Petition Before FDA to Allow Replacement of Cocoa Butter in Chocolate

July 16, 2007
There's an outrageous petition before FDA to allow the replacement of cocoa butter in chocolate.

Normally I'm a big supporter of evolving food technology, but this time they're going too far.

It seems there is an official FDA review under way that would change the standards of identity for chocolate to allow the replacement of cocoa butter with other vegetable fats. If this petition is accepted, it could open the door to square bagels, green ketchup and who-knows-what other atrocities.

Now, I turned the other cheek when they came out with nonalcoholic beer, when ice milk was allowed to be called low-fat ice cream, when someone took the dairy out of cheese. But sometimes a man has to take a stand.

I celebrated the birth of my children with a Hershey's Special Dark bar. The chocolate shavings made my wedding cake all the more special. Every Thanksgiving, dessert is a Baker's Square French Silk pie. I could go on. But you understand my concern.

To top it off, in the past year or so, we learned chocolate is actually a health food!

Apparently the root of this whole ruckus goes back to the Clinton administration (don't get me started!) and its suggested re-evaluation of all food standards of identity. Last October, the Grocery Manufacturers Assn. submitted a citizen petition -- co-signed by 11 other organizations -- suggesting "six categories of variations that should be allowed to provide needed flexibility."

Now, I am all for the use of "enzyme technologies that enhance the properties of egg yolk used in mayonnaise." And anybody familiar with me knows I'm all about the ability to make stewed tomatoes chunky. But it's bullet point No. 2 that has me worried:

  • "...use of safe and suitable ingredients such as salt substitutes, sweeteners and vegetables fats and oils, where appropriate."

As one of the signatories, the Chocolate Manufacturers Assn., or at least some of its members, took that to mean that certain vegetable fats could be substituted for cocoa butter. Not as a rule, of course, but as an option for some.

The current standards of identity for chocolate products are contained in the Code of Federal Regulations, Title 21 Part 163. There are standards for 15 chocolate and cocoa products, specifying the minimum amounts of such required ingredients as chocolate liquor (the liquid or paste made from ground, roasted cocoa beans), milk solids and milk fat. I like the term "chocolate liquor."

Standards are good. They keep our refrigerators at 35-38°, our lawyers certified and our kids in Illinois achieving the same minimal reading abilities as those in Pennsylvania.

Would you want to risk 80-octane gasoline, even if it were labeled?

So why mess with a good -- no, great -- thing. That's precisely what the organization Don't Mess With our Chocolate (, of course) is saying. The group's unassailable purpose: "to provide information regarding how to get involved in saving the real chocolate that we all love and enjoy."

"Through the years, consumers have had a passionate love affair with chocolate," the web site says. "Chocolate is an indulgence that everyone can afford, and it provides comfort, pleasure and happiness. It truly is one of the world's most unique and special foods." Can't argue with that.

Sure, preserve the march of food technology. Allow the "addition of ingredients intended solely for technical, nondistinctive effects, such as emulsifiers, stabilizers or antimycotic agents." But leave my chocolate alone.

Because if we don't stop them now, next they'll be messin' with my beer.

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