Monday, April 2, 2007

Don’t Mess with Our Chocolate!

I’m not sure if you’re aware of this, but the FDA controls what fits under the definition of chocolate for sale in the United States. They want to make MOCKOLATE into CHOCOLATE.

As it is, chocolate is not an unhealthy treat. Cocoa Butter, which is composed of stearic acid, has been found to have no effect on blood lipid levels (cholesterol). Cocoa solids have been shown to have a positive effect on our bodies because of the high levels of antioxidants, insulin-like and anti-inflammatory compounds.

The new rules would completely obliterate the current definition, basically making any concoction containing cocoa solids and a fat into Chocolate. Like magic!

The rules currently state (basically) that chocolate must contain cocoa solids and cocoa butter. Other things can be in there, like milk fat and milk solids to make milk chocolate and a small amount of milk fat can be added to dark chocolate as well. The new proposal would allow products that contain NO COCOA BUTTER to be called chocolate.

We all know that these mockolate products are crappy. They don’t taste the same ... they feel oily or greasy on the tongue and don’t have the smooth buttery melt. What’s worse? They usually contain partially hydrogenated oils (trans fats) or tropical oils (saturated fats) ... these fats raise our cholesterol levels.

Why is the Chocolate Manufacturers Association pushing for this? Because it’s more cost efficient.

There’s no reason that consumers want this dilution of the standards for chocolate!

It’s all for the chocolate companies to be able to make a cheaper product, an inferior product. Think about it, have you ever picked up a mockolate product and thought, “Goodness, that’s better than real chocolate!” Have you? I thought not. There will be a few holdouts that will continue with the tried and true traditional formulations of chocolate and they’re going to be the losers. Sure, the high end companies will do okay, because they’ve always had consumers with deeper pocketbooks. But the big chocolate companies that want to make this cheap mockolate will flood the market and confuse consumers ... ultimately just frustrating us with bad experiences and wasted money (and possibly a fatter belly and clogged arteries).

You know what? The FDA doesn’t have to give the CMA what they want. You have the power to reject this ... but you have to tell the FDA!


It’s never been easier ... just visit the FDA’s public comment portion of their website and tell them that you don’t want to lose real chocolate in a sea of wax and tropical oils. You can fill out the form, or send them a letter or a fax. Here’s what you’re commenting on:

2007P-0085 - Adopt Regulations of General Applicability to all Food Standards that would Permit, within Stated Boundaries, Deviations from the Requirements of the Individual Food Standards of Identity

Just visit this page for a tutorial and some talking points ... or read through the issues and draft your own letter. The important thing to do is to tell them that this change does NOT PROTECT CONSUMERS. The use of alternate fats not only makes for crappy chocolate, it’s not good for us.

The deadline for public comment on this is

April 25th, 2007

June 25, 2007.

The FDA’s current Standards of Identity for Chocolate (not easy to read as a layperson).
The Chocolate Manufacturers Association Glossary (pretty easy to understand definitions)
Don’t Mess with our Chocolate “How To Help”
Current FDA Food Labeling Guide (they don’t have to say “imitation chocolate” any longer!)
Here are some little graphics I made that you can display on your site!

POSTED BY Cybele AT 10:58 am Tracker Pixel for Entry     CandyFDAChocolateNews

  1. This reminds me of the Friends episode,The One With The List (208):

    MONICA: Ok, this is pumpkin pie with mockolate cookie crumb crust. This is mockolate cranberry cake, and these are mockolate chip cookies. Just like the Indians served.

    RACHEL: Oh my god.

    MONICA: Oh my god good?

    RACHEL: Oh my god, I can’t believe you let me put this in my mouth.

    PHOEBE: Oh, oh sweet lord! This is what evil must taste like!
    MONICA: Now, in some of these recipes, the quantities may seem just a little unusual, uh, like these coconut mockolate holiday nut bars. I’ve indicated four cups of coconut, and four cups of crushed nut, and only, uh, one tablespoon of mockolate.

    MR. RASTATTER: Doesn’t matter.

    MONICA: What?

    MR. RASTATTER: Our FDA approval didn’t come through. Something about laboratory rats.

    MONICA: Oh, gosh, I’m sorry.

    MR. RASTATTER: Yeah, well, anyhoo, here is your check. Thank you for all the trouble you went through. Um, listen, you didn’t eat a lot of it while you were cooking, did you?

    MONICA: Well, uh, I ate some.

    MR. RASTATTER: Oh, some, that’s fine. Some is fine. Some is not a lot. So, it doesn’t burn when you pee, does it?

    So, true. smile Anyways, I sent my two cents to the FDA.

    Comment by Michelle on 4/03/07 at 12:37 pm #
  2. Thanks for the heads up. I added my comment on the FDA’s site and also put a banner linking to this page on my site. smile

    Comment by Ari (Baking and Books) on 4/04/07 at 7:07 am #
  3. Many thanks for the informative warning.  I’ve chucked my own nickel’s worth at the FDA.  Hopefully, non-violent protests will be sufficient, but I’ve got an army of chocodiles ready to fight if need be.

    Comment by Jason Schepers on 4/04/07 at 11:23 am #
  4. Thanks for the info. I did my bit at the FDA site and felt good about it. Viva Chocoholics!!

    Comment by Sharona on 4/04/07 at 6:56 pm #
  5. Did my part!  I posted a link on my blog at:

    Hope this helps!

    Comment by Robert de Leon on 4/13/07 at 2:44 am #
  6. Why does everyone get all bent out of shape at the proposed broadening of the definition? Like you say, it’s a “magical” change - in other words, a legal one, and nothing in reality actually changes, just names.

    A rose by any other name, right?

    Chocolate is still chocolate, and garbage chocolate imitator is still garbage - so what?

    Comment by T. Piatek on 4/13/07 at 8:59 pm #
  7. Cybele's avatar

    T. Piatek - you’ve made some interesting points here and in the other comments on the other posts on this subject.

    I guess my irritation is when I read the Petition on file with the FDA, it says that consumers haven’t formed any expectations. I think we have and I think we need to tell the FDA what those expecations are.

    Yes, I will still continue to read the labels, whether this goes through or not, because some companies label mockolate as chocolate anyway and the ingredients are the only way to tell.

    I also recognize that just throwing all the “true” ingredients together does not a “good” chocolate bar make. And I will admit that there are some very good mockolates out there. (The high end coating chocolates made by Guittard and Wilbur come to mind). But the nutritional profile of the substitute fats is not as good, simply put. Cocoa butter has passed the tests finally, it’s blood lipid level neutral. The other oils (palm kernel & hydrogenated whatevers) are not.

    I hope you’ll put your comments on file with the FDA. I think it’s good for them to hear that there are consumers that understand the differences and read the back of the label for their information, not just the front.

    Comment by Cybele on 4/14/07 at 6:01 am #
  8. It occurred to me today, as I was whipping up a white chocolate dessert: what, if anything, will this ludicrous FDA definition have to do with white chocolate, whose sole raison d’?tre is built on cocoa butter? Good Gawd, white chocolate is all about the cocoa butter. Will we be reduced to purchasing bars of sweetened Crisco?  The thought is appalling.  If I want that, I can pick up a six-pack of Entenmann?s cupcakes.

    Comment by Susan on 4/15/07 at 12:24 pm #
  9. I can’t believe that companies are going to put things in our chocolate that is not good for us.  Every women I know eats chocolate.  Is this why the FDA doesn’t care because we are women.  I would rather pay more for chocolate than to have mockolate.  I do not need my arteries clogged.  Why is it that companies don’t care about people, just how much money they can make.

    Gale Fondonella

    Comment by Gale Fondonella on 4/16/07 at 5:04 am #
  10. I want chocolate to stay the way it is.  The FDA is out of line!

    Comment by Bonnie Langhaar on 4/19/07 at 6:56 am #
  11. Thank you for helping us consumers fight for the priviledge of enjoying true chocolate. I posted my comments on the FDA site, per the link you provided. Thank you very much! Todd

    Comment by Todd Hays on 4/19/07 at 9:18 am #
  12. Leave the chocolate alone.

    Comment by D. Sawyer on 4/22/07 at 3:00 pm #
  13. Interesting how I found out about this petition right after I read an article on how our subsidized farm system is creating a surfeit of corn and soy products (like oils, trans fats and corn syrup) that have to go Somewhere, and that somewhere is into our diet.

    Seems to fit into this petition well. Cocoa butter is not subsidized, so it costs 3 times what corn or soy products cost (the stuff that will likely be replacing cocoa butter if they get their way). But that cost is covered by taxpayers, who’s money goes toward the billions in subsidies paid out to farmers to produce as Much (not as high quality) food as possible.

    I have to look at enough labels already, I don’t want to have to surf the candy section to find a Real chocolate bar whenever I get the urge. I hope it doesn’t pass.

    Comment by Stephanie R on 4/24/07 at 8:47 am #
  14. Slashdot mentions candyblog:

    Comment by danrj on 4/24/07 at 4:03 pm #
  15. With N.Y’s landmark legislation to ban trans fats praised as the new goal for other states to follow—this seems like a serious lapse in judgment by FDA.  Allowing cocoa oil (healthy) to be possibly replaced with a trans oil (killer), when Americans are taking on blimp proportions is frightening evidence of corporate $ interests penetratng and controlling a federal agency. 

    With all the disgraceful headlines that the FDA has experienced in the last 2-3 years—you would thnk this is the last calamity they would want to add to their list of debacles.

    Ban the proposal.  It is governmental stupidity at its height!

    Comment by J. Mary Brown on 4/27/07 at 7:44 am #
  16. I did my part, I posted message to Herschey, FDA (2 locations) and the Chocolate manufacturer.

    I sure hope that the FDA does not approve it.
    I really do not understand what is the thinking of the FDA.

    They can have another name for that product, certainly is not chocolate

    Comment by Clarissa on 4/29/07 at 6:50 am #
  17. Please do not allow this to go through by using artificial milk, artificial sweeteners, and trans-fats in chocolates.  There are many food products where trans-fats are not allowed so why even consider allowing it to be used in chocolates.
    Hopefully, the FDA will not approve what Hershey Chocolates wants to do.  There is no way these substitutions can give chocolate the same taste that it has now.

    Comment by Debbie on 4/29/07 at 8:23 am #
  18. Debbie, you are right. FDA stop Hershey. Beckie

    Comment by Beckie Overton on 5/04/07 at 4:11 pm #
  19. interestingly, the “proposed changes” do not even mention cocoa, cacao, or chocolate, but the potential impact is unmistakable.  here is the comment I just submitted:

    I oppose Docket 2007P-0085, the proposal to adopt horizontal changes in all food standards.  The various food manufacturing industries are seeking a blank check to undermine and rewrite the definitions of even common foods under the pretext of a fictitious limitation on their ability to innovate or improve efficiency.  If they want to make macaroni with 51% whole grains (as their repeated example), then call it something OTHER than whole grain macaroni, don’t water down the definition of whole grains or confuse consumers.  Further, their petition does not even mention chocolate, cocoa, or any related products, though the Chocolate Manufacturers Assoc. are co-signers, and I understand this proposal would allow substitution of non-cocoa vegetable oils in place of cocoa butter.  This would be a travesty.  Again, if they want to make such products, they already can, and just call it what is: “Contains chocolate solids.”  Don’t change the definition of a food, just to make it easier for them to market their new food products that are sorta-kinda-but-not-really what the consumer expects.  The vast breadth of this proposal also directly contradicts several of the explicitly stated goals such as: “The proposed regulations would not, however, undermine existing policies or requirements…this petition recognizes that flexibility involving certain ingredients…would probably trigger considerable controversy.” (pg.4).  Further, the document contains many false assertions such as: “Ingredients such as flavors, flavor enhancers, salt substitutes, sweeteners, and vegetable fats and oils [which] impart familiar and/or readily apparent properties…are used freely in non-standardized foods…there is no reason why similar flexibility should not be allowed for standardized products.”  There is a VERY GOOD reason why such flexibility should not be allowed: removing the standards for the “familiar and/or readily apparent properties” is tantamount to revoking the standard entirely.  Standards exist to protect consumers by ensuring that someone who buys a product (whether it is whole wheat, or chocolate, or organic) is getting what they think they are buying.  Standards exist to prevent the manufacturers from doing precisely what they are requesting permission to do: to manufacturer non-roses and call them roses.  Let the manufactures use accurate descriptive names for their new products, instead of obliterating the meaning from all existing food names.

    Comment by Fred Werner on 6/25/07 at 6:39 am #
  20. hook me up

    Comment by shanay on 12/10/07 at 7:55 am #
  21. I’m a chocolate lover. I love bittersweet chocolate covered nuts, dark chocolate, etc.

    I never buy candy with hydrogenated or interesterified fat. I prefer my chocolate to contain cocoa butter, butter, or coconut fat.

    I prefer to purchase anti-oxidant, magnesium rich cocoa/chocolate products for both flavor and health.

    Let’s not ruin chocolate by lowering standards.

    Comment by Sylvia Sage on 12/12/07 at 1:35 pm #
  22. Anyone have an update on this? Did it pass? Are we now eating tainted “chocolate”?

    On a side note, Hershey “Chocolate” Syrup is fat free. If it is fat free, then how can they use the word chocolate on the label, since by definition chocolate must contain fat?

    Comment by Joe on 2/09/08 at 2:20 am #
  23. Cybele's avatar

    Joe - we won! The FDA received 34,000 comments on the subject and they decided to remove that part of the “safe and suitable substitution” application.

    It’s actually called “Genuine Chocolate Flavor Hershey’s Syrup” so they get by with the “chocolate flavor” part.

    Comment by Cybele on 2/09/08 at 6:19 am #
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