Expert Opinion: No Chocolate Crisis

Recently, the U.S. Chocolate Industry, through its Chocolate Manufacturers Assn., along with 11 other food industry associations, joined a Grocery Manufacturers Assn./Food Products Assn. (GMA/FPA) citizen’s petition asking the FDA for approval to change current standards of identity (SOIs) for a number of food categories.

By Robert Earl, M.P.H., RD., senior director for Nutrition Policy, Grocery Manufacturers Assn./Food Products Assn.

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The GMA/FPA petition doesn't ask to change the chocolate standard. (For another angle on this topic, see "A chocolate (flavored) outrage," Food Processing, July, 2007.)

Opponents claim such changes could lead to problems such as labeling issues, use of trans fats in chocolate and misleading consumers. They believe consumers will find it difficult to differentiate the current "gold standard" of chocolate vs. any concoction not containing pure cocoa butter. They also claim any such change opens the door to economic fraud.

However, labels wouldn't change -- all products would carry full ingredient labeling. Opponents also claim manufacturers who don't support the change will be forced to convert to new formulations to remain competitive. They predict an overall downgrade in chocolate quality. This is unlikely. Manufacturers don't make products consumers reject. In the EU, standards already allow up to 5 percent non-cocoa butter in chocolate, so even the fanciest European chocolates might not have pure cocoa butter.

If the petition passes, "sugar-free" chocolate would be possible. Currently, manufacturers can't legally claim a chocolate as sugar-free. Also, stability problems in chocolate, such as "bloom," can be remedied by including other vegetable oils.

It must be pointed out the GMA/FPA petition is just a preliminary step in a long, multi-year process. Efforts to change the SOIs of chocolate products would require a proposed rule-seeking notice and comment as to specific changes.


- Robert Earl, M.P.H., RD., senior director for Nutrition Policy, Grocery Manufacturers Assn./Food Products Assn.

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