Wheat Gluten, Dried or Not

Wet (undried) wheat gluten has a much shorter shelf life and is rarely traded internationally in significant volumes; virtually all commercially traded wheat gluten is the dried, powdered 'vital' form. The SITC heading covers both states, but importers should specify the moisture content and form in their commercial documentation to avoid classification disputes and to meet FDA labeling requirements.

Yes. Wheat is one of the major food allergens under the Food Allergen Labeling and Consumer Protection Act, so wheat gluten used in finished food products must be declared on the label. Importers of food-grade wheat gluten should ensure their supplier documentation clearly identifies the product as a wheat-derived ingredient, and they should maintain Foreign Supplier Verification Program records as required by FDA food safety regulations.