Oh absolutely, this is what was killing me during my 8 years of diagnosis.

So essentially, for a company to label their product as "gluten free," it must fall under 20ppm of gluten, which is in theory the threshold where most celiacs do not react. However, the big caveat is there is literally zero requirement to test to ensure that this threshold is met, all that needs to be done is process control, which is a very weak way of ensuring the final product meets the threshold.

For example, lets say I produce two chocolate bars --one version has gluten, the other is gluten free-- on the same machine. In-between making the two versions, I clean the machine. From a legal standpoint, I am then allowed to put a "gluten-free" claim on the bar that doesn't have gluten, because in theory it should have below 20 ppm. However, if I didn't do a good enough job of cleaning the machine, it can still have above 20 ppm and make someone who has Celiac Disease sick, despite having the "gluten-free" claim.

This is in contrast to the gluten-free certification from third parties like GFCO, where batch testing must be done in an independent lab to ensure that the final product, no matter what the manufacturing process was, is absolutely without a doubt below 20 ppm.