Regulation of Vegetable Fats other than Cocoa Butter

March 15, 2000: chocolate that includes vegetable fats other than cocoa butter in addition to it, are allowed to be manufactured and sold throughout the European Union. 

The main provisions of the new chocolate regulations:

– For the most part, the previously applicable legislation is maintained with regards to the definition and classification of the different types of chocolate: chocolate, milk chocolate, etc …

– The same applies to the addition of edible materials (honey, dried fruits, cereals, etc.) which remains authorized within a certain limit (40% of the weight of the finished product). The addition of animal fat, flour, and starch, as well as the use of aroma imitating the flavor of chocolate or milk, are still prohibited.

– Mandatory labeling of the cocoa content is maintained and the general labeling provisions are imposed on chocolate, as for all foodstuffs, namely: list of ingredients and the best by date. 

– The new directive does not deal directly with the case of additives, as it is governed by the general framework of a directive listing the authorized substances (soy lecithin thus remains accepted in chocolate as an emulsifier).

– To stick to the above indications, the future regulation seems to be similar to that applicable so far. But a single sentence, in Article 2 of the text approved on March 15, is enough to offer the opportunity of changing the product’s substance: “vegetable fats other than cocoa butter … can be added in chocolate products … ” 

While chocolate is being manufactured (most often by conching), it will therefore be possible to incorporate mixture a quantity of fat different from cocoa butter into the cocoa and sugar 

– vegetable fats belonging to the category of cocoa butter equivalents are as follows: illipé, palm oil, salt, shea butter, kogum gurgi and mango kernels. cocoa butter … can be added into chocolate products … “

– In the maximum limit of 5% in relation to the weight of the finished products, chocolate part only.

Product labeling with M.G.V. should be completed with the following note, both clearly visible and legible: “contains vegetable fats in addition to cocoa butter”. This statement must appear in the area as the list of ingredients, although it must be quite distinct from this list, and must appear in bold, or as big. 

Finally, the directive has not explained how to control the content of MGV, which is nevertheless essential to ensure compliance with the 5% limit, and is hardly binding as to the need to take into account the impact of the measure on the economy of cocoa-producing countries, which are all developing countries. 

In summary: a new chocolate containing some fat previously absent in the product in a difficult to control limit and whose presence will not always be reported next to the word “chocolate” will now be found on the market.

Chocolate containing vegetable fats will not immediately appear on the market. After the formal adoption of the new directive and its official publication, Member States have 36 months to introduce it into their internal regulations. We still have 2 or 3 years ahead of us.