The White Chocolate Con: Part 1

What if we told you a major restaurant chain was falsely advertising that a product contained White Chocolate when in fact the ingredients list shows it’s not White Chocolate?

Short version:

In order to call something “White Chocolate” or “White Chocolate Flavored” the product has to contain cocoa butter. It’s the law (FDA regulation).
Continue to part 2 here:

Really long version:

Whenever I see a cookie labeled “White Chocolate” I check the ingredients list, if there is no cocoa butter the product is mislabeled. This is because white chocolate has what is called a “standard of identity” which is a description of what is needed to be called that name. The FDA has these rules so the consumers don’t buy “milk” that is made from drywall dust or worse. Beef comes from cows, chicken breasts from chickens.. and when you buy various types of chocolate the product actually is chocolate or contains chocolate (like a chocolate cake).

The key ingredient in white chocolate is cocoa butter, it comes from the same bean as the cocoa solids that make milk and dark (semi-sweet) chocolate. Without the cocoa butter it’s not white chocolate, you can call it “fudge”,  “candy”, “coating”, or just about any non-regulated term.. just not “White Chocolate” or use “White Chocolate” in its name.

What about “flavored”? In order to use the term flavored with white chocolate you need to have the key ingredient, cocoa butter, otherwise someone could say “White Chocolate Flavored” and use sawdust.

With Milk and Dark (semi-sweet) chocolate the key ingredient is the cocoa solids, also known as “cocoa powder”, “chocolate solids”, “chocolate mass” or even just “chocolate”.  Since “White Chocolate” does not contain any of the cocoa solids it relies on the cocoa butter to be called chocolate.

So who made all of those rules?
The FDA did, to protect the consumers. Chocolate is defined in what is called CFR 163 (CFR stands for Code of Federal Regulations). The full text is here: The wording is technical, and the legal description is not what anybody would use in common speech. This version is simpler and less technical:

Now that we’ve established you don’t mess around with the term “White Chocolate”  (and white chocolate it is a real thing no matter what the uninformed say) just widespread is the mis-labeling?

A major chocolate company just settled a lawsuit about this not to long ago, their logo contained the word “Chocolate” even though the major labeling on the front of the package did not describe the product as chocolate, only as “Classic White”. , it would have been so easy for them to replace the “Chocolate” in the logo with “Confection”, it would have saved them $5.25 million.

Previously I purchased what was labeled as a “White Chocolate Chip” cookie at an nationwide upscale sandwich restaurant   (know for their bread..) and it just didn’t taste right. I went online, checked the ingredients and found it was mis-labeled. I let them know through their online customer contact form, they got back to me quickly, and the customer service rep forwarded it to the right internal person, who did a small bit of research and admitted the problem and pledged to fix it. That restaurant admitted and fixed the problem, I just re-checked and the product is now made with real white chocolate.

A cookie company we used to deal with also falsely claimed a “White Chocolate” cookie, while they didn’t have a online ingredients list and didn’t provide one when asked I just had a bad feeling about them.  I was visiting their shop one day and saw the physical ingredients, it was not labeled white chocolate. I let the owner know about the mis-labeling and he chose not to correct the error.  Likewise their other chocolate chip products were only chocolate flavored. Because of this, and other factors, we no longer do business with them at all.

Intentionally mis-labeled “White Chocolate” is rampant in the chocolate strawberry industry, the biggest company is not even using real milk or dark chocolate, but this story just laying the foundation for the next one… what world wide restaurant is mis-labeling something as white chocolate?… that comes in the next update. (but if you really must have true chocolate strawberries you can get them at


Part 2 is now available at

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