I’ve always said that nothing short of religion or politics evokes more passion than does a discussion of food. That passion undoubtedly applies to all of us who revere the traditional chocolate that we know and adore. In 2007 proposed changes to chocolate manufacturing standards ignited a firestorm of opposition and opinion of a magnitude that has not been seen since the Boston Tea Party or the Whisky Rebellion.
In October, 2006 a Citizens Petition to Modernize Food Standards was submitted to FDA by the Grocery Manufacturers Association along with 11 other food industry associations including the Chocolate Manufacturers Association. Through this petition they have asked the FDA for approval to change current requirements for a number of food categories including chocolate. This petition has been recorded with the FDA as Docket #2007P-0085.
Whereas this petition has some merit in that it reflects the need for flexibility in food manufacturing due to changing technologies and consumer demands, it does include changes in the standard of identity for chocolate. The potential impact is significant in that the petition would allow the addition of vegetable fat based cocoa butter substitutes and non-nutritive, non-carbohydrate sweeteners in products and still allow the product to be called chocolate. Chocolate manufactures will not be required to make these formula changes and can still make chocolate the same way they have for years.
How the product will be labeled is adding to the confusion. Although manufacturers will have to label all ingredients in the ingredient statement on the back of the package, consumers will find it difficult and confusing to differentiate between real chocolate and its imitation. This will amount to economic fraud to the consumer as the product will become cheaper with inferior ingredients.
Although some of the big chocolate manufacturers are in favor of the proposed changes in regulations because they want to keep prices down on key ingredients by using less expensive vegetable fats numerous chocolate manufacturers are not. Guittard Chocolate Company has been at the forefront opposing this petition from the start. Chocolate makers who want to reduce costs can already do so and indeed many have. They simply have to label their product as chocolate flavored or some other applicable fake adjective.
At a time when we as food professionals and consumers are becoming more conscientious in regards to fair trade, the global chocolate industry is at work to improve working and economic conditions of cocoa farmers worldwide. Changing cocoa butter for vegetable fats could have a dramatic if not disastrous economic impact on their livelihoods. Demand for cocoa butter would likely decrease thus causing prices to tumble as some manufacturers switch to cheaper substitutes.
The big question now is what the FDA will do. They can deny it, grant it, postpone it indefinitely or initiate a proposed rulemaking and comment period. If for some reason the petition moves forward it would be years before modified regulations are established. Keep in mind it took 10 years to establish a standard of identity for white chocolate. It would be unlikely for the FDA to grant a petition such as this without a proposed rulemaking and comment period.
I love chocolate just the way it is; made with 100% cocoa butter, real milk and yes real sugar. Cocoa butter is a unique fat that gives a texture and mouth feel to chocolate that no substitute fat can imitate. None of what is being proposed benefits the consumer. No consumer research was submitted to support such changes. We as consumers need to demand what is acceptable and not acceptable. I for one say “DON’T MESS WITH MY CHOCOLATE!”
In October, 2006 a Citizens Petition to Modernize Food Standards was submitted to FDA by the Grocery Manufacturers Association along with 11 other food industry associations including the Chocolate Manufacturers Association. Through this petition they have asked the FDA for approval to change current requirements for a number of food categories including chocolate. This petition has been recorded with the FDA as Docket #2007P-0085.
Whereas this petition has some merit in that it reflects the need for flexibility in food manufacturing due to changing technologies and consumer demands, it does include changes in the standard of identity for chocolate. The potential impact is significant in that the petition would allow the addition of vegetable fat based cocoa butter substitutes and non-nutritive, non-carbohydrate sweeteners in products and still allow the product to be called chocolate. Chocolate manufactures will not be required to make these formula changes and can still make chocolate the same way they have for years.
How the product will be labeled is adding to the confusion. Although manufacturers will have to label all ingredients in the ingredient statement on the back of the package, consumers will find it difficult and confusing to differentiate between real chocolate and its imitation. This will amount to economic fraud to the consumer as the product will become cheaper with inferior ingredients.
Although some of the big chocolate manufacturers are in favor of the proposed changes in regulations because they want to keep prices down on key ingredients by using less expensive vegetable fats numerous chocolate manufacturers are not. Guittard Chocolate Company has been at the forefront opposing this petition from the start. Chocolate makers who want to reduce costs can already do so and indeed many have. They simply have to label their product as chocolate flavored or some other applicable fake adjective.
At a time when we as food professionals and consumers are becoming more conscientious in regards to fair trade, the global chocolate industry is at work to improve working and economic conditions of cocoa farmers worldwide. Changing cocoa butter for vegetable fats could have a dramatic if not disastrous economic impact on their livelihoods. Demand for cocoa butter would likely decrease thus causing prices to tumble as some manufacturers switch to cheaper substitutes.
The big question now is what the FDA will do. They can deny it, grant it, postpone it indefinitely or initiate a proposed rulemaking and comment period. If for some reason the petition moves forward it would be years before modified regulations are established. Keep in mind it took 10 years to establish a standard of identity for white chocolate. It would be unlikely for the FDA to grant a petition such as this without a proposed rulemaking and comment period.
I love chocolate just the way it is; made with 100% cocoa butter, real milk and yes real sugar. Cocoa butter is a unique fat that gives a texture and mouth feel to chocolate that no substitute fat can imitate. None of what is being proposed benefits the consumer. No consumer research was submitted to support such changes. We as consumers need to demand what is acceptable and not acceptable. I for one say “DON’T MESS WITH MY CHOCOLATE!”
