quote:

The FDA Standards of Identity for chocolate are here [url]http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=163[/url].

Sebastian is partially correct. Minimum and maximum cocoa butter content for chocolate liquor are specified in section 163.111: "Chocolate liquor contains not less than 50 percent nor more than 60 percent by weight of cacao fat."

The EU standards embodied in the Codex Alimentarius are more precise. The Codex is here [url]http://www.codexalimentarius.net/web/index_en.jsp[/url].

:: Clay
Discover "The Chocolate Life @
http://www.thechocolatelife.com/

I have in front of me a bar of Lindt Excellence 70%. The "Nutrition Facts" label shows that each 40 gram serving has 17 grams of fat. So we divide 17 by 40, and see that the bar is 43% fat. We subtract the 43% from the 70% total, and see that the bar contains 27% deffated cocoa solids.

Correct?

quote:

what I'm saying is, if the liquor did NOT happen to be 54% fat, because of different properties of the source beans, the real amount of liquor the chocolate would have to have would be different from 35%. So if the source beans had, say, 60% fat, the chocolate would in fact need to have about 39% liquor in order to conform to the "35%" rule, that is to say, they are stating 35% with reference to a standard (arbitrary) liquor that in theory had 54% fat.

quote:

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On a label it would be listed as simply 'chocolate liquor'. Now, manufacturers are allowed to add additional cocoa butter to that liquor, elevating the total fat % of the liquor to as high as 60% if they so choose to, and not have it impact a label. For example, if your starting liquor is 54% fat, you can add sufficient cocoa butter to that liquor so that it's total fat content is now 60%. On the ingredient label, it would still be simply listed as 'chocolate liquor' - you would not need to list the additional cocoa butter that was added to bring the liquor component to a total fat content of 60%

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Yes, that could be OK, but that would have the net effect of requiring your "liquor" percentage, in the sense of what you claimed on the *label* to go up to the 39%. So you wouldn't be "getting away" with anything - because the original starting liquor would still have to compose 35%, thanks to the fact that the added cocoa butter wouldn't contribute to the total used for the purposes of calculating liquor percentages in order to establish that the product could be called chocolate in the eyes of the USDA. The additional cocoa butter is factored out by the way the USDA does the calculation.

It's also been asked - why not require everyone to list defatted cocoa solids percentage, cocoa butter percentage, and sugar percentage as separate figures? Yes, that's actually essentially what's done in the professional trade, and I think the educated consumer wouldn't have a problem with that, but from a regulatory perspective it would put an odious burden on small manufacturers who'd have to send samples of their bars to expensive testing labs in order to get them all individually tested - and this could vary from year to year as bean lots changed, whereas you can compute your cocoa solids percentage directly from your ingredient list without actually having to test it. It would also add significant regulatory overhead (= cost, personnel) which might be more than the tax system of the concerned countries could do. I think it would be nice if chocolate manufacturers provided this information on a voluntary basis, but *compelling* them to do so I think would create new problems in an attempt to solve old ones.

Alex Rast
Alex_Rast_Alternate@hushmail.com

The problem with cocoa percentages is that there's no standard, legally binding definition of them. It could mean anything, and at the same time doesn't really mean anything because there's no standardized definition. The american legislation is written such that a semisweet chocolate, for example, needs to contain at least 35% liquor. Now that liquor as it comes from a standard ivorian bean, for example, may turn out to be exactly 54% fat. On a label it would be listed as simply 'chocolate liquor'. Now, manufacturers are allowed to add additional cocoa butter to that liquor, elevating the total fat % of the liquor to as high as 60% if they so choose to, and not have it impact a label. For example, if your starting liquor is 54% fat, you can add sufficient cocoa butter to that liquor so that it's total fat content is now 60%. On the ingredient label, it would still be simply listed as 'chocolate liquor' - you would not need to list the additional cocoa butter that was added to bring the liquor component to a total fat content of 60%.... confusing? Sure is 8-)

But it's late, and i'm tired, and i may be attempting to address points that aren't even being raised - if that's the case, so sorry and i'll bow out now ;-)

quote:

No, what I meant is not that the government is *stipulating* that the cocoa butter in the bean must be 54% (that would be impossible if mfrs were to have reasonable bean selection, as you note), what I mean is, that for the purposes of calculating cocoa content, they are specifying it relative to a "reference" source bean having 54%. The manufacturer could, for instance, have a bean with greater cocoa butter percentage, but if they were to do that, then it would have to have a slightly greater total amount of chocolate liquor in order to fit within the regulations. Likewise one with less cocoa butter could get by with slightly less liquor.

Alex Rast
Alex_Rast_Alternate@hushmail.com

quote:

Actually, it can be anywhere between 50-60% totoal cocoa butter in the liquor, according to the current standard. Some beans inherently have more or less fat than others - it's a variable agricultural product. This allows a manufacturer to allow for that variability.

quote:

What this means is that they are "normalising" the amount of cocoa butter in the chocolate liquor to 54%, presumably to try to circumvent any issues arising from different fat percentages in different raw beans. This is another way of saying that if you happened to find a bar with a disproportionately high fat content, you'd have to have a greater total percentage in order to meet the requirement. Note here that added cocoa butter isn't even being considered, so the bar has to have 15% chocolate liquor equivalent before you add any more, thus eliminating the possibility of "cheating" by adding even more cocoa butter. Notice also that this means 54% isn't what they adjust to for a "standard" bar in the finished chocolate, just in the liquor. For instance, that would mean that a 70% chocolate, using this system, that contained 54% cocoa butter beans, and a 40% cocoa butter total, would have about 29.6 % defatted cocoa solids. However, there is a flaw in the ratings as I see it, because this doesn't account for the reverse: adding cocoa powder, as some chocolates do, in order to boost the amount of defatted cocoa solids. Nonetheless, it would seem the US is at least trying to prevent abuse of the system.

quote:

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and European: "in the case of chocolate, not less than 43 % total dry
(1) OJ L 184, 17.7.1999, p. 23. cocoa solids, including not less than 26 % cocoa butter,

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This is clearer but has more possibilities of cheating. Here the bar would have to be classified as a 43% bar, using the standard system lumping both constituents of chocolate together. Furthermore, such a bar at the minimal level, containing the requisite 26% cocoa butter, would therefore be 17% defatted cocoa solids - they'd need to add a pretty big amount of cocoa butter, assuming typical beans which for convenience we will say contain 50% cocoa butter - 9%. The cocoa butter minimum makes no stipulation on how much of some other kind of fat you could choose to have in there, so in fact the bar could be 40% fat and have 14% vegetable fat. Then it would have 43% sugar.

quote:

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3.8.2000 EN Official Journal of the European Communities L 197/21
— in the case of milk chocolate, not less than 30 % total
dry cocoa solids and not less than 18 % dry milk solids
obtained by partly or wholly dehydrating whole milk,
semi- or full-skimmed milk, cream, or from partly or
wholly dehydrated cream, butter or milk fat, including
not less than 4,5 % milk fat,

So again they set the total cocoa solids percentage and the milk solids percentage, along with the milk fat percentage. They don't, interestingly, stipulate a cocoa butter percentage so I don't see anything technically in this specification as quoted that prevents the manufacturer from replacing all the cocoa butter with palm kernel oil. Hmm...

— in the case of couverture chocolate, not less than 16 %
of dry non-fat cocoa solids.

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And this is entirely unambiguous, cheat-free when it comes at least to the flavour constituents. Your minimum is 16% defatted cocoa solids, flat. If, however, there's nothing about cocoa butter, then the couverture could again technically be 100% vegelate, but I suspect you've trimmed a bit off this last regulation.

Alex Rast
Alex_Rast_Alternate@hushmail.com

and European: "in the case of chocolate, not less than 43 % total dry
(1) OJ L 184, 17.7.1999, p. 23. cocoa solids, including not less than 26 % cocoa butter,
3.8.2000 EN Official Journal of the European Communities L 197/21
— in the case of milk chocolate, not less than 30 % total
dry cocoa solids and not less than 18 % dry milk solids
obtained by partly or wholly dehydrating whole milk,
semi- or full-skimmed milk, cream, or from partly or
wholly dehydrated cream, butter or milk fat, including
not less than 4,5 % milk fat,
— in the case of couverture chocolate, not less than 16 %
of dry non-fat cocoa solids.

Guess I have to go and study it!!!