A rare food industry post

[beetiger]

(lediva requested that I address this issue. Here you are, love.)

There's been a furor going around the Internet lately about a petition sponsored by the Grocery Manufacturers of America, proposing a change in the standard of identity of chocolate to allow products made with other fats than cocoa butter to still meet the definition of "chocolate". And one of the high-end chocolatiers, Guittard, has launched an attempt to get consumers up in arms about it, writing to the FDA, etc. "Don't mess with our chocolate."

The point of standards of identity for ingredients and products is simple -- to give people the products they expect, not diluted or adulterated. The fat content and fat source in products is often one of the key points in it. The FDA also has a second big concern these days -- that consumers not be confused by the plethora of formulated products out there.

The last major change to regulations that I remember concerning labeling of this sort was back in 1998, when the FDA revoked the standard of identity for many milk products, allowing labeling of reduced fat milk products to be more understandable and appealing to consumers. Low fat ice cream instead of ice milk, light cheese instead of cheese food product, fat-free sour cream instead of imitation sour cream, fat-free milk instead of skimmed milk. It was meant to be a move to help American health, by legitimizing these products, and making them sound good. This was in my opinion a very good thing.

The FDA recently (in government terms, I believe the rule went into effect in 2004) established a standard of identity for white chocolate, which has being made with cocoa butter as a core component of it. Having this as a precedent showing that consumers think cocoa butter = chocolate is certainly a point of evidence against the proposal realistically being one step away from Hershey being allowed to make chocolate with 100% corn oil or something. And although the Chocolate Manufacturers of America are supporting the petition, they at least officially are phrasing it as an opportunity over all to look at our definition of what your average American junk food eater wants to understand about his junk food.

Understand that higher end producers are still going to be able to put explicit ingredient lines and information on their products, letting you know exactly what's in them, down to the name of the region of the country that they got the beans from and the exact percentage of cocoa solids. The market for chocolate stuff from the big suppliers of things that are primarily chocolate continues to look primarily toward the high end, as makers as low-end as Hershey come out with products like Cacao Reserve.

The big problem is that chocolate isn't just a product, it's an ingredient. And if the standard of identity for it changes, things like store-brand products with long complicated ingredient lines including six kinds of pretzels, caramel, ice cream, and chocolate chips in low-fat ice cream are going to be able to cheap out on the chips without telling you quite as explicitly in their three paragraph ingredient line. But if you're eating that kind of rework anyway, do you really care that much? Do you really expect it to be made well?

On the other hand, I don't think we've got a situation like we did with milk product labeling. People aren't ruining their health by avoiding products with "chocolate flavored coating" on them. This is pretty much an industry driven request, and I hope the FDA looks at it that way, because frankly, much as it might sometimes be really inconvenient from the point of view of a product formulator, the FDA is really there to try to protect the American public's health.

Give me some fine artisan chocolate truffles, hand made with some nice Callebaut dark chocolate and some fancy spices and essential oils or liqueurs or something, and I'll be happy.

Here are some folks who are thinking about it harder than I am. I'll be following what they find out.

Here, and here are the current standards of identity for chocolate products, if you are curious.

Comments

Hmmm.

[orb2069.livejournal.com]

In the wake of what seems like nonstop food/drug recalls, am I just having un-wishful thinking that the performance of the FDA and food inspection in general has slipped pretty badly? Is this a {Republicans killing big goverment, handjobs for industry} thing?

Or were things always this bad and I never noticed?

Re: Hmmm.

[beetiger.livejournal.com]

Well, recalls mostly mean they *are* doing their job. It's all that stuff that isn't being recalled that you probably want to worry about. :P As far as the overall state of the FDA, I have to admit that I'm not completely up on it on the inspection side. I tend to mostly follow regulatory. That was my big concern when I was working, since I'm a formulator, once the stuff's on the shelf it's out of my hands.