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In defense of chocolate

(article, Emily Stone)

In April, a grassroots group of chocolate lovers (including me) stood up to Big Food and demanded that American chocolate not be adulterated by the use of cheap and unpalatable vegetable fats in place of cocoa butter. And we won. 

That is, we won the right to continue making comments to the FDA for an additional two months, until June 25.

The whole process is paralyzingly bureaucratic. And the resulting grassroots campaign for pure chocolate is composed of an overwhelming mishmash of information, some accurate and some inaccurate, some reserved and some reactionary. But all this banging on the chocolate pot might help us hammer out a definition of chocolate that everyone can agree on. Right now, the government, the chocolate makers, and the consumers all have different ideas. It’s time to start making sense of the labels.

[%image feature-image float=right width=400 credit="Photo: iStockphoto/elkor" caption="A cacao pod sitting atop a bag of cocoa beans."]

Executives at Bay Area chocolate maker Guittard (a 139-year-old family-owned business) have turned this chocolate controversy into a cause célèbre. Guittard’s “Don’t Mess with Our Chocolate” website (which links to press coverage everywhere from National Public Radio to a forum on socially responsible investing) helps individual consumers get involved by instructing them on how to register official “Consumer Comments” at the FDA website.  

Confusingly, the document that these comments are intended to respond to is a standard form filled out by the Grocery Manufacturers Association (GMA) under the name “Citizen’s Petition.” So the dossier of comments logged by Guittard’s supporters essentially comprises a petition against a petition.

It may seem trite for me, as the founder of a blog called Chocolate in Context, to argue that we put this matter in context, but that’s what I’m going to do. The GMA petition (which is undersigned by 11 other food-industry organizations ranging from the Chocolate Manufacturers Association to the National Cattlemen’s Beef Association) is a rambling and repetitive, though largely reasonable, 35-page document pertaining to general food standards and describing specific processed foods like canned tomatoes and breaded shrimp. It mentions chocolate only in an appendix. 

The reference to chocolate is vague and broadly drawn, though it is cause for alarm. The current U.S. standards for chocolate production are stricter than those in the European Union, where products labeled “chocolate” can contain up to five percent non-cacao vegetable fat. But the GMA petition’s wording could be interpreted as promoting a much more lax standard in the U.S.

However, it’s important to understand that the proposed changes are more about labeling than manufacturing. American candy makers can already produce foods with cocoa-butter substitutes (such as Butterfingers and Whoppers). But they can’t call them chocolate.

So what are we really talking about? Mostly, we’re talking about cocoa butter, an ingredient known for the cholesterol-lowering properties of its natural stearic acid and, more importantly, for its unusual tendency to melt at body temperature. So where does cocoa butter come from and how does it get into our chocolate? The FDA is unnecessarily confusing about the substance, referring to it as “cacao fat” and sending those who wish to learn more to the archives in a Washington, D.C., office instead of simply publishing the definition on its website.

Even blogger Cybele May, whose “Keep it Real” campaign on Candy Blog inspired more than 100 mentions of the proposed FDA changes on the Internet, gives a misleading description of the ingredient in an editorial that was syndicated in New York Newsday and the Los Angeles Times:

bq. Cacao pods are fermented and then roasted and ground into a fine paste that can be separated into two components: cacao solids (commonly called cocoa powder) and cocoa butter. Each chocolatier uses different proportions but generally blends sugar, cocoa solids and cocoa butter plus the optional ingredients — emulsifiers, flavors (typically vanilla) and milk solids (to make milk chocolate) — and molds that into a chocolate bar.

Actually, it’s not the pods but the beans found within them that are fermented and roasted. And while May’s description of how cocoa butter is separated from the solids that become cocoa powder is accurate, she misrepresents the role of that process in the transformation from bean to bar, since the base of processed chocolate is not cocoa powder but the paste she mentions (arguably more gritty than fine), which is commonly called “chocolate liquor.” Chocolate liquor naturally contains approximately 50 percent cocoa butter.

Making the process even more confusing, most modern chocolate bars contain extra cocoa butter to increase their smoothness.


At every step, chocolate production is hard to explain. Cocoa butter is a particularly vexing ingredient, like a snake eating its own tail; it must be extracted from one batch of chocolate liquor only to be added to another. May’s fumble isn’t unusual. Almost everyone I’ve ever heard discuss chocolate production gets tripped up somewhere along the way, and I’ve certainly made statements on my website that I thought were accurate but turned out to be not quite right. 

So why are we beating up a bureaucratic governmental body like the FDA about its definition of chocolate, when we the consumers, we the “experts,” haven’t gotten our chocolate stories straight?

While waiting for the FDA (busy cleaning up the mess of recent spinach and peanut-butter scandals) to rule on the GMA “Citizen’s Petition,” individual consumers could turn to [%bookLink code=0500282293 "The True History of Chocolate"], by scholars Sophie and Michael Coe, to understand the chocolate-making process, from fermenting to drying to roasting to winnowing to grinding to conching to molding. Or they could choose from more than a dozen extensively researched contemporary cookbooks on the subject, ranging from Michael Recchiuti and Fran Gage’s [%bookLink code=1584794577 "Chocolate Obsession"] to Maricel Presilla’s [%bookLink code=1580081436 "The New Taste of Chocolate"].

And American chocolate companies could use the interim period between the petition and the FDA’s ruling to come up with some labeling standards of their own. Guittard indicates the use of “cacao beans” on its labels, while the chocolate maker’s San Francisco neighbor Ghirardelli prefers the term “unsweetened chocolate,” and Jacques Torres (a boutique chocolate producer in New York) opts for “cocoa liquor” — but they’re all talking about the same ingredient. 

Furthermore, Berkeley-based Scharffen Berger refers to the controversial fat of the cacao bean as “cocoa butter,” while its stepsister company Dagoba (both Scharffen Berger and Dagoba are recently acquired subsidiaries of the Hershey Company) chooses the description “cacao butter.”  

With or without government intervention, it would be a boon for serious chocolate consumers if manufacturers standardized the terms they used for chocolate ingredients.

Gary Guittard, CEO of the company that bears his name, made a public statement that “the proposed FDA changes would allow the current ‘Gold Standard’ for chocolate to be changed in a way that will ultimately result in short-changing the consumer and changing what we know and love as traditional chocolate.”  

I agree, and I filed a comment with the FDA. I hope other chocolate lovers will do the same — and take the opportunity to question what all the fuss is about.

p(bio). New York-based Emily Stone keeps a blog called Chocolate in Context.

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