Chocolate Lovers Unite, Then Write The FDA

The food supply is in the news these days : a proposed food czar, contaminated chicken feed and modified chocolate labeling requirements. You probably haven't seen much about the third item on this list. But if you want to make sure that the "chocolate" you buy contains cocoa butter -- not vegetable oil (hydrogenated? yes) -- and that it contains milk -- not "milk substitutes" -- then be sure to write the Food and Drug Administration (FDA) by 25 June. You can even summit your comments online.

Food safety is divvied up between USDA and FDA, but FDA owns these labeling requirements, which reflect a "standard of identity."

Truth in labeling is a key component of consumer trust, which in turn is a key component in commerce, at all levels. Rather than fiddling around with chocolate labels, seems to me that FDA should be a lot more concerned about the quality (and truth in labeling) of pharmaceuticals or ingredients entering the food supply from outside our borders, like the stuff that tainted the pet food supply (and now chicken feed, thus indirectly affecting the "human grade" supply chain.).

But no-o-o-o-o-o-o.

What's At Stake?
Chocolate is Big Business: $15.7 billion in the US in 2005. Premium chocolate is only about 10 percent of this total, but it's the growing bit (28 percent from 2003-2005). At least one premium chocolate maker (Guittard) is at odds with the Chocolate Manufacturers of America (CMA) and the Grocery Manufacturers Association (GMA), the two organizations that petitioned FDA to make the change in a (cough) "Citizens Petition."

According to "Don't Mess With Our Chocolate," the proposed change in ingredients would not be reflected on the label: in other words, the products could still be called "chocolate." No surprise here: the change would save manufacturers as much as two-thirds of their "fat" cost.

Yes, Virginia, this is the stuff that your government thinks important: mucking up a standard of identity, that's been in effect since the 1940s, for a beloved consumer product. The standard of identity for chocolate has been modified a couple of times in 60+ years, but only to reflect changes in manufacturing technology and to define "white chocolate." Not to confuse consumers. Or save international corporations a few bucks.

From the "Don't Mess With Our Chocolate" press release:

Changing the current "Gold Standard" for chocolate by allowing the substitution of hydrogenated or chemically-modified vegetable fats for cocoa butter will also have a dramatic impact on cocoa growers in Central and South America, the Caribbean Basin, Africa, and nations in Southeast Asia at a time when the global chocolate industry is working to improve working and economic conditions of these developing countries' farmers. In fact, the plan to substitute these types of vegetable fats for cocoa butter would cause a disastrous economic impact on their livelihoods as the demand for cocoa butter would likely decrease and prices would plummet as some manufacturers switch to the cheaper substitutes.

Standards -- in food labels or drug formulations, in 110/220 electrical outlets or wireless internet protocol -- speed adoption. Standards also (to use a Republican cliche) "level the playing field" for firms. Firms then compete in the marketplace on equal footing.

The Case of Milk: An Example
What are some examples in food? Let's look at milk. On average, fresh cow's milk is 87.2% water, 3.7% milk fat, 3.5% protein, 4.9% lactose, and 0.7% ash. But there is variance between breeds as well as individual cows. And although dairy farmers have been historically paid based on the percentage of milk fat (it's what makes butter), consumers prefer low-fat products.

Enter standardization.

Whole milk must have a minimum of 3.25% milk fat; non-fat or skim milk has a maximum of 0.5% milk fat. Low-fat milks -- 1% or 2% -- are either 99% fat-free or 98% fat-free (another way of looking at the standard). Thus both consumers and producers benefit from the labeling requirement -- it reduces market transaction friction.

So there you have it. If you've read this far and you're still "bothered," go tell the FDA. You have until 25 June.