The classification split follows the intended end use declared at entry. Food-grade product triggers FDA food-facility registration requirements for the foreign manufacturer and FSMA Foreign Supplier Verification Program obligations for the US importer. Non-food wheat starch used in industrial applications such as adhesives or textile sizing does not carry those FDA requirements, though the physical product may be identical — making accurate end-use documentation essential.

Wheat starch inherently contains residual gluten protein, so it does not meet FDA's gluten-free threshold of less than 20 ppm unless it has been specially processed and tested to that standard. Importers supplying gluten-free food manufacturers should obtain gluten-content certificates from the supplier and ensure that labeling claims on finished products comply with FDA's gluten-free labeling rule.