It should surprise no one that there is a FDA regulation that stipulates what “chocolate” should be. The reason this regulation exists is to prevent the more nefarious candy producers from trying to foist less than desirable chocolate products upon the shelves, placing them in competition with those companies who put forth the time and effort to put out reasonable products.
These regulations contain an essential guide in explaining what should be in chocolate. Aside from the base cacao product itself (be it sweet chocolate or milk chocolate o), they have a specific list of what else is allowed to be added to the chocolate without putting the “chocolate” nomenclature at risk.
Item number one of optional ingredients is cocoa fat (aka cocoa butter). Currently you can’t substitute the cocoa fat in chocolate with a cheaper fat and still call it “chocolate”. You can call it chocolate flavored, but it can’t be packaged and sold in the same way as…say…a Hershey Bar.
However, the Chocolate Manufacturers Association wants this rule to change. The CMA, whose membership reads like a Who’s Who list of the Greedy Corporate Bastards Association (including such luminaries as Cargill, Archer Daniels Midland, Nestle, and yes, even Hershey’s) want to be able to replace the more expensive cocoa butter with something cheaper.
I know some of you are thinking “yeah, yeah, why is this a big deal?” It’s a fair question.
In my opinion, the cocoa butter is as critical of a component for chocolate as the chocolate itself. It is hard and brittle at room temperature but melts very sharply below body temperature, giving chocolate its desirable properties of ‘snap’ and ‘melt-in-the-mouth’.
Cocoa Butter Substitutes fats usually based on soybean oil, cottenseed, palm kernel oil or coconut oil. They have snap and melting properties similar to cocoa butter but a different chemical composition. They are not compatible with cocoa butter and the presence of more than 20% cocoa butter in a mixture with them leads to softening and/or bloom formation. They also have a shorter shelf life.
Or, as Cybele wrote in her post, “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.”
It will allow them to make a cost effective chocolate bar, albeit at the expense of quality.
If this lowering of standards irks you, even a bit, fret not, as you have recourse. The FDA is allowing public comment on these standards and the suggested change.
This page gives you a brief tutorial on how to get the FDA to listen to you.
From my point of view, I have mixed feelings about this.
First, I hate to see the lowering of any quality standards, which is exactly what this is. In a world of slow food and home cooking, we should be celebrating good foods, and preventing inferior products from being treated as equals.
However, if I were a chocolate artisan, part of me would love to see this rule change. The
taste texture of chocolate without cocoa butter is very noticeable, and never for the better. If Hersheys and Nestle want to lower their standards, I’d make sure that I was there, still producing higher quality bars, with my own takes on Snickers, Reese’s Peanut Butter cups, and Twix bars all at the ready.
Part of me think that my latter take is a bit “pie in the sky”.
Regardless, shame on the Chocolate Manufacturers Association. Way to thumb your nose at tradition, guys.