We've been fielding some member questions about reconstitution, so we thought it might be helpful to explain the WGC's position about this approach. "Reconstitution" is the practice of buying bran, germ, and endosperm separately and combining them "at the mixing bowl" in a food factory. In theory, this can result in a whole grain flour that meets the FDA's definition of whole grain: all of the bran, germ, and endosperm in their original proportions.

In practice, however, there can be some challenges. Since all grains differ in their original proportions, and different mills may include different grain fractions in their bran or endosperm, it may be difficult for even the most conscientious companies to ensure they are achieving the original proportions. Nutritional analysis, with a comparison to standard whole grain flour, may be necessary.

Even so, one big hurdle remains: labeling. In a routine meeting initiated by the WGC in 2012, FDA stated that all ingredients purchased separately must be listed separately on the ingredients list. This would mean that the ingredient list of a product made with reconstituted whole wheat flour would read, "Wheat flour, [other ingredients], wheat bran, [other ingredients], wheat germ. As you might expect, we could not allow the Whole Grain Stamp to be used on such a product because it would cause consumer confusion if the Stamp were to appear on a product where there are no whole grain ingredients listed. Contact Cynthia Harriman ([email protected] or 617-896-4820) if you'd like any further information about the WGC's position on reconstitution.