Yes, Virginia, There is Such a Thing as White Chocolate

Clay Gordon
02/19/17 14:59:49
1,680 posts

There is a persistent belief that white chocolate isn’t actually chocolate. Few places serve to perpetuate this myth more than the twin temples of the Internet: Twitter and Facebook.

The most commonly mentioned argument raised in any discussion of whether white chocolate is or is not chocolate is that it doesn’t contain any cocoa solids — what’s left over after the fat (cocoa butter) is removed from the paste made of ground up cocoa nib. Even though white chocolate does contain cocoa butter, somehow it’s not chocolate.

Let me set the record straight for anyone and everyone: white chocolate is chocolate. Really. Legally. This is not an alternative fact and it’s not subject to interpretation or subject to your personal feelings about taste or texture.

The proof can be found in Title 21, Volume 1, Subchapter B, Part 163 Section 124 (21.163.124) of the US Code of Federal Regulations, which contains the definitions (also called standards of identity) for Cacao Products. The very fact that there is a specific section in CFR 21.163 defining what white chocolate is should be all the proof anyone needs to realize that white chocolate is really chocolate.

§163.124 lays out the rules for what ingredients can - and can’t be - in a cacao product for it to be legally labeled as white chocolate. If a product conforms to the specifications listed in §163.124 it can be called white chocolate. Conversely, if it does not meet the definition it cannot be called white chocolate.

That naming bit is explicitly spelled out in CFR Nomenclature: The name of the food is “white chocolate.” 

There are no ifs, ands, or buts. §163.124 is the definition for white chocolate and it is not open to second guessing.

Unfortunately, there is no entry in Snopes on this topic (though I have brought it to their attention), for those who are still skeptical.

You may not like it. You may not agree with it. But you are wrong if you persist in your belief that white chocolate is not chocolate. The only way around this is to change the law.

Ironically, most people don’t know that there is actually no legal definition for dark chocolate. What is referred to as “dark” chocolate falls into the category of “sweet” chocolate (§163.123). Unknown to most, §163.123 allows sweet chocolates to contain dairy ingredients, including:

  • Cream, milkfat, butter;
  • Milk, concentrated milk, evaporated milk, sweetened condensed milk, dried milk;
  • Skim milk, concentrated skim milk, evaporated skim milk, sweetened condensed skim milk, nonfat dry milk;
  • Concentrated buttermilk, dried buttermilk; and
  • Malted milk.

And, just to make things even crazier, there is no formal legal distinction between semisweet and bittersweet chocolate.

Take a look at the front label on a bar of Hershey’s Special Dark® (45% cocoa content) Chocolate. You will notice that “Special Dark” is a trademarked term. Elsewhere on the front label you will find the phrase “mildly sweet chocolate.” This is to let regulators and inspectors know which section of CFR 21.163 the chocolate falls into. If you take a look at the ingredients list you will find milk fat and lactose (milk). Lactose is a milk sugar.

I am not making these things up. Go look them up for yourself. All of the above information about white chocolate is objectively factual. It has nothing to do with taste or quality, or whether you like it or not, §163.124 covers what can, and can’t, be in white chocolate as well as legally naming foods that conform to the regulation.

I won’t disagree with the observation that a lot of white chocolate is not worth the calories. What determines the quality of a white chocolate is the quality of the ingredients. What most people are thinking of when the think of white chocolate is the cheapest form of white chocolate imaginable, or a chocolate-like white-ish substance where some or all of the cocoa butter is replaced by another fat.

I agree. Ick.

Much of the appeal of white chocolate is the texture. Because there are no non-fat solids (the brown part), white chocolate is basically just smooth sweet fat. As a species, homo sapiens is genetically programmed to crave sugar and fat. When you add the experience of the way chocolate melts in the mouth, you have the potential for a perfect edible trifecta.

I can tell you from personal experience that white chocolates made with undeodorized cocoa butter (cocoa butter that has not had the flavor and aroma chemicals removed) will change your mind about white chocolate. They did mine.

I can tell you from personal experience that white chocolates made with exceptional dairy will also change your mind - assuming you are open to the possibility. Try white chocolate made with goat milk. Or white chocolate made with full-cream dairy produced by cows eating tender grass growing in sun-drenched alpen glades in early Spring and undeodorized cocoa butter.

But please don’t judge all white chocolate based on your {{ shudder }} experience with drug store easter bunnies.

In closing:

  • Yes, there is such a thing as white chocolate.
  • Be open-minded: don’t assume every white chocolates sucks just because the ones you’ve eaten suck.
  • Don’t believe everything you read on the Internet. (But you can believe this.)

clay -

updated by @clay: 05/08/17 14:09:13
04/18/17 01:14:39
23 posts

cool, thanks! it's very interesting..

Eric K. Meredith
05/01/17 12:57:43
9 posts

Hello Clay,

You really know just about everything about Chocolate & especially the law, I am really hoping that you can give me some advise to understand this. Yes, I fully understand that you have the Cocoa Butter & temper the pure FILTER COCOA BUTTER to get white chocolate. This Press for Cocoa butter is driving me crazy.

I purchased a Hydraulic Cocoa Butter Press. now I purchased it from a Chinese company, which is part of my problem. They (the manufacture) sent me TWO (2) separate videos & both of the videos used (NIBBS) everything I have read & even the sales person said it is best to use COCOA PASTE/CHOCOLATE LIQUOR. But please let me explain, the videos used (NIBBS) & I can understand why.

Video #1) They put the (NIBBS) into this White Cloth bag tied & a felt pad on top of the cloth bag full of (NIBBS). Then they put a metal Plate on top of the Felt Pad & closed the lid & started the press. The Bag & felt Pad help to filter the SOLIDS out of the oil/butter. Still leaving a little bit of the solids in with the butter/oil. A dirty Creamy White oil/butter!!

Video #2) They (the manufacturer) Didn't use nothing (NO BAG & NO FELT PAD) the put the (NIBBS) STRAIGHT into the Press Chamber. put the metal Plate on top of the (NIBBS) & turned on the press. This time a WATERY CHOCOLATE came out of the press into the collection bowl.

Video #1) looked like most of the Cocoa Butter you see. But NO WHERE as clean as WHITE CHOCOLATE!!! Video #2) looked like DARK BROWN Oil/Butter. IT MUST BE FILTERED!! I can understand that the Cloth bag & felt pad help to filter the (NIBBS) oil. But if you put Chocolate Liquor/Cocoa Paste. into a bag & felt pad. I picture a CHOCOLATE MESS. IO can not even imagine putting Cocoa Paste into the press without anything. I see a real big mess.

Please, Clay, can you explain to me on how to filter the Cocoa Butter in VIDEO #1) that looks like normal Cocoa Butter. But I keep thinking, if you use the Cocoa Paste instead of the (NIBBS) in Video #1) you are going to get the same color oil as video #2) . Please, can you explain to me on how to filter the Cocoa Butter/oil?? Thanks,


Julie M. McLean
05/08/17 13:48:51
15 posts

THANK YOU Clay!!!!!! I cannot tell you how many times I have to try and explain this to non-believers! This is a very academic way to explain:)  


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