from the Agricultural Marketing Resource Center, "Globally, rye is considered a minor crop compared to wheat and acreage continues to decline in most regions of the world." In 2022, Rye generated almost $109 Million in U.S. farm income.

In 2022, Oats generated almost $199 Million in U.S. farm income.

Wheat accounted for $13.46 Billion in US farm income in 2022, and Barley, Rye and Oats together amounted to $1.23 Billion. In comparison to Wheat, U.S. farm income in 2022 for Barley, Rye and Oats collectively totaled about 10.9% of the overall 2022 U.S. farm income from Wheat.

As it pertains to Barley, Rye and Oats, it is also instructive to view these commodities in the context of 2022 U.S. farm income generated by leading crops. In other words, the required labeling of Wheat has not hurt Wheat's value, including with U.S. farm income. Therefore, the evidence strongly suggests that the requested required labeling of Barley, Rye and Oats in the U.S., just like labeling is required for Barley, Rye and Oats in 87 other countries, will not adversely impact the value or U.S. farm income generated from Barley, Rye and Oats.

"America’s farmers and ranchers are committed to producing safe and affordable food for consumers in the U.S. and around the world." -- Farm Bureau

2022 U.S. Farm Income: Leading Crops

Crops	U.S. Farm Income
Corn	$88,573,921,000
Soybeans	$62,374,502,000
Fruits and nuts	$26,548,625,000
Vegetables and melons	$22,401,148,000
Wheat	$13,461,763,000
Hay	$9,821,279,000
Cotton	$8,906,913,000
Rice	$3,346,959,000
Peanuts	$1,523,138,000
Barley	$918,748,000
Oats	$199,003,000
Rye	$108,822,000

Source: USDA, Economic Research Service, https://data.ers.usda.gov/reports.aspx?ID=17845, Last Accessed on September 9, 2023.

According to The New York Times, "because use of the gluten-free claim is voluntary, many foods that are in fact gluten-free might not be labeled as such." The Celiac community just wants to know whether Barley, Rye and Oats are in food products so that we can make informed and safe choices.

Gluten Grains - All About Fear to the Celiac Community

To paraphrase the words of agriculture economist Bob Utterback, Gluten Containing Grains are "all about fear" to the Celiac community since even eating a crumb of Gluten Containing Grains is like eating poison! To that end, we have a right to know whether all food products sold in the U.S. have Gluten Containing Grains, and the way to accomplish that is through labeling Gluten as a Major Food Allergen on all packaged foods in the U.S., just like Gluten must be declared on all food labels in 87 other countries worldwide.

"Eating without fear is our hope! Food insecurity happens every day for Celiacs because of the constant threat of cross contact with Gluten, 80% of foods have Gluten in them, the high price of Gluten Free food, the limited availability of Gluten Free food, and moreover Gluten is not required to be labeled on packaged foods in the U.S. like it is in Canada and across Europe." -- Jax Bari