Wheat allergen labeling on US food packs

The short answer

Wheat is the FALCPA cereal. Enriched flour, bread, soy sauce, malt vinegar from wheat, and many spice rubs need the word wheat. Barley and rye are not FALCPA majors; they still matter if you make a gluten-free claim.

Where this shows up in a real kitchen

US labels miss wheat in soy sauce, beer batter, flour dusting on pretzels and “natural flavor” in some mixes. A gluten-free claim is 21 CFR 101.91, a different rule from FALCPA wheat declaration. You can have wheat declared and no gluten-free claim; you cannot have a gluten-free claim and wheat as an ingredient.

The US rule

Declare wheat by the common name. Spelt and farro are wheat. FDA’s allergen page lists wheat derivatives. Gluten-free means the food meets the <20 ppm rule and other 101.91 conditions — not merely “we used oat flour once”.

How to apply it

Read every sauce and coating. Put flour (wheat) or Contains: wheat. If you switch to a wheat-free soy sauce, reprint. Do not print GLUTEN-FREE on a pack that still lists wheat. Keep rye bread’s rye in the ingredients list even though rye is not a FALCPA major.

1. Map flour, bread, soy sauce, malt and spelt to wheat.
2. Declare wheat on those SKUs.
3. Keep gluten-free claims on a separate checklist.
4. Do not call oats wheat; do check oats for wheat cross-contact if claiming gluten-free.

Worked example

Soy-glazed salmon, sealed: salmon, soy sauce (water, soybeans, wheat, salt), sugar, garlic. Contains: fish (salmon), soy, wheat. A “gluten-free soy glaze” version uses a wheat-free sauce and drops wheat from Contains — and only then considers a gluten-free claim if the process meets 101.91.

Writing Contains: gluten instead of wheat

FALCPA’s word is wheat. Gluten is a gluten-free-claim word. They are not interchangeable on a Contains line.

Questions