See [THE LAWS OF PESACH BY RAV DAVID BROFSKY](http://etzion.org.il/vbm/english/archive/moadim70/02-70moed.htm) from etzion.org.il First part of the quote is background. > Shiur #2: The laws of Pesach. Defining chametz. Two passages in the > third chapter of pesachim discuss the definition of “chimutz” > (leavening). one passage (pesachim 48b) presents the physical > characteristics of chametz. the mishna describes the leavening process > as follows: first, the dough becomes pale, similar to the appearance > of a man whose hair stands on end out of fright. next, cracks begin > to develop on the dough’s surface, described by the mishna as “karnei > chagavim” (locusts’ antennae). the cracks then begin to increase and > merge into each other. This part of the quote is the main point: > The Rishonim and the Shulchan Arukh (451:2) rule in accordance with > the Sages (and R. Meir) regarding the definition of chimutz. it is > forbidden and punishable by karet to eat the mixture once it has > developed cracks like a “locust’s antennae.” > > > R. Yosef Karo, in the Shulchan Arukh (459:2), concludes: One should > not leave dough without it being worked, even for a moment. **as long as one is > working the dough, even for the entire day, it does not become > chametz.** If one left the dough without working it for a mil, then > it becomes chametz. the period of a mil is 18 minutes. From this we see that the halachic status of chimutz is specifically related to the appearance of the dough and not to some chemical status. The [chemical fermentation process](http://www.britannica.com/EBchecked/topic/334116/leavening-agent) of leavening will continue while the dough is being worked. So yes, the concept of chametz is to be treated as a purely halachik construct independent of the "physical" (I prefer to call it "chemical") phenomenon of yeast/gluten interaction.